If your organization works with U.S. government agencies, including the Department of Defense, you may be required to undergo CMMC assessments and NIST assessments. Preparing for these assessments starts with identifying the standards relevant to your contracts, conducting a readiness review, implementing the necessary controls, and collaborating with an accredited assessor to ensure compliance.
Not sure if your organization is ready? Schedule a consultation today to evaluate your CMMC assessment readiness and streamline your compliance process.
CMMC and NIST Assessment Preparation: A Step-by-Step Guide
The National Institute of Standards and Technology (NIST) develops cybersecurity frameworks that help U.S. government agencies and contractors protect sensitive data. These frameworks specify the security controls organizations must implement, while agencies like the Department of Defense define the exact requirements for CMMC and NIST assessments.
Preparing for CMMC assessments or NIST audits can be complex. To simplify the process, organizations should follow these four essential steps:
- Identify applicable regulations and frameworks for your contracts.
- Assess current systems and architecture against the relevant standards.
- Implement or map required controls to meet compliance requirements.
- Conduct official assessments, whether self-led, third-party, or government-led.
Working with an experienced Compliance Advisor can streamline the process, helping your organization not only meet but exceed CMMC and NIST assessment requirements.
Determine Which Regulations Apply for CMMC Assessments
For government contractors, the NIST SP 800-30 risk assessment framework provides best practices for evaluating security risks. Depending on the type of data your organization handles, you may also need to comply with additional frameworks to ensure full compliance.
In defense and military work, two primary types of data are tightly regulated:
- Controlled Unclassified Information (CUI): Technical, maintenance, and other sensitive data critical to national security. The Information Security Oversight Office (ISOO) CUI Registry lists CUI categories across federal agencies.
- Federal Contract Information (FCI): Information related to government contracts, including details about the work and involved parties.
To protect CUI, organizations must follow NIST SP 800-171, which establishes essential security controls. Building on this, the Cybersecurity Maturity Model Certification (CMMC) introduces additional safeguards for both CUI and FCI, specifically for defense contractors.
Before starting your CMMC assessment preparation, carefully review your contracts and consult with agency stakeholders. This ensures you understand whether a NIST risk assessment alone is sufficient or if you’ll need to pursue full CMMC certification.
Understanding CMMC Maturity Levels and Assessments
The Cybersecurity Maturity Model Certification (CMMC) is a framework specifically designed for Department of Defense (DoD) contractors. Overseen by the DoD’s Chief Information Officer (DCIO) and the Office of the Undersecretary of Defense for Intelligence and Security (OUSD), CMMC ensures that organizations in the Defense Industrial Base (DIB) maintain the cybersecurity maturity necessary to protect sensitive military data and, by extension, national security.
CMMC assessments certify organizations at one of three maturity levels, each with increasing security practices and assessment rigor:
- CMMC Level 1 – Foundational
- Implements 15 practices derived from NIST SP 800-171
- Requires annual self-assessment and self-attestation
- CMMC Level 2 – Advanced
- Implements 110 practices covering the full scope of NIST SP 800-171
- Requires triennial third-party assessments for most contractors
- CMMC Level 3 – Expert
- Implements advanced practices adapted from NIST SP 800-172
- Requires triennial government-led assessments
In most cases, the CMMC assessment level required will be clearly stated in your DoD contract. Reviewing these requirements early ensures your organization targets the appropriate maturity level from the start.
Consider a Preparatory NIST Assessment Before Your CMMC Assessment
After identifying which regulations apply, it can be tempting to move straight into implementing controls and scheduling an official audit. However, a more strategic approach is to start with a readiness or preparatory assessment to evaluate your current compliance posture. This step can be performed internally or with the guidance of a qualified NIST or CMMC advisor.
A preparatory NIST assessment or vulnerability review provides valuable insights into gaps in your existing security framework. It can reveal missing controls, misconfigurations, or areas that need improvement before an official CMMC assessment. In some cases, it can also confirm that many of your current controls are already mapped effectively, reducing both the time and cost required to achieve full compliance.
Mapping NIST Requirements to Other Frameworks for CMMC Assessments
Many government contractors have already implemented controls from widely used NIST standards, such as the Cybersecurity Framework (CSF) or NIST SP 800-53: Security and Privacy Controls for Information Systems and Organizations.
