CMMC Certification will soon be a requirement for nearly all Department of Defense (DoD) contractors. For many organizations, achieving compliance may feel overwhelming. A practical way to streamline the process is through control mapping aligning existing security controls from other frameworks you already follow with CMMC requirements.
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Mapping Controls for CMMC Certification
Organizations that work with the Department of Defense (DoD) must comply with the Cybersecurity Maturity Model Certification (CMMC). Achieving CMMC Certification can be challenging, but control mapping helps simplify the process by aligning existing security frameworks with CMMC requirements.
Key crossover considerations include:
- NIST controls: Understanding how CMMC requirements relate to the NIST 800-171 framework.
- PCI DSS requirements: Mapping protections from the Payment Card Industry standards.
- HITRUST CSF framework: Leveraging its comprehensive approach to streamline compliance needs.
Working with an experienced CMMC compliance advisor ensures you implement the right controls and stay prepared not only for CMMC Certification but also for other regulatory requirements.
NIST SP 800 171 and 172 and CMMC
The foundation of CMMC Certification is built on two core NIST frameworks that regulate government data security: NIST Special Publication (SP) 800-171 and NIST SP 800-172. These publications apply to organizations that handle Controlled Unclassified Information (CUI) while working with, or alongside, U.S. government agencies.
Here’s how NIST requirements map directly into CMMC:
- CMMC Level 1: Requires a subset of the 110 Basic and Derived Requirements from NIST SP 800-171.
- CMMC Level 2: Requires full implementation of all 110 requirements from NIST SP 800-171.
- CMMC Level 3: Will add an undetermined number of Enhanced Requirements from NIST SP 800-172.
In practice, achieving CMMC Certification is largely a process of mapping NIST requirements into the CMMC model. Similarly, when mapping from other frameworks, the goal is ultimately to align them with NIST standards.
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CMMC Security Requirements from NIST
The CMMC Certification framework draws heavily from NIST SP 800-171 and NIST SP 800-172, breaking down into 14 Domains of Practices. Each domain is tied to Requirement Families in NIST and maps directly into CMMC Levels 1 and 2:
- Access Control (AC) – Restricts access to sensitive environments. 4 Practices at Level 1, 18 Practices at Level 2.
- Awareness and Training (AT) – Defines required cybersecurity training. 0 at Level 1, 3 at Level 2.
- Audit and Accountability (AU) – Governs audits, findings, and accountability. 0 at Level 1, 9 at Level 2.
- Configuration Management (CM) – Establishes baseline security settings. 0 at Level 1, 9 at Level 2.
- Identification and Authentication (IA) – Covers identity and access management (IAM). 2 at Level 1, 9 at Level 2.
- Incident Response (IR) – Requires real-time response and recovery capabilities. 0 at Level 1, 3 at Level 2.
- Maintenance (MA) – Ensures secure oversight of systems and devices. 0 at Level 1, 6 at Level 2.
- Media Protection (MP) – Regulates use, marking, and disposal of media. 1 at Level 1, 8 at Level 2.
- Personnel Security (PS) – Covers screening, onboarding, and termination. 0 at Level 1, 2 at Level 2.
- Physical Protection (PE) – Secures physical systems and workstations. 4 at Level 1, 2 at Level 2.
- Risk Assessment (RA) – Requires ongoing risk and vulnerability assessments. 0 at Level 1, 3 at Level 2.
- Security Assessment (CA) – Establishes methods to validate security controls. 0 at Level 1, 4 at Level 2.
- System and Communications Protection (SC) – Ensures secure communication channels. 2 at Level 1, 14 at Level 2.
- System and Information Integrity (SI) – Focuses on identifying and mitigating vulnerabilities. 4 at Level 1, 3 at Level 2.
For CMMC Level 3, requirements are still being finalized. However, since NIST SP 800-172 includes 35 Enhanced Requirements, Level 3 CMMC Certification will likely expand the framework to nearly 145 total Practices.
Mapping PCI DSS to CMMC Controls
The Payment Card Industry Data Security Standard (PCI DSS) applies to nearly all organizations that handle credit card payments or store cardholder data (CHD). It is managed by the PCI Security Standards Council (SSC), with enforcement from its members (e.g., Visa, Mastercard). Non-compliance can result in fines, penalties, or even loss of service.
