CMMC and NIST SP 800-171

CMMC and NIST 800-171 are not the same thing. Most contractors need both.

If you are dealing with a prime flowdown, preparing for a CMMC assessment, maintaining an SPRS score or handling Controlled Unclassified Information, you are dealing with both. The relationship is simpler than the acronyms suggest.

The control set

NIST SP 800-171

Defines the 110 security requirements you must implement to protect Controlled Unclassified Information.

The assessment

CMMC

The framework used to evaluate whether those requirements have actually been implemented.

For most organizations handling CUI CMMC Level 2 — assessed against the 110 requirements in NIST SP 800-171.

Knowing the requirements exist was never the hard part. Implementing them, evidencing them, and proving they operate is.

Thirty minutes, no prep. Tell us what you handle and who is asking, and you will leave knowing your likely CMMC level, how big the scope really is, and what the first ninety days look like.

What CMMC Level 2 assesses

110 requirements, fourteen families, and a lot of operational work

Contractors consistently underestimate what a CMMC program involves. This is not a policy exercise. Every one of the 110 requirements needs all five of these before it counts toward your score.

An owner An implementation approach Supporting evidence Ongoing maintenance A documented process

Access Control

22Requirements

The largest family by some distance, and where most CMMC assessments spend their time. Who can reach CUI, from where, and how that is enforced and reviewed.

Typical work
  • Quarterly access reviews
  • Least privilege enforced and evidenced
  • Remote access controls and session handling

System and Communications Protection

16Requirements

The second largest family. Boundaries, encryption and how CUI moves between systems and out to the people who need it.

Typical work
  • Boundary protection and separation
  • Encryption in transit and at rest
  • Cryptographic key management

Identification and Authentication

11Requirements

Who is who, proven. Multi-factor authentication lives here, and so does most of what a prime contractor asks about first.

Typical work
  • MFA on privileged and network access
  • Password and authenticator management
  • Identifier handling for users and devices

Audit and Accountability

9Requirements

Logging that actually gets reviewed, retained appropriately, and protected from alteration. The review is the part that fails.

Typical work
  • Log review with a record that it happened
  • Retention that survives an assessor asking
  • Time synchronization across systems

Configuration Management

9Requirements

Known good baselines, and control over what changes. Also where the scope question from further down this page comes back to bite.

Typical work
  • Documented baseline configurations
  • Change control with approvals
  • Inventory of what is actually in scope

Media Protection

9Requirements

Physical and digital media holding CUI, through its whole life, including the part after you stop using it.

Typical work
  • Marking and handling procedures
  • Encryption on portable media
  • Sanitization and disposal records

System and Information Integrity

7Requirements

Flaws found and fixed, and the monitoring that spots them before somebody else does.

Typical work
  • Flaw remediation on a defined timeline
  • Malicious code protection
  • Security alert monitoring and response

Maintenance

6Requirements

Who touches the systems, with what tools, and under whose supervision. Third-party repair is the usual gap.

Typical work
  • Controlled maintenance procedures
  • Media sanitization before off-site repair
  • Supervision of external maintenance staff

Physical Protection

6Requirements

The building, the visitors, and the devices that leave it. Nothing a network scan can validate for you.

Typical work
  • Physical access control and logs
  • Visitor escort and records
  • Protection of equipment holding CUI

Security Assessment

4Requirements

Assessing your own controls, and the documents that describe them. Four requirements that decide how the CMMC assessment reads.

Typical work
  • A current System Security Plan
  • A POA&M that is maintained, not decorative
  • Periodic control assessment

Awareness and Training

3Requirements

Small in requirement count, routinely failed in practice, because the records are missing rather than the training.

Typical work
  • Annual training for everyone in scope
  • Role-based training for privileged users
  • Completion records by name and date

Incident Response

3Requirements

Few requirements, high consequence, including the 72-hour reporting obligation that sits in your DFARS clause rather than in NIST SP 800-171.

Typical work
  • A plan that has actually been tested
  • Detection, reporting and response roles
  • Incident records and lessons learned

Risk Assessment

3Requirements

Identifying and re-evaluating risk, including vulnerability scanning and what you did about the findings.

Typical work
  • Periodic risk assessment
  • Vulnerability scanning and remediation
  • Risk decisions documented

Personnel Security

2Requirements

Two requirements, and both of them bite on the day somebody leaves.

