CMMC and NIST SP 800-171

The CMMC vocabulary

Every term here has a page of its own. Each one quotes the official definition, where a source document gives one, and keeps the author's own Practitioner Guidance separate and labeled.

The terms are grouped into topics, in the order a first-time reader can read them. You can also browse the 110 Level 2 Requirements.

The contract

10 terms

• 32 CFR Part 170

  The regulation that creates the CMMC Program: the levels, the assessment types, the scoping rules, and the affirmation you sign each year.

  Also called 32 CFR 170, Part 170, the CMMC Program rule

• 48 CFR (the DFARS rule)

  The acquisition regulations. This is where the clauses live that put NIST SP 800-171 and CMMC into a contract you actually signed.

  Also called 48 CFR, DFARS, Defense Federal Acquisition Regulation Supplement

• DFARS 252.204-7012

  The contract clause that put NIST SP 800-171 on your systems and requires you to report a cyber incident to DoD within 72 hours.

  Also called 7012, DFARS 7012, Safeguarding Covered Defense Information and Cyber Incident Reporting

• DFARS 252.204-7019

  The solicitation provision that makes a current NIST SP 800-171 score in SPRS a condition of being considered for award.

  Also called 7019, DFARS 7019, Notice of NIST SP 800-171 DoD Assessment Requirements

• DFARS 252.204-7020

  The clause that keeps your NIST SP 800-171 score in SPRS, lets the Government assess you, and blocks subcontract awards without a score.

  Also called 7020, DFARS 7020, NIST SP 800-171 DoD Assessment Requirements

• DFARS 252.204-7021

  The contract clause that requires a current CMMC status at the level the contract names, an annual affirmation, and flow-down to subcontracts.

  Also called 7021, DFARS 7021, Contractor Compliance With the Cybersecurity Maturity Model Certification Level Requirements

• FAR 52.204-21

  The clause holding the 15 basic safeguarding requirements for Federal Contract Information. It is the whole of CMMC Level 1.

  Also called 52.204-21, FAR 52.204-21, Basic Safeguarding of Covered Contractor Information Systems

• Flow-down

  Passing a contract requirement to your suppliers. Under 32 CFR 170.23 the CMMC level you flow down depends on what each supplier will handle.

  Also called flowdown, flow down, flow-down clause

• Prime contractor

  The company holding the contract directly with the Government. It owns the CMMC obligation for the whole supply chain beneath it.

  Also called prime, primes

• Subcontractor

  Any company furnishing supplies or services under a prime contract. CMMC reaches every tier that handles FCI or CUI, not just the first.

  Also called sub, subs, supplier

What you protect

7 terms

• Controlled technical information (CTI)

  Controlled technical information with military or space use. It is the CUI category most defense work produces, and it must carry distribution statement B to F.

  Also called CTI, controlled technical info

• Controlled Unclassified Information (CUI)

  CUI is unclassified information a law, regulation, or Government-wide policy requires you to protect. Handling it puts you at CMMC Level 2.

  Also called CUI, Controlled Unclassified Information

• CUI marking

  The banner and designation block an agency applies to CUI. Marking is the Government's job, and an unmarked document can still be CUI.

  Also called CUI markings, banner marking, CUI banner marking, CUI designation indicator

• CUI Registry

  The National Archives list of every approved CUI category, its marking, and the law behind it. It is the authoritative list, and it is public.

  Also called the Registry, NARA CUI Registry

• Export-controlled information

  Information whose export could harm national security. It is a CUI category, but export-controlled and CUI are not the same set of information.

  Also called export control, EXPT, export-controlled

• Federal Contract Information (FCI)

  FCI is information a contract provides to you or generates for the Government that is not for public release. Holding only FCI means CMMC Level 1.

  Also called FCI, Federal Contract Information

• ITAR

  The International Traffic in Arms Regulations, which control defense articles and technical data. Showing that data to a foreign person is an export.

  Also called International Traffic in Arms Regulations, 22 CFR 120

Scope and assets

12 terms

• Boundary

  The line between what is inside your assessment scope and what is outside it. An assessor tests whether the line is actually enforced.

  Also called assessment boundary, scope boundary, boundary protection

• Contractor risk managed asset

  An asset that could handle CUI but is not intended to, kept away by written policy. It gets a plan review rather than a full assessment.

  Also called CRMA, contractor risk managed assets

• CUI asset

  An asset that can process, store, or transmit CUI. These are assessed against all 110 Level 2 requirements, so the count drives your cost.

  Also called CUI assets, Controlled Unclassified Information asset

• Customer responsibility matrix

  The document from a service provider that says which requirements it meets and which are yours. The rule requires one for every ESP.

  Also called CRM, customer responsibility matrices

• Enclave

  A separated environment built to hold the controlled work and nothing else. It is the usual way a small company keeps its assessment small.

  Also called CUI enclave, secure enclave

• External service provider

  An outside provider handling your CUI or your security protection data. What it handles decides how it enters your assessment.

  Also called ESP, external service providers

• Inheritance

  Relying on someone else's control to meet a requirement. It is allowed, and you still have to show the control exists and works.

  Also called inherited controls, inheriting

• Out-of-scope asset

  An asset that cannot handle CUI and protects nothing that does. It is not assessed, and you must be ready to justify the claim.

  Also called out-of-scope assets, OOS asset

• Scope

  The set of assets that will be assessed. Scope is the single decision that drives your cost, your evidence burden, and your assessment length.

  Also called CMMC Assessment Scope, assessment scope, scoping

• Security protection asset

  An asset that provides security functions for your assessment scope. It is in scope and assessed against the requirements it is relevant to.

