TOP 10: Challenges of NIST 800-171 for Companies to Meet DOD Cybersecurity Contracting Requirements

The National Institute of Standards and Technology (NIST) Special Publication 800-171, “Protecting Controlled Unclassified Information in Nonfederal Information Systems and Organizations,” is a set of cybersecurity standards and guidelines that companies use to meet the cybersecurity contracting requirements levied by the Department of Defense (DOD).

Here are the top ten issues that companies may face when using NIST 800-171 to meet these requirements:

1. Understanding the scope of NIST 800-171: NIST 800-171 applies to nonfederal organizations that process, store, or transmit controlled unclassified information (CUI) on behalf of the federal government. Companies must understand the scope of NIST 800-171 and how it applies to their operations to implement the requirements effectively.
2. Mapping CUI to NIST 800-171 requirements: NIST 800-171 includes a variety of requirements that cover various aspects of cybersecurity, including access control, incident response, and media protection. Companies may have difficulty mapping the CUI they handle to the specific NIST 800-171 requirements that apply.
3. Implementing technical controls: NIST 800-171 includes specific technical controls that must be implemented to protect CUI. These controls may be challenging for companies to implement, particularly if they do not have the necessary resources or expertise.
4. Establishing a risk management program: NIST 800-171 requires companies to develop a risk management program that includes risk assessments, treatments, and acceptance. This can be a complex process that requires significant resources and expertise.
5. Maintaining documentation: NIST 800-171 requires companies to maintain detailed documentation of their cybersecurity program, including policies, procedures, and compliance records. This can be a time-consuming and resource-intensive process.
6. Ensuring ongoing compliance: NIST 800-171 requires companies to continuously monitor and assess their cybersecurity program to ensure it remains compliant with the requirements. This can be a challenging task, particularly for companies with limited resources.
7. Managing supply chain risks: NIST 800-171 requires companies to assess and manage risks associated with their supply chain, including the cybersecurity practices of their partners and suppliers. This can be a complex and time-consuming process.
8. Handling data breaches: NIST 800-171 requires companies to have the plan to respond to data breaches and other cybersecurity incidents. This can be challenging, particularly for companies that do not have the necessary resources or expertise.
9. Providing training and awareness: NIST 800-171 requires companies to provide training and awareness to their employees on the importance of cybersecurity and the specific requirements of NIST 800-171. This can be a time-consuming and resource-intensive process.
10. Assessing vendor capabilities: NIST 800-171 requires companies to assess the cybersecurity capabilities of their vendors and partners. This can be complex and time-consuming, particularly for companies with many vendors.

NIST 800-171 is a comprehensive set of cybersecurity standards and guidelines companies use to meet the cybersecurity contracting requirements levied by the Department of Defense. Implementing NIST 800-171 can be challenging, particularly for companies with limited resources or expertise. It is vital for companies to carefully assess their capabilities and develop a plan for effectively implementing the requirements of NIST 800-171 to protect CUI and meet the cybersecurity contracting requirements of the DOD.

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