Typical work
  • Screening before access is granted
  • Access removed on departure or transfer

22 + 16 + 11 + 9 + 9 + 9 + 7 + 6 + 6 + 4 + 3 + 3 + 3 + 2 = 110. Every requirement is scored, and a CMMC Level 2 assessment looks at all of them. The families are listed here largest first, because that is the order in which they consume your team's time, not the order NIST prints them.

Beyond controls

Controls are not enough. You also have to document it.

A defensible CMMC program is more than technical controls. Four artifacts carry the weight, and assessors look at all of them.

SSP

System Security Plan

The document explaining how each requirement has been implemented in your environment. If it does not match reality, that is the finding.

POA&M

Plan of Action & Milestones

Outstanding deficiencies and what you are doing about them, with dates. A POA&M nobody has touched in a year says more than a gap does.

SPRS

Your assessment score

Maintained in the Supplier Performance Risk System, and visible to the contracting officers deciding whether you are eligible to bid.

Affirmation

Senior official affirmation

A named senior official affirming the status of your CMMC compliance posture. Not an administrative step.

!

That affirmation is a representation made to the government

It should be treated accordingly. An SPRS score that was optimistic when it was entered, and never corrected, is a different kind of problem to an incomplete program, and it attaches to a named individual rather than to the company. This is the single most common thing we are asked to quietly fix, and the fix is to correct the score rather than to hope nobody checks.

Scoping

The most important question in a CMMC program comes before controls

Most organizations start by discussing controls. The smarter question comes first, and the answer decides the size, cost and duration of everything that follows.

Where is Controlled Unclassified Information actually stored, processed or transmitted?

CUI contained in a defined boundary

Narrow scope
Users in scope
Only those who handle CUI
Devices in scope
Enclave endpoints only
Systems in scope
The boundary and what connects to it
Everything else
Out of scope, defensibly

The rest of your business carries on unchanged. Marketing laptops, the general file share and the office network stay outside the CMMC assessment.

CUI spread across the business

Broad scope
Users in scope
Potentially everyone
Devices in scope
Every laptop and phone
Systems in scope
Email, file storage, the lot
Everything else
There is no everything else

Every one of the 110 requirements now applies to all of it. This is the single most expensive decision a contractor can make by accident.

The difference between a well-defined enclave and an overly broad environment is not marginal. It changes the users in scope, the devices, the systems, the cost, the complexity and the CMMC assessment boundary, and it is decided before you implement a single control.

This is also why a gap assessment bought before the scoping conversation is usually money spent twice. Assess the wrong boundary and you get an accurate report about the wrong thing. The first question we ask is never "which controls are you missing", it is "show us where the CUI actually goes", and the answer is frequently different from what the org chart suggests.

Where the CUI lives

Most platforms stop at the dashboard. The CUI still has to live somewhere.

This is the clearest difference between Greypike and the commercial compliance platforms moving into the Defense Industrial Base. They can tell you what is missing. They cannot give the data a home.

The part nobody else has

The Secure Enclave

An environment designed specifically for organizations handling CUI, built in your own tenant, operated and monitored as an accredited boundary.

What the enclave provides
  • Controlled assessment boundary
  • CUI-focused architecture
  • Microsoft GCC High support
  • Microsoft Entra ID GCC High
  • Microsoft 365 GCC High
  • Microsoft Intune GCC High
  • Managed boundary operations

Compliance is what you do. The enclave is where you do it.

Learn more about the Secure Enclave

The enclave is optional, and plenty of contractors do not need one. It exists for organizations whose CUI has nowhere defensible to sit today. If yours is already contained and you simply need the CMMC program run properly, the Compliance App on its own is the right answer, and we will tell you that.

Not sure which CMMC level applies to you?

Send us the contract clause or the prime's flowdown. In thirty minutes we can tell you the level you are likely assessed at, how big the scope really is once someone looks at where the CUI goes, and whether you need an enclave or just the program run properly.

How the program runs

110 requirements, reviewed by credentialed practitioners

Every requirement becomes one or more tasks. Instead of managing 110 CMMC requirements by hand, your team works through structured assignments and receives guidance before any evidence reaches an assessor.

Who this usually lands on
IT managersProgram managersFacility security officersOperations leadersCompany owners

Compliance review by credentialed practitioners

Most contractors have no dedicated compliance team. Greypike includes review by credentialed practitioners with government contractor experience, so problems are found while there is still time to fix them rather than during the assessment.

