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CMP Quick Overview for NIST 800-171

There is only one reason to use CMP: to prove you’re compliant with NIST 800-171. At a high-level, these are the steps you’ll need to take.

Identify CUI
    1. Identify and describe the environment where CUI will be stored or processed.
      1. Organization Name
      2. Environment Name
      3. Environment Description
      4. Environment Contacts
      5. Operational Status
      6. System Boundary
      7. Interconnections
Assess NIST 800-171 Environment
  1. Assess the environment against the 110 NIST 800-171 controls.
    1. Understand the control requirements, and determine if the environment satisfies the requirements.
    2. Assign a control status for each control: Implemented, Not Implemented, Not Applicable, In Progress, or Not Started.
      • Implemented (Previously “Passed”) – The requirements are clearly satisfied in your environment.
      • Not Implemented (Previously “Failed”)- Your environment is unable to meet some part of the requirements.
      • Not Applicable – The control clearly does not apply to your environment (e.g. a wireless network control does not apply to your environment if you do not use wireless networking).
      • In Progress – An assessment of the current requirement has been started but has yet to be finished.
      • Not Started – An assessment of the current requirement has not yet been started.
    3. Document your rationale for assigning a status for each control. If your environment passes a control, describe precisely why. If a control is not applicable, explain in detail and leave no room for questions.
    4. Upload evidence for all non-failed controls. This evidence might be a screenshot of a technical configuration proving you pass a control. It may be an organizational policy document or a photo of a locked server cabinet. Make sure the evidence supports the claims you’ve made.
Create Plan of Action for NIST 800-171
  1. Create Plans of Action (Remediations) for all failed controls.
    1. You can still maintain NIST 800-171 compliance with failed controls, as long as you’ve documented your intentions to correct any deficiencies.
    2. Describe the deficiency and the action you will take to comply with the failed control.
Document Nist 800-171
  1. Document all your results in a System Security Plan.
    1. Attest to the accuracy of the assessment by certifying the results.
    2. Generate a new System Security Plan at the completion of the assessment and anytime changes are made.