Many government contractors are struggling to understand their cybersecurity requirements. When they encounter DFARS 252,204-7008, 252.204-7012, 252.204-7019, 252.204-7020, 252.204-7021 (CMMC), or other regulations that point back to NIST SP 800-171, they are often overwhelmed. The 110 controls, and their 300+ objectives/determination statements, presents a daunting list of “to do” items. Contractors often have no idea how to prioritize implementation of the controls. The chart below is intended to help contractor organizations and others who find themselves in that situation.
In creating the chart, we weighed existing best practices and risks, as well as organizational and operational necessities (e.g., training) to assign relative priorities. In some cases, similar requirements were grouped together in an effort to leverage efficiencies (e.g., since you’re already there making changes…). In other cases, related requirements were separated because other requirements were perceived as a higher priority.
Although we are publishing the chart, we recognize that the relative priorities are somewhat subjective and will vary depending on a variety of factors including the contractor’s industry and whether the contractor already has certain controls in place. However, hope the chart provides at least a starting point for organizations which are new to government contracting and/or cybersecurity.
We also hope that the list sparks a discussion among the contractor community. To that end, we are allowing comments on this post. We look forward to our readers’ feedback and will periodically adjust the chart based on the then-current feedback.
A version of the prioritized list that also includes automated SPRS and FAR and Above scoring is available as part of our free Self-Assessment Tool.
| FAR Ref. | NIST SP 800-171 Control | Safeguarding Requirement | DoD Score Value | Incremental SPRS Score |
| (x) | 3.13.1 | Monitor, control, and protect communications (i.e., information transmitted or received by organizational systems) at the external boundaries and key internal boundaries of organizational systems. | 5 | -198 |
| (xi) | 3.13.5 | Implement subnetworks for publicly accessible system components that are physically or logically separated from internal networks. | 5 | -193 |
| (viii) | 3.10.1 | Limit physical access to organizational systems, equipment, and the respective operating environments to authorized individuals. | 5 | -188 |
| (ix) | 3.10.3 | Escort visitors and monitor visitor activity. | 1 | -187 |
| (ix) | 3.10.4 | Maintain audit logs of physical access. | 1 | -186 |
| (ix) | 3.10.5 | Control and manage physical access devices. | 1 | -185 |
| (vii) | 3.8.3 | Sanitize or destroy system media containing CUI before disposal or release for reuse. | 5 | -180 |
| (xii) | 3.14.1 | Identify, report, and correct system flaws in a timely manner. | 5 | -175 |
| (xiii) | 3.14.2 | Provide protection from malicious code at designated locations within organizational systems. | 5 | -170 |
| (xiv) | 3.14.4 | Update malicious code protection mechanisms when new releases are available. | 5 | -165 |
| (xv) | 3.14.5 | Perform periodic scans of organizational systems and real-time scans of files from external sources as files are downloaded, opened, or executed. | 3 | -162 |
| (v) | 3.5.1 | Identify system users, processes acting on behalf of users, and devices. | 5 | -157 |
| (vi) | 3.5.2 | Authenticate (or verify) the identities of users, processes, or devices, as a prerequisite to allowing access to organizational systems. | 5 | -152 |
| (i) | 3.1.1 | Limit system access to authorized users, processes acting on behalf of authorized users, and devices (including other systems). | 5 | -147 |
| (ii) | 3.1.2 | Limit system access to the types of transactions and functions that authorized users are permitted to execute. | 5 | -142 |
| (iii) | 3.1.20 | Verify and control/limit connections to and use of external systems. | 1 | -141 |
| (iv) | 3.1.22 | Control information posted or processed on publicly accessible systems. | 1 | -140 |
| 3.5.3 | Use multifactor authentication (MFA) for local and network access to privileged accounts and for network access to non-privileged accounts. | 5 | -135 | |
| 3.7.5 | Require multifactor authentication to establish nonlocal maintenance sessions via external network connections and terminate such connections when nonlocal maintenance is complete. | 5 | -130 | |
| 3.1.8 | Limit unsuccessful logon attempts. | 1 | -129 | |
| 3.10.2 | Protect and monitor the physical facility and support infrastructure for organizational systems. | 5 | -124 | |
| 3.5.7 | Enforce a minimum password complexity and change of characters when new passwords are created. | 1 | -123 | |
| 3.5.8 | Prohibit password reuse for a specified number of generations. | 1 | -122 | |
| 3.1.6 | Use non-privileged accounts or roles when accessing non-security functions. | 1 | -121 | |
| 3.13.3 | Separate user functionality from system management functionality. | 1 | -120 | |
| 3.5.9 | Allow temporary password use for system logons with an immediate change to a permanent password. | 1 | -119 | |
| 3.2.1 | Ensure that managers, systems administrators, and users of organizational systems are made aware of the security risks associated with their activities and of the applicable policies, standards, and procedures related to the security of those systems. | 5 | -114 | |
