Defense Contractors Urged to Shift From Snapshot to Continuous NIST 800-171 Evidence

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Ahead of a Cyber AB Town Hall on October 27, the CMMC Reform Task Force's findings remain unpublished. Presenters at September's Town Hall speculated that the Department of Defense may move away from point-in-time assessments that quickly become outdated. Cybersecurity advisors recommend that contractors generate evidence on a regular schedule, such as monthly MFA and access reports, dated vulnerability scans, and centralized audit logs. They also suggest mapping each of NIST SP 800-171's 110 requirements to its proof, refresh cadence, and owner within the System Security Plan. Regardless of reform outcomes, contractors handling CUI under DFARS 7012 must still meet NIST SP 800-171 and maintain an accurate SPRS score.

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