Task 014 — NIST SP 800-171, 3.5.3

Require MFA on every administrator account

Turn on multi-factor authentication for all accounts with admin privileges in the enclave identity provider, then export the enrollment report.

Owner
Dana Whitfield, IT
Due
30 September 2026
Evidence
Admin enrollment export from Microsoft Entra ID
Accepted when
100% of admins enrolled, exceptions documented
Also satisfies
CMMC Level 2, SOC 2, ISO/IEC 27001
MO
Marcus O., Registered Practitioner

Accepted. One service account cannot take MFA, so I have recorded it as an exception with the compensating control, and it will not read as a finding at assessment. Your SSP text for 3.5.3 is updated to match.

Illustrative example, not a real customer record

Credentials and limits

Credentialed leadership, and the limits that go with it

Greypike's CMMC practice is led by a Cyber AB Registered Practitioner Advanced. That credential is held individually by Rob Sinex. It belongs to a person, not to a company, and we describe it that way because that is what it is.

Veteran-ownedSBA-certified small business
CAGE 9WVS6SAM UEI N6CJNGDARFM5
RPA-ledCyber AB Registered Practitioner Advanced
GovCon-builtWhere the company started

Greypike is not a C3PAO

We do not perform CMMC certification assessments.

  • Prepare you for the CMMC assessment
  • Maintain the program between assessments
  • Manage evidence and documentation
  • Operate a compliant environment for CUI
  • Conduct the certification assessment itself

Formal CMMC assessments are conducted by authorized C3PAOs. The separation keeps the assessment independent, and it means we have no reason to tell you anything other than where you actually stand.

Second framework

Complete the work once. Reuse it across frameworks.

Many government contractors also sell commercially. Much of the work done for CMMC carries directly into the frameworks those customers ask about, which is why the second framework costs a fraction of the first.

This is our first framework

Everything points at one assessment

Your program has a single destination, which makes it simpler to run. The work still needs owners, evidence and maintenance, but you are not reconciling competing frameworks.

What we focus on
  • All 110 requirements as assigned tasks
  • A System Security Plan that matches reality
  • A POA&M that is maintained rather than decorative
  • An SPRS score you can defend
  • Evidence organized the way an assessor will ask for it
We have done one before

Most of the work counts twice

Risk assessments remain risk assessments. Access reviews remain access reviews. Vendor management and security training are the same activities described in different language.

What carries across
  • Access reviews to SOC 2 logical access and ISO/IEC 27001 access control
  • Risk assessments to both, with minor reframing
  • Vendor management to supplier controls in both
  • Security awareness training, identical evidence
  • Incident response, same plan and same test record

The same work also answers

Customer security questionnairesSupplier security reviewsPrime flowdownsSOC 2ISO/IEC 27001

CMMC is the strictest of the set, which is the useful part. A program built to survive a C3PAO assessment holds up comfortably in front of a SOC 2 auditor, an ISO certification body or an insurer's renewal questionnaire. See how the frameworks overlap, or the same program by industry.

Pricing

Published pricing, both products

Most organizations need the Compliance App. Organizations whose CUI has nowhere defensible to sit need the enclave as well.

Founding customer price

Compliance App

$399per month

or $4,000 a year — first 25 customers, locked 24 months

Included
  • CMMC and NIST SP 800-171 task library
  • Review by credentialed practitioners
  • Evidence management
  • Framework mapping and reuse
  • Continuous monitoring
  • One framework included
For organizations handling CUI

Secure Enclave

$4,500one-time setup

plus $205–$295 per CUI user, per month — bands down by seat count

What the seat includes
  • Accredited enclave environment
  • Microsoft GCC High, Entra ID, Intune
  • Boundary operations and monitoring
  • CUI protection controls

The Compliance App is required with the enclave and billed separately. The enclave is the environment; the app is the program that runs inside it.

Who builds this David Dillow Founder, Greypike
  • Veteran-Owned Small Business
  • 20+ years across government and the Defense Industrial Base
  • 20+ DIB contractors on active contracts supporting defense missions
  • 14 years as a cybersecurity and fraud investigator
  • Cyber AB Registered Practitioner (RP) and Registered Practitioner Advanced (RPA) on the team
  • MIT Sloan certificate in artificial intelligence for business strategy and governance

Why this page leads with scoping rather than controls

Almost every CMMC conversation in this market opens with a control list, because a control list is easy to sell against. It is also the wrong place to start. Two contractors with identical control gaps can be eighteen months and several hundred thousand dollars apart purely on where their CUI ended up living, and nobody decided that deliberately.