| 3.2.2 | Ensure that personnel are trained to carry out their assigned information security- related duties and responsibilities. | 5 | -109 | |
| 3.2.3 | Provide security awareness training on recognizing and reporting potential indicators of insider threat. | 1 | -108 | |
| 3.11.2 | Scan for vulnerabilities in organizational systems and applications periodically and when new vulnerabilities affecting those systems and applications are identified. | 5 | -103 | |
| 3.12.2 | Develop and implement plans of action designed to correct deficiencies and reduce or eliminate vulnerabilities in organizational systems. | 3 | -100 | |
| 3.11.1 | Periodically assess the risk to organizational operations (including mission, functions, image, or reputation), organizational assets, and individuals, resulting from the operation of organizational systems and the associated processing, storage, or transmission of CUI. | 3 | -97 | |
| 3.11.3 | Remediate vulnerabilities in accordance with risk assessments. | 1 | -96 | |
| 3.7.1 | Perform maintenance on organizational systems. | 3 | -93 | |
| 3.7.2 | Provide controls on the tools, techniques, mechanisms, and personnel used to conduct system maintenance. | 5 | -88 | |
| 3.7.6 | Supervise the maintenance activities of maintenance personnel without required access authorization. | 1 | -87 | |
| 3.13.2 | Employ architectural designs, software development techniques, and systems engineering principles that promote effective information security within organizational systems. | 5 | -82 | |
| 3.13.11 | Employ FIPS-validated cryptography when used to protect the confidentiality of CUI. | 5 | -77 | |
| 3.13.10 | Establish and manage cryptographic keys for cryptography employed in organizational systems. | 1 | -76 | |
| 3.5.10 | Store and transmit only cryptographically-protected passwords. | 5 | -71 | |
| 3.1.17 | Protect wireless access using authentication and encryption. | 5 | -66 | |
| 3.1.16 | Authorize wireless access prior to allowing such connections. | 5 | -61 | |
| 3.1.12 | Monitor and control remote access sessions. | 5 | -56 | |
| 3.1.13 | Employ cryptographic mechanisms to protect the confidentiality of remote access sessions. | 5 | -51 | |
| 3.13.15 | Protect the authenticity of communications sessions. | 5 | -46 | |
| 3.12.4 | Develop, document, and periodically update system security plans that describe system boundaries, system environments of operation, how security requirements are implemented, and the relationships with or connections to other systems. | 0 | -46 | |
| 3.14.3 | Monitor system security alerts and advisories and take action in response. | 5 | -41 | |
| 3.14.6 | Monitor organizational systems, including inbound and outbound communications traffic, to detect attacks and indicators of potential attacks. | 5 | -36 | |
| 3.6.1 | Establish an operational incident-handling capability for organizational systems that includes preparation, detection, analysis, containment, recovery, and user response activities. | 5 | -31 | |
| 3.6.2 | Track, document, and report incidents to designated officials and/or authorities both internal and external to the organization. | 5 | -26 | |
| 3.6.3 | Test the organizational incident response capability. | 1 | -25 | |
| 3.3.7 | Provide a system capability that compares and synchronizes internal system clocks with an authoritative source to generate time stamps for audit records. | 1 | -24 | |
| 3.1.18 | Control connection of mobile devices. | 5 | -19 | |
| 3.1.10 | Use session lock with pattern-hiding displays to prevent access and viewing of data after a period of inactivity. | 1 | -18 | |
| 3.1.4 | Separate the duties of individuals to reduce the risk of malevolent activity without collusion. | 1 | -17 | |
| 3.1.5 | Employ the principle of least privilege, including for specific security functions and privileged accounts. | 3 | -14 | |
| 3.3.2 | Ensure that the actions of individual system users can be uniquely traced to those users so they can be held accountable for their actions. | 3 | -11 | |
| 3.3.1 | Create and retain system audit logs and records to the extent needed to enable the monitoring, analysis, investigation, and reporting of unlawful or unauthorized system activity. | 5 | -6 | |
| 3.3.3 | Review and update logged events. | 1 | -5 | |
| 3.3.4 | Alert in the event of an audit logging process failure. | 1 | -4 | |
| 3.3.5 | Correlate audit record review, analysis, and reporting processes for investigation and response to indications of unlawful, unauthorized, suspicious, or unusual activity. | 5 | 1 | |
| 3.14.7 | Identify unauthorized use of organizational systems | 3 | 4 | |
| 3.3.6 | Provide audit record reduction and report generation to support on-demand analysis and reporting. | 1 | 5 | |
| 3.4.8 | Apply deny-by-exception (blacklisting) policy to prevent the use of unauthorized software or deny-all, permit-by-exception (whitelisting) policy to allow the execution of authorized software. | 5 | 10 | |
| 3.4.9 | Control and monitor user-installed software. | 1 | 11 | |
| 3.4.7 | Restrict, disable, or prevent the use of nonessential programs, functions, ports, protocols, and services. | 5 | 16 | |
