As a defense contractor, it can be daunting to understand two complex security standards to win defense contracts. As an RPO with certified RPAs and Security Experts, we have helped several organizations navigate this maze and comply with both NIST SP 800-171 Rev 2 and CMMC. Simply put, NIST SP 800-171 Rev 2 provides the foundation for cybersecurity controls that CMMC builds upon. CMMC is a certification program, while NIST SP 800-171 Rev 2 is a set of guidelines.
If you compare NIST SP 800-171 Rev 2 and CMMC, the findings reveal that they are complementary frameworks designed to work together rather than compete. NIST SP 800-171 Rev 2 provides the technical foundation and implementation guidance, while CMMC adds the verification mechanisms and competitive advantages that defense contractors need.
Organizations that recognize this complementary relationship can optimize their compliance investments by using NIST SP 800-171 Rev 2 as a strategic mapping tool for CMMC preparation. This approach reduces implementation costs, accelerates certification timelines, and provides greater confidence in certification success.
This comprehensive blog reveals exactly how these frameworks align, where they diverge, and how to use NIST SP 800-171 Rev 2 as your strategic roadmap for CMMC success.
Important Note on NIST Versions: The DoD requires contractors to continue complying with NIST SP 800-171 Rev 2 until further notice. Therefore, this comparison focuses on Rev 2, which remains the current DoD requirement for both DFARS compliance and CMMC.
Understanding the Foundation of NIST SP 800-171 and CMMC
Both frameworks serve the same fundamental purpose of protecting Controlled Unclassified Information (CUI) in the Defense Industrial Base (DIB), but they approach this goal differently. NIST SP 800-171 Rev 2 establishes what security controls must be implemented, while CMMC adds verification mechanisms to ensure these controls are actually working as intended.
Table 1: Framework Comparison Overview
Feature | NIST SP 800-171 Rev 2 | CMMC Level 1 | CMMC Level 2 | CMMC Level 3 |
Primary Purpose | Protecting CUI in non-federal systems | Basic cyber hygiene for FCI | Creating verified CUI protection | Advanced CUI protection against APTs |
Assessment Type | Self-assessment | Self-assessment | Self-assessment OR C3PAO assessment | Government assessment (DIBCAC) |
Who Signs Assessment | Senior company official | Senior company official | Senior company official OR C3PAO assessor | DIBCAC assessors |
Number of Requirements | 110 security requirements | 17 requirements | 110 requirements (matching NIST 800-171) | 134 requirements (110 + 24 enhanced) |
Maturity Focus | Implementation of controls | Basic cyber hygiene | Implementation + demonstrated maturity | Advanced security + threat protection |
Required For | DoD contracts with DFARS 252.204-7012 | DoD contracts handling FCI | DoD contracts handling CUI | DoD contracts with critical CUI/high-value programs |
Assessment Frequency | Annual SPRS score submission | Annual self-assessment | Certification process is Triennial + Annual Affirmation of Continued Compliance | Certification process is Triennial + Annual Affirmation of Continued ComplianceTriennial |
Documentation | SSP and POA&M required | Basic documentation (SSP not required but recommended) | SSP, POA&M, plus comprehensive evidence | SSP, POA&M, plus advanced evidence and threat documentation |
This comparison reveals why NIST SP 800-171 Rev 2 serves as an ideal mapping tool for CMMC preparation. Organizations can use their NIST implementation to evaluate their readiness for CMMC requirements, identify documentation gaps, and develop remediation plans before engaging in formal CMMC assessment processes.
Comparing Security Controls Architecture
The most critical comparison lies in how each framework structures its security requirements. Understanding this architecture helps organizations leverage their existing NIST SP 800-171 Rev 2 work for CMMC preparation.
Table 2: Security Controls Architecture Comparison
Framework Element | NIST SP 800-171 Rev 2 | CMMC Level 1 | CMMC Level 2 | CMMC Level 3 |
Total Requirements | 110 controls | 17 practices focused on protecting FCI | 110 practices | 110+ practices (adds 24 from NIST SP 800-172) |
Source Framework | NIST SP 800-53 (moderate baseline) | FAR 52.204-21 | NIST SP 800-171 Rev 2 (identical) | NIST SP 800-171 Rev 2 + 24 controls from NIST SP 800-172 |
Domain Coverage | 14 security families | 6 security domains | 14 security families | 14+ security families |
Maturity Focus | Implementation | Basic cyber hygiene | Implementation + CMMC documentation | Implementation + CMMC documentation + Advanced threat protection |
This architectural comparison helps organizations to use their NIST SP 800-171 gap analysis as a precise roadmap for CMMC Level 2 preparation, since the technical requirements are identical.