While PCI DSS and CMMC Certification both require strict cybersecurity practices, their assessment models differ:
- PCI DSS: Levels are based on transaction volume and dictate the type of reporting and auditing required. All organizations implement the same security controls.
- CMMC: Levels are based on maturity of cybersecurity practices and dictate which controls must be implemented.
Because PCI DSS controls are standardized across organizations, they can be mapped directly onto CMMC controls, helping businesses that already comply with PCI DSS streamline their CMMC Certification process.
How the PCI DSS Requirements Compare
The PCI DSS places a strong emphasis on network security, reducing the risk of unauthorized access to cardholder data (CHD). Many of these protections also help safeguard Controlled Unclassified Information (CUI), making PCI DSS compliance a strong foundation for CMMC Certification.
Below is how PCI DSS requirements align with CMMC Domains:
- Install and Maintain Network Security Controls – All Domains
- Apply Secure Configurations to All System Components – CM
- Protect Stored Account Data – CM, MA, MP
- Encrypt CHD for Transmission over Open, Public Networks – SC, SI
- Protect All Systems and Networks from Malicious Software – CM, MA
- Develop and Maintain Secure Systems and Software – All Domains
- Restrict Access to Components by Business Need to Know – AC, IA
- Identify Users and Authenticate Access to System Components – AC, IA
- Restrict Physical Access to CHD – MP, PE
- Log and Monitor Access to System Components and CHD – AU
- Test Security of Systems and Networks Regularly – AU, SA, CA
- Support Information Security with Policies and Programs – All Domains
There is significant crossover between PCI DSS and CMMC controls, which positions organizations that are PCI-compliant to more easily achieve CMMC Certification. Mapping these requirements can reduce duplication of effort and streamline audit readiness.
HITRUST Assessments and CMMC
The HITRUST CSF is a widely adopted compliance framework that helps organizations manage cybersecurity and privacy requirements across multiple regulations. Maintained by the HITRUST Alliance, the CSF provides a comprehensive assessment protocol designed to map existing controls to different regulatory standards efficiently.
Although HITRUST assessments are not mandatory in most industries, they are a powerful tool for organizations seeking to comply with local laws, industry standards, or CMMC Certification. By using HITRUST’s “assess once, report many” approach, businesses can streamline their CMMC compliance efforts, reduce duplication across frameworks, and accelerate readiness for certification audits.
Understanding HITRUST Control Categories
Unlike PCI DSS and CMMC frameworks, the HITRUST CSF is data-agnostic, designed for maximum flexibility across all environments. Its control categories can help organizations align with multiple regulatory frameworks efficiently.
Below are the 14 HITRUST CSF Control Categories and the CMMC Domains they most closely map to:
- 00: Information Security Management Program – All Domains
- 01: Access Control – AC, IA
- 02: Human Resources Security – PS
- 03: Risk Management – RA, CA
- 04: Security Policy – All Domains
- 05: Organization of Information Security – SI, AU, AT
- 06: Compliance – All Domains
- 07: Asset Management – SI, MP
- 08: Physical and Environmental Security – PE, MP
- 09: Communications and Operations Management – SC, SI
- 10: Information Systems Acquisition, Development, and Maintenance – SI
- 11: Information Security Information Management – SI
- 12: Business Continuity Management – SC, SI
- 13: Privacy Practices – IA, RA, CA
HITRUST assessments are increasingly popular because they prepare organizations for multiple regulatory frameworks, including CMMC Certification, PCI DSS, and HIPAA. Organizations leveraging HITRUST can streamline compliance efforts, reduce audit duplication, and accelerate readiness across all frameworks
Streamline Your CMMC Certification
Organizations that work with the Department of Defense (DoD) or plan to need to prepare for CMMC Certification as soon as possible. If your organization already complies with other frameworks, such as PCI DSS, NIST, or HITRUST, control mapping can help you meet CMMC security requirements efficiently and reduce duplication across audits.
At RSI Security, we have guided countless organizations through CMMC Certification preparation. Our philosophy is simple: discipline creates freedom. Mapping and implementing controls today sets your organization up for long-term compliance success and growth.
Ready to simplify your path to CMMC Certification? Contact RSI Security today to learn how our experts can help you map controls and accelerate readiness for your audit.
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