If your organization has completed a NIST CSF or SP 800-53 assessment, you may already be well-positioned for SP 800-171 implementation. These frameworks often include mapping guidance that shows how existing controls correspond to new requirements, helping streamline both NIST and CMMC assessment preparation.
For example, according to the mapping tables in SP 800-171:
- Requirements 3.1.1 and 3.1.2 align with SP 800-53 controls:
- AC-2 (Account Management)
- AC-3 (Access Enforcement)
- AC-17 (Remote Access)
- Requirement 3.1.3 aligns with AC-4 (Information Flow Enforcement)
- Requirement 3.1.4 aligns with AC-5 (Separation of Duties)
This overlap means that if your organization already follows SP 800-53 controls, integrating SP 800-171 and preparing for a CMMC assessment can be significantly easier. In many cases, the process focuses less on building entirely new safeguards and more on mapping and optimizing existing protections.
Implement NIST Requirements and CMMC Practices
After completing a readiness review, the next step in your CMMC assessment preparation is implementing the required security practices. Whether your goal is NIST compliance or achieving a specific CMMC level, your organization will need to follow the controls outlined in NIST SP 800-171, and, for higher maturity levels, SP 800-172.
Here’s a breakdown of the key practices required for CMMC Level 2 (aligned with NIST SP 800-171), along with potential enhancements for CMMC Level 3:
- Access Control: 21 requirements (2 Basic, 19 Derived) + 3 Enhanced (Level 3)
- Awareness & Training: 3 requirements (2 Basic, 1 Derived) + 2 Enhanced (Level 3)
- Audit & Accountability: 9 requirements (2 Basic, 7 Derived)
- Configuration Management: 9 requirements (2 Basic, 7 Derived) + 3 Enhanced (Level 3)
- Identification & Authentication: 11 requirements (2 Basic, 9 Derived) + 3 Enhanced (Level 3)
- Incident Response: 3 requirements (2 Basic, 1 Derived) + 2 Enhanced (Level 3)
- Maintenance: 6 requirements (2 Basic, 4 Derived)
- Media Protection: 9 requirements (3 Basic, 6 Derived)
- Personnel Security: 2 requirements (all Basic) + 2 Enhanced (Level 3)
- Physical Protection: 6 requirements (2 Basic, 4 Derived)
- Risk Assessment: 3 requirements (1 Basic, 2 Derived) + 7 Enhanced (Level 3)
- Security Assessment: 4 requirements (all Basic) + 1 Enhanced (Level 3)
- System & Communications Protection: 16 requirements (2 Basic, 14 Derived) + 5 Enhanced (Level 3)
- System & Information Integrity: 7 requirements (3 Basic, 4 Derived) + 7 Enhanced (Level 3)
By completing these practices, your organization will be well-prepared for NIST assessments and CMMC certification. At this stage, many organizations choose to conduct a follow-up readiness assessment to confirm all gaps have been addressed before beginning the official audit.
Conduct a CMMC or NIST Assessment
The final step in your compliance journey is completing the CMMC assessment or NIST assessment required for your contracts.
For organizations eligible to self-assess, the process is relatively straightforward. The Department of Defense’s Chief Information Officer (DCIO) provides documentation for CMMC Level 1 and CMMC Level 2 self-assessments, allowing organizations to complete the evaluation at their own pace.
If a third-party or government-led assessment is required, you’ll need to engage an accredited auditor in advance. For CMMC Level 2 third-party assessments, the Cyber AB (formerly the CMMC Accreditation Body) certifies trusted vendors. The most effective partners go beyond testing, helping you implement, validate, and optimize controls holistically.
Government-led assessments are still being finalized. While exact requirements remain under development, the CMMC 2.0 framework emphasizes flexibility, focusing on relative security maturity and continuous improvement over time. Organizations earlier in their cybersecurity journey may not yet be ready for full exposure to Controlled Unclassified Information (CUI) or the risks associated with handling it at scale.
Regardless of your certification level, RSI Security provides expert support to help your organization prepare, pass, and maintain compliance for both CMMC and NIST assessments.
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