Comparing Assessment and Verification
The most significant difference between these frameworks lies not in what you implement, but in how you prove you’ve implemented it correctly. This distinction has profound implications for preparation strategy and resource allocation.
Table 3: Assessment Methods Comparison
Assessment Element | NIST SP 800-171 Rev 2 | CMMC Level 1 | CMMC Level 2 | CMMC Level 3 |
Assessment Type | Self-assessment using NIST DoD Assessment Methodology | Self-assessment | Self-assessment OR C3PAO assessment (based on contract designation) | Government assessment (DIBCAC) |
Assessor Requirements | Internal team or consultant | Internal team | Internal team OR certified C3PAO | Government assessors (DIBCAC) |
Assessment Frequency | Annual SPRS score submission | Annual Self-Assessment | Certification process is Triennial + Annual Affirmation of Continued Compliance | Certification process is Triennial + Annual Affirmation of Continued Compliance |
Scoring System | 110-point scale with weighted controls | 17-point scale | 110-point scale (same as NIST SP 800-171) | 134-point scale (110 from NIST SP 800-171 + 24 enhanced from NIST SP 800-172) |
Pass/Fail Criteria | Score submission to SPRS | All controls have to be implemented. No POA&M allowed | Minimum score + mandatory pass on critical controls + limited POA&Ms applicable for certification | Minimum score + mandatory pass on critical controls + limited POA&Ms applicable for certification |
Verification Depth | Documentation review | Basic CMMC documentation review | CMMC Documentation + interviews + technical validation by a third-party | Enhanced CMMC documentation + interviews + technical validation & threat assessment by a third party |
Senior Executive Affirmation | Not required | Required annually | Required annually | Required annually |
Certificate Validity | N/A(ongoing compliance required) | 1 year | 3 years | 3 years |
This comparison reveals why NIST SP 800-171 Rev 2 assessment serves as excellent preparation for CMMC evaluation. Organizations can conduct thorough internal NIST assessments to identify and remediate gaps before engaging C3PAOs for formal CMMC certification. This approach reduces assessment costs and increases certification success rates.
Comparing Evidence and Documentation Standards
One of the most underestimated differences between these frameworks involves evidence requirements. Organizations often discover that their NIST SP 800-171 Rev 2 documentation, while technically compliant, falls short of CMMC assessment expectations.
Table 4: Documentation and Evidence Comparison
Evidence Type | NIST SP 800-171 Rev 2 | CMMC |
System Security Plan | Required, flexible format per NIST SP 800-171 requirement 3.12.4 | Required, structured format with detailed implementation descriptions |
Policy Documentation | General policies covering control families | Specific policies for each practice with implementation procedures |
Technical Evidence | Implementation description | Screenshots, logs, configuration exports, system reports |
Process Evidence | Procedure documentation | Evidence of consistent execution over time |
Training Records | General security awareness | Role-specific training with competency validation |
Incident Documentation | Incident response capability | Evidence of testing, lessons learned, improvements |
Assessment Documentation | NIST SP 800-171A Rev 2 self-assessment | CMMC Assessment Report from C3PAO or government assessor |
Using NIST SP 800-171 Rev 2 as a mapping tool helps organizations identify documentation gaps early. Internal teams or consultants can evaluate existing documentation against CMMC evidence standards, creating targeted remediation plans that address specific gaps rather than starting documentation efforts from scratch.
Comparing POA&M Management
The handling of Plans of Action and Milestones represents a critical operational difference that affects implementation strategy and resource planning.
