Understanding the Scope of NIST and CMMC Compliance for Your Organization
- John W. Harmon, PhD
- 57 minutes ago
- 3 min read
Meeting cybersecurity standards is no longer optional for organizations working with sensitive information, especially those in government contracting or handling controlled unclassified information (CUI). Two key frameworks that often come up are the National Institute of Standards and Technology (NIST) guidelines and the Cybersecurity Maturity Model Certification (CMMC). Understanding the scope of these compliance requirements is critical for organizations to protect data, avoid penalties, and maintain eligibility for contracts.
This post explains what it means to set the scope for NIST and CMMC compliance, why it matters, and how organizations can approach it effectively.
What Does Setting the Scope Mean?
Setting the scope defines which parts of your organization, systems, and processes fall under the compliance requirements. It answers questions like:
Which assets contain or process sensitive information?
What systems need to meet security controls?
Which business units or locations are involved?
Without a clear scope, organizations risk applying controls too broadly, wasting resources, or too narrowly, leaving gaps that could lead to breaches or failed audits.
Key Differences Between NIST and CMMC Scopes
Both NIST and CMMC aim to protect sensitive information but differ in their approach and application.
NIST SP 800-171 focuses on protecting Controlled Unclassified Information (CUI) in non-federal systems. It requires organizations to implement 110 security controls.
CMMC builds on NIST 800-171 but adds maturity levels and third-party certification. It applies primarily to Department of Defense (DoD) contractors.
The scope for NIST compliance typically centers on systems that store, process, or transmit CUI. CMMC scope includes these systems but also considers organizational maturity and processes.
How to Define Your Compliance Scope
1. Identify Sensitive Information
Start by locating all CUI within your organization. This includes documents, emails, databases, and any system that handles this data. Examples of CUI include:
Export-controlled technical data
Proprietary business information
Personal identifiable information (PII) related to defense contracts
2. Map Information Flows
Understand how CUI moves through your organization. This helps identify:
Systems that store or process CUI
Networks that transmit CUI
Third-party vendors with access to CUI
3. Determine System Boundaries
Define which systems are in scope based on their interaction with CUI. This may include:
Servers and databases
Workstations and laptops
Cloud services and applications
4. Include Supporting Infrastructure
Don’t overlook infrastructure that supports in-scope systems, such as:
Network devices (firewalls, routers)
Security monitoring tools
Backup and recovery systems
5. Consider Organizational Units
Some departments may not handle CUI directly but support compliance efforts, such as IT security or compliance teams. Decide if they fall within scope.
Practical Example of Scope Setting
Imagine a mid-sized defense contractor with multiple offices and a mix of on-premises and cloud systems.
Step 1: They identify all contracts involving CUI.
Step 2: They locate CUI stored in project management software, email servers, and file shares.
Step 3: They map data flow from employee laptops to cloud storage.
Step 4: They include network firewalls and VPNs that protect access to CUI systems.
Step 5: They decide the compliance scope covers the IT department and project teams handling CUI but excludes unrelated HR systems.
This focused scope helps them apply controls efficiently and prepare for CMMC certification.
Challenges in Defining Scope
Over-Inclusion
Some organizations try to include all systems to be safe. This can lead to excessive costs and complexity.
Under-Inclusion
Others exclude systems that indirectly affect CUI, creating security gaps.
Dynamic Environments
Cloud adoption, remote work, and third-party services make scope setting a moving target.
Tips for Managing Scope Effectively
Use a data inventory tool to track where sensitive information resides.
Engage stakeholders from IT, legal, and business units to get a full picture.
Document scope decisions clearly for audits and future reviews.
Review scope regularly to adjust for changes in systems or contracts.
Leverage external expertise if needed, especially for complex environments.
How Scope Affects Compliance Efforts
The scope determines the extent of controls you must implement, test, and maintain. It impacts:
Resource allocation: Time and budget for security upgrades
Training: Who needs cybersecurity awareness and technical training
Audit readiness: What systems and processes auditors will examine
A well-defined scope helps focus efforts where they matter most, improving security and compliance outcomes.
Moving Forward with NIST and CMMC Compliance
Organizations should treat scope setting as a foundational step, not an afterthought. It shapes the entire compliance journey and influences risk management.
Start by:
Conducting a thorough assessment of your information and systems
Aligning scope with contract requirements and organizational goals
Building a compliance roadmap based on your defined scope
By focusing on the right areas, organizations can meet NIST and CMMC requirements more efficiently and protect sensitive information effectively.
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