Two decades inside the Defense Industrial Base is mostly an education in which decisions are expensive and which ones only look expensive. Fourteen years investigating cybersecurity and fraud cases is an education in what happens when a number gets entered optimistically and never corrected. Both of those shape this page more than the 110 requirements do.

So the order here is deliberate: understand what CMMC actually assesses, know which four documents carry the weight, decide where the CUI lives before you buy anything, and only then start working the requirements. Get the scoping right and the rest is a project. Get it wrong and it is a permanent tax on the whole company.

Questions

CMMC questions we get asked

What is the difference between CMMC and NIST 800-171?

NIST SP 800-171 is the control set. It defines the 110 security requirements you must implement to protect Controlled Unclassified Information. CMMC is the assessment framework used to evaluate whether those requirements have actually been implemented. For most organizations handling CUI the destination is CMMC Level 2, assessed against those same 110 requirements. You do not choose between them; if one applies to you, so does the other.

Which CMMC level do we need?

It is decided by what data you handle under the contract. Federal Contract Information alone generally points at Level 1. Controlled Unclassified Information points at Level 2, which is where most Defense Industrial Base contractors land, and which is assessed against the 110 requirements in NIST SP 800-171. Level 3 builds on NIST SP 800-172 and is aimed at organizations supporting the most sensitive programs. The contract language decides it, not the size of your company, so send us the clause rather than guessing from revenue.

What is an SPRS score and why does it matter?

It is your self-assessment score against NIST SP 800-171, maintained in the Supplier Performance Risk System and visible to the contracting officers deciding whether you are eligible to bid. It is also affirmed by a named senior official, which makes it a representation to the government rather than an internal metric. A score entered optimistically and never corrected is a different category of problem to an incomplete program, and it attaches to that individual. If yours is stale or was generous, correcting it is the right move.

How long does CMMC take?

The honest answer on a first call is a range rather than a date, because the driver is rarely the framework. It is how much of your CUI is already contained, how much evidence already exists, and how much of your team's week is available. What we can tell you quickly is how big your scope really is once someone looks at where the CUI actually goes, and that single answer moves the timeline more than anything else on this page.

Do we need a Secure Enclave?

Not necessarily, and plenty of contractors do not. The enclave exists for organizations whose CUI has nowhere defensible to sit today, typically because it is spread across ordinary email, laptops and file shares. If your CUI is already contained in a boundary you can describe and defend, the Compliance App on its own is the right answer and we will tell you that. The enclave narrows your CMMC assessment boundary; it does not replace the program that runs inside it.

Is Greypike a C3PAO?

No. Greypike does not perform CMMC certification assessments. We prepare you for the assessment, maintain the program between assessments, manage evidence and documentation, and operate a compliant environment for CUI. Formal assessments are conducted by authorized C3PAOs. That separation keeps the assessment independent, and it means we have no commercial reason to tell you anything other than where you actually stand.

Does CMMC Level 2 require a penetration test?

No. Neither CMMC Level 2 nor NIST SP 800-171 requires penetration testing, and this is one of the most common and most expensive misunderstandings in the defense market. CMMC Level 3 builds on NIST SP 800-172, where testing features far more prominently. You may still choose to test for other reasons, but check the source before you buy one on the strength of a Level 2 requirement that does not exist. See what actually requires a penetration test.

Can we do this without a dedicated compliance person?

That is the case the platform is built for. Most Defense Industrial Base contractors under a few hundred people have no compliance team at all, and CMMC lands on an IT manager, a program manager, a facility security officer or the owner. Requirements arrive as assigned tasks with an owner, a due date and a definition of done, so nobody has to translate control language into work, and a credentialed practitioner reviews what gets submitted before an assessor sees it.

Last reviewed: September 2026

CMMC does not fail because requirements are missing. It fails because the work does not get done.

All 110 requirements become actionable work reviewed by credentialed practitioners, with a Secure Enclave available for organizations handling CUI. The challenge was never downloading NIST SP 800-171.

Veteran-Owned Small Business · RPA-led · Not a C3PAO, by design