Table 5: POA&M Management Comparison
POA&M Element | NIST SP 800-171 Rev 2 | CMMC Level 1 | CMMC Level 2 | CMMC Level 3 |
POA&M Allowed | Yes | No – POA&Ms are not permitted at any time for Level 1 self-assessments | Yes – for certain low-impact controls only. Non POA&M Controls include:AC. L2-3.1.22AC. L2-3.1.20CA. L2-3.12.4PE. L2-3.10.3PE. L2-3.10.4PE. L2-3.10.5 | Yes – permitted for non-critical requirements only. |
Allowable Items | All 110 controls can be in POA&M status | N/A (no POA&Ms allowed) | Maximum of 22 security requirements that are each valued at 1 point + 1 exception:SC. L2-3.13.11 (CUI Encryption at 3 points if partially implemented) | Selected non-critical requirements only (similar restrictions to Level 2) |
Timeline Requirements | No specific timeframes mandated | N/A | 180 days to fix allowed deficiencies—after that, the certification expires if issues aren’t resolved | 180-day maximum remediation timeline |
High-Priority Restrictions | No restrictions | N/A | POA&Ms are only allowed for 1-point controls, excluding specific 1-point CMMC CUI controls | Similar high-priority restrictions as Level 2 – critical requirements must be fully implemented |
Score Requirements | No minimum score for POA&M use | N/A | Must achieve a minimum score of 80% on initial assessment (88 out of 110 points) | Must achieve minimum score of 80% on initial assessment |
Approval Process | Self-managed | N/A | Must be approved by assessor (C3PAO for certification assessments) | Must be approved by government assessor (DIBCAC) |
Impact on Compliance | Acceptable for contract performance | N/A | Conditional Certification – eligible for contracts but only if deadline is met | Conditional Certification – eligible for contracts during remediation period |
Remediation Tracking | Internal process via SPRS | N/A | eMASS for certification assessments, SPRS for self-assessments | eMASS with automatic transmission to SPRS |
Closeout Assessment | No formal closeout required | N/A | POA&M closeout self-assessment for self-assessments; C3PAO assessment for certifications | C3PAO must conduct closeout assessment |
Consequences of non-completion | Internal risk management decision | N/A | Certification expires; contractual penalties up to termination possible | Conditional Status expires; contract eligibility impacts |
This comparison shows why NIST SP 800-171 Rev 2 assessment helps optimize POA&M strategy for CMMC. Organizations can identify which controls they can reasonably complete versus those that might require POA&M status, ensuring they meet CMMC’s more restrictive POA&M requirements while maintaining implementation momentum.
Security Domain Coverage Comparison
Understanding how security domains are addressed across frameworks helps organizations prioritize implementation efforts and identify areas requiring additional attention for CMMC preparation. The controls for CMMC Level 2 are identical to NIST SP 800-171 Rev 2. For CMMC Level 3, all controls of Level 2 are required and an additional 24 controls from NIST SP 800-172 are applicable.
Table 6: Security Domain Coverage Comparison
Security Domain | NIST SP 800-171 Rev 2 Controls | CMMC Level 1 | CMMC Level 2 | CMMC Level 3 |
Access Control (AC) | 22 controls | 4 practices | 22 practices | 22+ practices |
Awareness and Training (AT) | 3 controls | Not addressed | 3 practices | 3+ practices |
Audit and Accountability (AU) | 9 controls | 2 practices | 9 practices | 9+ practices |
Configuration Management (CM) | 9 controls | 2 practices | 9 practices | 9+ practices |
Identification and Authentication (IA) | 11 controls | 2 practices | 11 practices | 11+ practices |
Incident Response (IR) | 3 controls | Not addressed | 3 practices | 3+ practices |
Maintenance (MA) | 6 controls | Not addressed | 6 practices | 6+ practices |
Media Protection (MP) | 9 controls | Not addressed | 9 practices | 9+ practices |
Personnel Security (PS) | 2 controls | Not addressed | 2 practices | 2+ practices |
Physical Protection (PE) | 6 controls | 3 practices | 6 practices | 6+ practices |
Risk Assessment (RA) | 3 controls | Not addressed | 3 practices | 3+ practices |
Security Assessment (CA) | 4 controls | 1 practice | 4 practices | 4+ practices |
System and Communications Protection (SC) | 16 controls | 2 practices merged | 16 practices | 16+ practices |
System and Information Integrity (SI) | 7 controls | 1 practice | 7 practices | 7+ practices |
This domain analysis demonstrates how NIST SP 800-171 Rev 2 implementation creates comprehensive coverage for CMMC Level 2. Organizations can use their NIST domain assessments to identify which areas are already mature and which require additional development, creating focused preparation strategies for CMMC certification.
Comparing Implementation Timeline and Resource Planning
The timeline differences between NIST SP 800-171 Rev 2 implementation and CMMC preparation reflect the additional verification and documentation requirements inherent in certification processes.
