Policy templates and tools for CMMC and 800-171

This page has links and reviews of available templates and tools relating to the CMMC and NIST SP 800-171

**Updated December 16, 2022**

Please help others in the community by leaving a comment with resource links!


Defense Industrial Base Cybersecurity Assessment Center (DIBCAC)

https://www.dcma.mil/DIBCAC/

This page on the Defense Contract Management Agency’s (DCMA) website has several great resources for defense contractors in the final stages of preparation for 800-171 or CMMC assessment.

In particular, check out the following:

Public 800-171 Self-Assessment Database – This is an Access database that captures data during an assessment and calculates scores based on findings.

Pre-assessment package for candidate C3PAO assessments. – This package gives some expectations for inheritance, not applicable practices, and evidence. Real CMMC assessments of defense contractors will ask many of these questions during planning.

DoD Assessment Methodology – How DIBCAC performs an 800-171 assessment and scores it

DoD Cybersecurity Toolbox – Answers to tough questions about defense cybersecurity, referenced by DIBCAC and CMMC assessors as clarification.


Checklist to evaluate your Managed Service Provider

https://ndisac.org/wp-content/uploads/2022/12/NDISAC-SMB-WG-MSP-Shopping-Questionnaire-Rev-4.5.pdf

This document is half training, half scoring template. It is designed to help a small or medium sized defense contractor evaluate Managed Services Providers for CMMC. Very few MSPs know what they are doing in regard to CMMC compliance. If you don’t have a big enough company to staff a full IT and cybersecurity department, choosing a CMMC-knowledgeable MSP is critical.


Free CUI Training from Department of Defense

https://securityawareness.usalearning.gov/cui/index.html

This training course introduces Controlled Unclassified Information and provides guidance for marking and protecting it.


US-CERT – Threat Intelligence

https://www.cisa.gov/cybersecurity

Subscription page for Threat Intelligence bulletins

Both CMMC and NIST SP 800-171 require that you pay attention to sources of cyber threat intelligence. For most of us, the easiest way to achieve this is to subscribe to the U.S. Cybersecurity & Infrastructure Security Agency (CISA) bulletins.

Check the bottom of the CISA page for a subscribe link. The information they provide is eye-opening.


Free Cybersecurity Awareness Training

https://public.cyber.mil/training/cyber-awareness-challenge/

This training includes general cybersecurity awareness as well as indicators of insider threat. Small businesses can send their employees to this link and collect the certificates of completion to meet two CMMC requirements.


SANS Institute – Security Policies

https://www.sans.org/information-security-policy/

SANS Institute provides a set of best practices security policies in both PDF and DOC format. No registration required. These policies aren’t designed for 800-171 or CMMC so you will need to rework them significantly.


Kieri Compliance Documentation

https://www.kieri.com/kcd

This is a plug for our sponsor, Kieri Solutions. If you are seeking a set of CMMC-specific policy, procedures, and a partially written system security plan (which would take 200 hours worth of work to build from scratch) and you are willing to pay a modest fee, Kieri Solutions sells an excellent product called the Kieri Compliance Documentation. We feel this is the best CMMC template package available! Kieri Solutions passed their CMMC assessment using this core documentation. This template set can help you (at least partially) meet more than 240 assessment objectives out of 320.


DoD Environmental Research Programs templates for NIST SP 800-171

https://www.serdp-estcp.org/Tools-and-Training/Installation-Energy-and-Water/Cybersecurity/Templates-and-Checklists

Evaluation: This site has about twenty downloadable documents ranging from Incident Response forms to a full IT policy document. The ESTCP IT Policies and Procedures template looks to have a wide range of standard policies included. They are all in one long document, which means you will need to do some cross-referencing to show which chapter relates to which control. Update: ESTCP has re-pushed this in DOC (Microsoft Word) format to make it easier to edit (cheers!) No sign-up required. This looks like the best free template set on the Internet. The documents were updated in 2018 and 2019, which makes them quite recent.


Educational Institutions – Reference System Security Plan

https://www.regulatedresearch.org/resources/peer-practices/ssp

This System Security Plan can be requested for free by anyone with an .edu email address. It has sample responses to about 40 of the 800-171 and CMMC Level 2 requirements.