| 3.13.12 | Prohibit remote activation of collaborative computing devices and provide indication of devices in use to users present at the device. | 1 | 17 | |
| 3.13.4 | Prevent unauthorized and unintended information transfer via shared system resources. | 1 | 18 | |
| 3.3.8 | Protect audit information and audit logging tools from unauthorized access, modification, and deletion. | 1 | 19 | |
| 3.3.9 | Limit management of audit logging functionality to a subset of privileged users. | 1 | 20 | |
| 3.4.1 | Establish and maintain baseline configurations and inventories of organizational systems (including hardware, software, firmware, and documentation) throughout the respective system development life cycles. | 5 | 25 | |
| 3.4.2 | Establish and enforce security configuration settings for information technology products employed in organizational systems. | 5 | 30 | |
| 3.5.11 | Obscure feedback of authentication information. | 1 | 31 | |
| 3.1.21 | Limit use of portable storage devices on external systems. | 1 | 32 | |
| 3.8.7 | Control the use of removable media on system components. | 5 | 37 | |
| 3.8.8 | Prohibit the use of portable storage devices when such devices have no identifiable owner. | 3 | 40 | |
| 3.7.4 | Check media containing diagnostic and test programs for malicious code before the media are used in organizational systems. | 3 | 43 | |
| 3.8.2 | Limit access to CUI on system media to authorized users. | 3 | 46 | |
| 3.1.19 | Encrypt CUI on mobile devices and mobile computing platforms | 3 | 49 | |
| 3.8.1 | Protect (i.e., physically control and securely store) system media containing CUI, both paper and digital. | 3 | 52 | |
| 3.13.6 | Deny network communications traffic by default and allow network communications traffic by exception (i.e., deny all, permit by exception). | 5 | 57 | |
| 3.13.7 | Prevent remote devices from simultaneously establishing non-remote connections with organizational systems and communicating via some other connection to resources in external networks (i.e., split tunneling). | 1 | 58 | |
| 3.1.7 | Prevent non-privileged users from executing privileged functions and capture the execution of such functions in audit logs. | 1 | 59 | |
| 3.4.5 | Define, document, approve, and enforce physical and logical access restrictions associated with changes to organizational systems. | 5 | 64 | |
| 3.4.6 | Employ the principle of least functionality by configuring organizational systems to provide only essential capabilities. | 5 | 69 | |
| 3.4.3 | Track, review, approve or disapprove, and log changes to organizational systems. | 1 | 70 | |
| 3.4.4 | Analyze the security impact of changes prior to implementation. | 1 | 71 | |
| 3.12.3 | Monitor security controls on an ongoing basis to ensure the continued effectiveness of the controls. | 5 | 76 | |
| 3.12.1 | Periodically assess the security controls in organizational systems to determine if the controls are effective in their application. | 5 | 81 | |
| 3.8.4 | Mark media with necessary CUI markings and distribution limitations. | 1 | 82 | |
| 3.1.9 | Provide privacy and security notices consistent with applicable CUI rules. | 1 | 83 | |
| 3.13.16 | Protect the confidentiality of CUI at rest. | 1 | 84 | |
| 3.8.9 | Protect the confidentiality of backup CUI at storage locations. | 1 | 85 | |
| 3.1.3 | Control the flow of CUI in accordance with approved authorizations. | 1 | 86 | |
| 3.8.5 | Control access to media containing CUI and maintain accountability for media during transport outside of controlled areas. | 1 | 87 | |
| 3.13.8 | Implement cryptographic mechanisms to prevent unauthorized disclosure of CUI during transmission unless otherwise protected by alternative physical safeguards. | 3 | 90 | |
| 3.8.6 | Implement cryptographic mechanisms to protect the confidentiality of CUI stored on digital media during transport unless otherwise protected by alternative physical safeguards. | 1 | 91 | |
| 3.9.1 | Screen individuals prior to authorizing access to organizational systems containing CUI. | 3 | 94 | |
| 3.9.2 | Ensure that organizational systems containing CUI are protected during and after personnel actions such as terminations and transfers. | 5 | 99 | |
| 3.7.3 | Ensure equipment removed for off-site maintenance is sanitized of any CUI. | 1 | 100 | |
| 3.1.11 | Terminate (automatically) a user session after a defined condition. | 1 | 101 | |
| 3.13.9 | Terminate network connections associated with communications sessions at the end of the sessions or after a defined period of inactivity. | 1 | 102 | |
| 3.5.4 | Employ replay-resistant authentication mechanisms for network access to privileged and non-privileged accounts. | 1 | 103 | |
| 3.5.5 | Prevent reuse of identifiers for a defined period. | 1 | 104 | |
| 3.5.6 | Disable identifiers after a defined period of inactivity. | 1 | 105 | |
| 3.13.13 | Control and monitor the use of mobile code. | 1 | 106 | |
| 3.13.14 | Control and monitor the use of Voice over Internet Protocol (VoIP) technologies. | 1 | 107 | |
| 3.1.14 | Route remote access via managed access control points. | 1 | 108 | |
| 3.1.15 | Authorize remote execution of privileged commands and remote access to security-relevant information. | 1 | 109 | |
| 3.10.6 | Enforce safeguarding measures for CUI at alternate work sites. | 1 | 110 |