Table 7: Implementation Timeline Comparison
Implementation Phase | NIST SP 800-171 Rev 2 | CMMC Level 1 | CMMC Level 2 | CMMC Level 3 |
Initial Assessment | 2-4 weeks | 1-2 weeks (basic gap analysis) | 3-6 weeks (includes CMMC-specific gap analysis) | 4-8 weeks (comprehensive assessment including advanced controls) |
Control Implementation | 6-12 months | 2-4 months (basic controls) | 6-12 months | 12-18 months (This includes enhanced controls from NIST SP 800-172) |
Documentation Development | 2-4 months | 1-2 months (basic documentation) | 4-8 months (enhanced evidence requirements) | 6-12 months (comprehensive CMMC documentation + advanced evidence) |
Pre-Assessment Testing | Optional | 1 week (recommended) | 2-4 weeks (recommended for certification success) | 4-6 weeks (critical for DIBCAC assessment) |
Formal Assessment | 1-2 weeks (self-assessment) | 1-2 days(self-assessment) | 1-2 weeks(self-assessment) or 3-5 days(C3PAO assessment with a Certification Audit) | 1-2 weeks (DIBCAC assessment) |
Remediation Period | Ongoing via POA&M | 180 days maximum for POA&M items | 180 days maximum for POA&M items (limited scope) | 180 days maximum for POA&M items (limited scope) |
Maintenance Effort | Quarterly reviews, annual SPRS updates | Annual recertification preparation | Triennial recertification preparation | Triennial recertification preparation + continuous monitoring |
Using NIST SP 800-171 Rev 2 as a foundation significantly reduces CMMC implementation timelines. Organizations with mature NIST implementations can focus their CMMC preparation efforts on documentation enhancement and evidence collection rather than fundamental control implementation.
Cost Analysis Comparison
Understanding the cost implications helps organizations plan their compliance investments and optimize their approach to both frameworks.
Table 8: Cost Structure Comparison
Cost Category | NIST SP 800-171 Rev 2 | CMMC Level 1 | CMMC Level 2 | CMMC Level 3 |
Initial Implementation | $80,000-$200,000 (medium org) | $15,000-$40,000 (basic controls only) | $20,000-$60,000 | $100,000-$200,000 additional (for enhanced controls) |
Technology Investment | Security tools and platforms | Basic security tools | Enhanced monitoring and evidence collection tools | Advanced security platforms + threat hunting tools |
Personnel Costs | Security staff and training | Minimal additional staff | Additional certification coordination resources | Dedicated advanced security personnel |
Documentation Costs | Basic SSP and procedures | Simple documentation package | Enhanced CMMC documentation and evidence management | Comprehensive CMMC documentation + advanced procedures |
Assessment Costs | Internal or consultant-led | $5,000-$15,000 (self-assessment support) | $30,000-$60,000 for C3PAO assessment | $50,000-$100,000 for DIBCAC assessment preparation |
Ongoing Maintenance | $30,000-$80,000 annually | $10,000-$25,000 annually | $40,000-$100,000 annually (including recertification) | $80,000-$150,000 annually(including advanced monitoring) |
External Consulting | Optional optimization | Basic gap assessment | Recommended for certification preparation | Essential for advanced controls implementation |
Total 3-Year Cost Estimate | $170,000-$440,000 | $60,000-$155,000 | $230,000-$520,000 | $470,000-$850,000 |
This cost comparison demonstrates the value of using NIST SP 800-171 Rev 2 as a foundation. Organizations that invest properly in NIST implementation find their CMMC costs focus on assessment preparation and documentation enhancement rather than fundamental security program development.
Using NIST SP 800-171 Rev 2 as Your CMMC Mapping Tool
The strategic advantage of this framework relationship lies in using NIST SP 800-171 Rev 2 as a comprehensive mapping tool for CMMC preparation. Here’s how organizations can leverage this approach:
1. Internal Readiness Assessment
Conduct thorough NIST SP 800-171 Rev 2 assessments using the NIST DoD Assessment Methodology with internal teams or consultants to identify technical implementation gaps, documentation deficiencies, and evidence collection needs before engaging in formal CMMC processes.
2. Remediation Planning
Use NIST assessment results to develop targeted remediation plans that address specific CMMC requirements, focusing resources on areas most likely to impact certification success.
3. Documentation Enhancement
Evaluate existing NIST documentation against CMMC evidence standards, identifying specific enhancements needed to meet assessor expectations without over-documenting areas already meeting requirements.