Shared Responsibility Matrix template for CMMC

https://www.c3paoforum.org/wp-content/uploads/2022/05/Shared-Responsibility-Matrix-Template-C3PAOForum.docx

This template is not perfect (double-check the numbering) but is a great starting point to have a conversation with your Managed Services Provider or MSSP about their services.

Typically, your supporting organization will fill this template out entirely and provide it back to you under NDA. This is a great way to define a service offering that supports CMMC. MSPs typically realize that they need to change their pricing structure and take over more responsibilities when they complete a Shared Responsibility Matrix at this level of detail.


StateRAMP Policy Templates for 800-53 controls

https://stateramp.org/templates-resources/

These policy templates are overkill for CMMC and expect you to do a lot of writing to fill in the specifics, but if you are subject to FedRAMP because you offer cloud storage for CUI, I would start here.


NIST SP 800-171 System Security Plan Template

https://csrc.nist.gov/CSRC/media/Publications/sp/800-171/rev-2/final/documents/CUI-SSP-Template-final.docx

This is a template for the DFARS 7012 System Security Plan provided by NIST. System Security Plans are currently required for DoD contractors that hold Controlled Unclassified Information (CUI).

*Updated*: Training video on how to create a system security plan using the NIST template

Evaluation: You can’t go wrong by starting with this free template for your 800-171 self-assessment. It is also a good starting point for CMMC (though you will need to update the requirement IDs). The word document lists each control and gives you room to provide descriptions, evidence, and compliance status. You could use this document to overview your entire self certification process and print it out for an auditor.

This resource can help you meet the CMMC requirement to have a System Security Plan. It also makes it easier to provide evidence that you are meeting several other architectural and “define” requirements.


NIST SP 800-171 Plan of Action & Milestones (POAM) Template

https://csrc.nist.gov/CSRC/media/Publications/sp/800-171/rev-2/final/documents/CUI-Plan-of-Action-Template-final.docx

This is a template for the DFARS 7012 Plan of Action & Milestones (POA&M) which is currently required for DoD contractors that hold Controlled Unclassified Information (CUI).

Evaluation: You can’t go wrong by starting with this free template for your 800-171 self-assessment or to support your CMMC compliance efforts. You could use this document to overview your entire self certification process and print it out for an auditor.

This resource can help you meet the CMMC requirement to have a Plan of Action.


CMMC Official Assessment Guides

https://dodcio.defense.gov/CMMC/Documentation/

This is the official CMMC website hosted by the DoD. The documents on this page are as official as it gets.

Use the Assessment Guides to understand the full complexity of each practice.


NIST SP 800-171A Assessor’s Guide

https://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-171a.pdf

This guide is very similar to the CMMC Assessment Guides above, but includes additional information such as Appendix D, and the Non-Federal Organization controls, which were left out of CMMC documents.


How to write a System Security Plan

https://www.youtube.com/watch?v=uUPB5vUl3ug&t=464s

This video shows the thought process and level of detail you should use when writing a system security plan. If you are new to compliance, it is a must watch!


FedRAMP approved vendors list

https://marketplace.fedramp.gov/#!/products?sort=productName

DoD contractorsare currently required to use only Cloud Providers that are at least FedRAMP Moderate, IF they put CUI into that cloud. The FedRAMP marketplace lists companies that are either in-progress or approved, and their FedRAMP level.

Quote from DFARS 7012 regulation:

(D) If the Contractor intends to use an external cloud service provider to store,
process, or transmit any covered defense information
in performance of this contract, the Contractor
shall require and ensure that the cloud service provider meets security requirements equivalent to
those established by the Government for the Federal Risk and Authorization Management Program
(FedRAMP) Moderate baseline
(https://www.fedramp.gov/resources/documents/) and that the cloud
service provider complies with requirements in paragraphs (c) through (g) of this clause for cyber
incident reporting, malicious software, media preservation and protection, access to additional
information and equipment necessary for forensic analysis, and cyber incident damage assessment.