  Also called SPA, security protection assets

• Shared responsibility matrix

  A cloud provider's description of which parts of security it owns and which you own. Read it as the starting point, not as your evidence.

  Also called SRM, shared responsibility model, shared responsibility matrices

• Specialized asset

  Equipment that can handle CUI but cannot be fully secured: IoT, OT, Government furnished equipment, restricted systems, and test equipment.

  Also called specialized assets

Assessment

17 terms

• Assessment objective

  One lettered determination statement inside a requirement. Every applicable objective must be met, or the whole requirement is scored not met.

  Also called assessment objectives, determination statement

• Assessor

  The certified person who conducts your assessment. Assessors test objectives against evidence, and they do not advise you on how to fix gaps.

  Also called assessors, CMMC Certified Assessor, CCA, assessment team

• C3PAO

  A CMMC Third-Party Assessment Organization. It is the company that performs a Level 2 certification assessment and charges you for it.

  Also called CMMC Third-Party Assessment Organization, third-party assessor organization

• Cyber AB

  The Accreditation Body. It is the single organization DoD contracts with to authorize and accredit the assessors and other ecosystem members.

  Also called Accreditation Body, CMMC Accreditation Body, The Cyber AB

• DCMA DIBCAC

  The Government team that assesses defense contractors directly. It performs Level 3 assessments and the High assessments under DFARS 252.204-7020.

  Also called DIBCAC, Defense Industrial Base Cybersecurity Assessment Center

• Enduring exception

  A system where full compliance is not feasible and never will be. Documented in your SSP with mitigations, it is assessed as met.

  Also called enduring exceptions

• Evidence

  What you show an assessor to prove a requirement is met. It must be final, not draft, and it must match what your plan claims.

  Also called assessment evidence, artifacts

• NIST SP 800-171

  The publication holding the 110 security requirements that make up CMMC Level 2. Revision 2 is the version the CMMC Program uses.

  Also called 800-171, SP 800-171, NIST 800-171

• NIST SP 800-171A

  The companion publication holding the assessment objectives. It is the document an assessor actually works from, so it is the one to read.

  Also called 800-171A, SP 800-171A, NIST 800-171A

• Not applicable

  A finding that a requirement or objective does not apply to your environment. It counts the same as met, and it needs a written reason.

  Also called N/A, not applicable finding

• Plan of Action and Milestones (POA&M)

  A POA&M lists the CMMC requirements you have not met, who fixes each one, and by when. It buys a Conditional status and 180 days, not a pass.

  Also called POA&M, POAM, Plan of Action and Milestones

• Policy

  A short written statement of what your organization requires. It is approved, dated, and it says what people must do, not how.

  Also called policies, security policy

• Procedure

  The written steps that carry out a policy. It names who does what, in order, and it produces the records your assessment relies on.

  Also called procedures, standard operating procedure

• Self-assessment

  An assessment you conduct on your own system. It carries the same requirements as a certification assessment and the same legal weight.

  Also called self-assessments, Level 2 self-assessment, Level 1 self-assessment

• SPRS

  The Supplier Performance Risk System. It holds your NIST SP 800-171 score, your CMMC status, and the annual affirmation you sign.

  Also called Supplier Performance Risk System

• System Security Plan (SSP)

  The document describing your system and how it meets each requirement. It is itself a requirement, and it cannot go on a POA&M.

  Also called SSP, system security plan

• Temporary deficiency

  A known gap with a fix under way, documented in an operational plan of action. Handled properly, it is assessed as met.

  Also called temporary deficiencies

Certification

11 terms

• Affirmation

  The annual statement by a senior official that you still meet the requirements. It is entered in SPRS and it carries personal weight.

  Also called affirmations, affirmation of continuous compliance, affirming official

• CMMC

  The Cybersecurity Maturity Model Certification. It is the program that verifies a defense contractor meets the security requirements already in its contract.

  Also called Cybersecurity Maturity Model Certification

• Conditional certification

  The status you hold when your assessment left items on a POA&M. It lasts 180 days and expires if the closeout does not happen.

  Also called Conditional CMMC Status, conditional status

• Data flow diagram

  A drawing of how CUI moves through your organization. It is the artifact that makes a scoping decision defensible, and it is usually done first.

  Also called data flow diagrams, CUI data flow

• FedRAMP

  The Federal program that authorizes cloud services. A cloud service holding your CUI must meet the FedRAMP Moderate baseline or its equivalent.

  Also called Federal Risk and Authorization Management Program, FedRAMP Moderate

• Final certification

  The status you hold when every requirement is met. It lasts one year at Level 1 and three years at Level 2 and Level 3.

  Also called Final CMMC Status, final status

• FIPS 140 validation

  A cryptographic module tested and certificated under the NIST validation program. Encryption that is merely strong does not satisfy the requirement.

  Also called FIPS validation, FIPS 140, FIPS-validated cryptography

• Level 1

  The 15 basic safeguarding requirements for FCI, assessed by you every year. No plan of action is permitted at Level 1, ever.

  Also called CMMC Level 1, Level 1 (Self)

• Level 2

  The 110 requirements of NIST SP 800-171, assessed by you or by a C3PAO depending on what your contract says. This is where most CMMC work happens.

  Also called CMMC Level 2, Level 2 (Self), Level 2 (C3PAO)

• Level 3

  The 24 additional requirements from NIST SP 800-172, assessed by the Government. Final Level 2 (C3PAO) is a prerequisite for even starting.

  Also called CMMC Level 3, Level 3 (DIBCAC)

• Network diagram

  The drawing of your assessment scope. Table 3 requires one for every in-scope asset category, and an assessment starts from it.

  Also called network diagrams, scope diagram