4. Pre-Assessment Validation
Leverage NIST assessment methodology to conduct mock CMMC assessments, identifying potential assessment issues and addressing them before formal certification activities.
5. Cost Optimization
Use NIST implementation maturity to determine optimal CMMC certification timing and approach, ensuring maximum return on compliance investments.
Key Resources and References
NIST SP 800-171 Rev 2 – Current DoD requirement
CMMC Final Rule – 32 CFR Part 170
CyberAB – CMMC certification body
DoD CMMC Information – Official DoD CMMC resources
SPRS – Supplier Performance Risk System
The future of defense cybersecurity lies not in choosing between these two frameworks but in understanding how they work together to create comprehensive, verified protection for controlled unclassified information (CUI).
Whether your goal is efficient self-assessment or successful third-party certification, the path forward begins with understanding how your current NIST SP 800-171 Rev 2 implementation translates to CMMC requirements. This comparison provides the roadmap—the implementation success depends on how strategically you leverage these insights.
The Bottom Line is that NIST SP 800-171 Rev 2 remains your best investment for CMMC preparation. The identical technical requirements at Level 2 mean that every dollar and hour invested in proper NIST implementation directly advances your CMMC certification readiness. Focus on closing NIST gaps, enhancing documentation, and building evidence collection processes.
How databrackets can help you comply with NIST SP 800-171 and CMMC
At databrackets, we bring over 12 years of proven expertise in helping organizations achieve compliance with some of the most rigorous cybersecurity and data privacy standards, including ISO 27001:2022, SOC 2, HIPAA, and more.
As an authorized Registered Provider Organization (RPO) for CMMC with RPs and RPAs and a pending C3PAO candidate, we specialize in assisting organizations navigate the complexities of NIST SP 800-171 Revision 2, a critical component for securing Department of Defense (DoD) contracts. Our team specializes in providing practical, effective guidance that transforms CMMC compliance from a daunting obstacle into a strategic business enabler. If you would like to receive a free SSP Template, you can email us at sales@databrackets.com
Given below is our comprehensive suite of deliverables to help you prove your compliance with CMMC 2.0
Readiness & Implementation Support
Network Diagram
CUI Flow Diagram
CUI System Boundary
FIPS Validation Diagram
Shared control matrix
Creating your SSP
Customized Policies and Procedures
Data Breach Policy
Vulnerability Scan Report
Vendor Compliance Assessment
Advisory Services and Audit Support
Customized CUI Awareness Training (Optional / On-Demand)
- Other Customized Policies & Procedures
Schedule a Consultation if you would like to understand how we can customize our services to meet your specific requirements.
Overview of databrackets
Our team of security experts has supported organizations across a wide variety of industries to align their processes with security frameworks like ISO 27001:2022, SOC 2, HIPAA, 21 CFR Part 11, NIST SP 800-53, NIST Cybersecurity Framework, NIST SP 800-171, GDPR, CMMC etc. We are an authorized certifying body for ISO 27001 and a Registered Practitioner Organization for CMMC. We are also a candidate C3PAO organization for CMMC awaiting our DIBCAC Audit. We have partnerships to help clients prepare for and obtain other security certifications. We are constantly expanding our library of assessments and services to serve organizations across industries.
Author: Aditi Salhotra, Digital Marketing and Business Development, databrackets.com
Aditi is a Digital Marketing and Business Development Professional at databrackets.com. She graduated with honors in Marketing from Sheridan College, Canada. In addition to her current profile, she contributes to Product Development and Content Creation. She is a strong advocate of Good Cyber Hygiene and white hat SEO techniques. She is proud of the company’s mission to safeguard organizations from cyber threats and ensure their business continuity in adverse situations.
Technical Expert: Srini Kolathur, Director, databrackets.com
The technical information presented in this blog has been carefully reviewed and verified by our Director, Srini Kolathur. Srini is results-driven security and compliance professional with over 20 years of experience supporting, leading, and managing global IT security, compliance, support, and risk assessment in fortune 100 companies. Some of his key areas of focus are SOC 2, ISO 27001, NIST 800-171, NIST 800-53, NIST Cybersecurity Framework, HIPAA, Security Risk Assessment, CMMC 2.0 among others. He is a CMMC Registered Practitioner (RP), CISSP, CISA, CISM, MBA. He is active in several community groups including Rotary International and TiE.