DoD Cyber incident reporting procedures

https://www.acq.osd.mil/dpap/dars/pgi/pgi_htm/current/PGI204_73.htm

DoD contractors with CUI (this translates to CMMC Level 2 and 3) are currently required to report cyber-incidents to the DoD.

This is the Procedures Guidelines Instructions document which describes the back-and-forth process of reporting, and potential investigation, after a cyber incident.


Incident Response Tabletop Exercises

https://www.cisa.gov/cisa-tabletop-exercise-packages

These are packages of incident scenarios that CISA.GOV makes available for free to everyone. By reviewing these, you can utilize more creative scenarios or realize weaknesses in your current incident training program.


NIST Cryptographic Module Validation Program (CMVP)

https://csrc.nist.gov/Projects/cryptographic-module-validation-program/validated-modules/Search

You will want to use this website to verify that your cryptographic modules are “validated” according to FIPS 140-2. Assessors want to see the actual certificates relating to the encryption you use in your environment, if that encryption protects the confidentiality of CUI.

This resource is used to provide evidence that you are performing the CMMC requirement to use FIPS validated cryptography.


National Checklist Program

https://ncp.nist.gov/repository

Detailed guidance on how to apply secure configurations to hundreds of types of systems. Used primarily by the U.S. federal government.

This resource can help you meet the CMMC requirement for secure configurations.


Secure Technical Implementation Guidance (STIGs)

https://nvd.nist.gov/ncp/repository

One of the CMMC requirements is CM.2.064 “Establish and enforce security configuration settings for information technology products employed in organizational information systems.” While this can be interpreted in MANY ways, one way to meet this is to apply STIGs on your environment.

NIST provides security configuration settings at the above link. This is a pretty complex topic and a lot of work. I recommend talking to a security consultant with DoD experience if you haven’t encountered STIGs before.

This resource can help you meet the CMMC requirement for secure configurations.


Secure Cloud Business Applications (SCuBA)

https://www.cisa.gov/scuba

This website, hosted by CISA.GOV, contains detailed guidance on secure configurations for Microsoft 365 cloud and Google Cloud. Will eventually have configurations for other popular cloud products.

This resource can help you meet the CMMC requirement for secure configurations.


Manual Vulnerability Search

https://nvd.nist.gov/vuln/search

One of the most basic cybersecurity requirements (included in CMMC level 1, “FAR Critical 17”, and NIST 800-171) requires that you identify and correct vulnerabilities.

CMMC SI.1.210: “Identify, report, and correct information and information system flaws in a timely manner.”

This database, provided by NIST, has a list of all US Government published software and hardware vulnerabilities. Each vulnerability (called a CVE) is described in detail with links for patches or manual corrective action (if exists). This database is moderately difficult to use since the results can be overwhelming.

To get started, I recommend searching for a specific software on your computers or mobile phones. For example, try searching “Zoom Client” which is a popular meeting app with major vulnerabilities that were fixed in mid-2020.

This resource can help you meet the CMMC requirement for identifying vulnerabilities.


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17 thoughts on “Policy templates and tools for CMMC and 800-171

  1. John Dillard says:

    Great post. On the opening advisory on using compliance tools and the sensitivity — I agree 100% (and I say that as the provider of a platform that does this). Our company (ThreatSwitch, full disclosure) has been processing PHI/PII related to classified contracts for a long time so we built on a Fedramp environment (AWS Govcloud) and got SOC2 compliant very early on. I have not seen a single vendor other than us do anything remotely similar. As far as I know, we’re the only one using a FEDRAMP medium environment. Do be cautious — especially of products that only do the compliance crosswalk at a very low price. If it’s cheap, there is no early possibility that they are spending adequately on data security.

  2. Robin Desmore says:

    Thank you for putting this is straightforward explanations but also providing the links and summary of each! Extremely helpful!

    • R. A. Renk says:

      Just wish to point out that the site listed in the comments for https://www.dodcui.mil is NOT sponsored by the OUSD(A&S). It is sponsored by the OUSD(I&S) which has the DoD charter to establish DoD CUI policy. (DoDI 5200.48 2.1.a)…This is an entirely different organization.

      And the link to the CMMC page on the site gets the DFARS clause wrong…

      • Amira Armond says:

        Hello Randy,
        Whoops! I fixed the attribution from A&S to I&S on this page. I can’t do anything about the dodcui.mil website having the wrong DFARS clause quoted… it looks like they link to the correct place though. Thanks for the feedback!
        Amira

  3. Rodney Bassett says:

    I have a question regarding the overall process. I am an IT Consultant that has a client that is planning on becoming Level 3 certified. I handle all of their IT. Do I, as an individual, need to be certified Level 3 as well in order for my client to be Level 3? Or can this be handled by an NDA of some sort?

    • Amira Armond says:

      Hello Rodney,
      I recommend checking this recent webinar from Defense Acquisition University (the slide deck can be reached from this link)
      https://www.dau.edu/events/Cybersecurity%20Maturity%20Model%20Certification

      To my understanding, a consultant needs a CMMC Level 3 information system if they ….
      1) Store or process security vulnerability information (CUI) regarding their client’s network on the consultant’s information system. Example: You have a document on your personal laptop which lists firewall rules for the client network.
      2) Manage the client’s network (CUI systems) using the consultant’s information system. Example: You use your personal laptop to VPN into the client network and manage their file server.

      If the client issues you an account and a client-issued workstation to perform your work, and you don’t remove their sensitive documents from their network, you shouldn’t need any special certification or information system. In this situation, you would be roughly equivalent to the client’s in-house IT employee from a security standpoint.

  4. Cary Anderson says:

    I perused the policies and procedures availabe on here, and found policies – but not procedures/processes. I am probably missing something.

    • Amira Armond says:

      Hi Jeff,

      When you ask for a CMMC template, could you give a bit more information about what you are thinking of? A CMMC-specific policy? System security plan? What level of CMMC? There are some great resources here that absolutely fit CMMC (even the 800-171 stuff is a great fit), but it can be hard to see the trees for the forest.

      • Elliott Long says:

        Hello Amira,

        The kind of “template” I would like to see if a mapping of CMMC Practices to remediation tool. I realize that many of the remediation solutions are met with an organizational policy, but many of the practices require “technology”. I find the “technology” to be very interpretive, I could use a FW, or AD, or IDS, … hard to say, … has anyone constructed a good mapping of CMMC practices to Technology Remediations?

        • Amira Armond says:

          Hello Elliot,
          I recommend checking the link to the CMMC Center Of Awesomeness (CMMC-COA). There is a spreadsheet with recommended solutions on their site. Please note that I have concerns that some of their cloud vendor solutions (specifically Rapid 7) are not appropriate for CUI, as they are not FedRAMP accredited. Some cybersecurity professionals feel that antivirus and vulnerability scans are out of scope, but the DCMA has indicated that an antivirus that processes files with CUI can be in scope. CMMC, CUI, and Cloud Vendors – do you need FedRAMP?

  5. Michael Chipley says:

    CMMC, thanks for informing ESCTP the Information Systems Policies and Procedures template was posted in pdf format. The Word version will be posted so folks will not have to copy and paste.

    We are also posting a Ransomware Table-Top Exercise and After-Action Report templates in Word format.

  6. Michael Chipley says:

    The Installations and Environment Facilities Community created the various templates and checklist to cyber secure both corporate IT systems and Facility-Related Control Systems (HVAC, fire, lighting, etc.). Over the past 3 years as the Architect&Engineering, Construction and Operations community has been required to use these templates, and the cost to complete continues to come down. For a small/medium size business, multiple companies have achieved Level 3/4 at at cost of approximately $5000 to complete the RMF core documents, 2 security audits and a Table-Top exercise (all templates on the ESCTP website). Companies may need to acquire additional hardware and software (with most spending less than $3000-4000) for Continuous Monitoring/Auditing, and recurring costs of $1000-2000 per month to conduct audits. Key to an effective Cyber Risk Management Plan and CMMC certifcation is to have all staff fully engaged and involved, every end point is an entry point into DoD CUI.

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