COVID-19 Remote Working Leveraging NIST/CMMC Cyber Guidance

Brian Berger, President of Cytellix Corporation • March 31, 2020

COVID-19 Remote Working Leveraging NIST/CMMC Cyber Guidance

NIST SP800-171 and CMMC best practices enclosed provide guidance to meet compliance requirements for remote working. The talented Cytellix Corporation cyber analysts prepared the following guidance. Please take advantage of this valuable set of insights to support your organizations needs for safe remote working and cyber compliance: "Its just good cyber hygiene"


Remote Work Cybersecurity Concerns

Working from home, along with other forms of remote work, can present many challenges for organizations trying to balance security concerns with the ability to operate as effectively as possible. The NIST SP 800-171 and now CMMC standards for cybersecurity define several best practices that help to secure access to systems and data, as well as the practices needed to continue business operations by remote workers.


Practices directly related to NIST SP 800-171/CMMC (the Cybersecurity Maturity Model Certification)


Secure connections to your environment from the outside

If employees require access to systems and/or data that reside at company facilities, maintaining the security of those connections is a top priority. Remote access extends the security control enabled on-premise to remotely connected systems, but different risks need to be mitigated with expanded connectivity.   

  • Use VPN/HTTPS to ensure connections and communications are protected SC.3.190 – Protect the authenticity of communications sessions.
  • Ensure secure authentication methods for remote access connections and enforce strong encryption for transmitting data in remote access sessions AC.3.014 – Employ cryptographic mechanisms to protect the confidentiality of remote access sessions.
  • Ensure VPN connection are configured to prevent split tunneling SC.3.184 – 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).
  • Ensure network connections are terminated once communication sessions end SC.3.186 – Terminate network connections associated with communications sessions at the end of the sessions or after a defined period of inactivity.
  • Enforce security for remote access sessions and monitor remote access activity AC.2.013 - Monitor and control remote access sessions.
  • Use a limited number of remote access control points (entry points into the environment) AC.3.014 – Route remote access via managed access control points.
  • Require multi-factor authentication for all remote access IA.3.083 – Use multifactor authentication for local and network access to privileged accounts and for network access to non-privileged accounts.


Consider and authorize high-privileged remote access to both systems and data, following the least privilege principle.

High privileged access carries inherent risks that are amplified when extended over remote access. With unrestricted high-privilege access, a compromise of a system admin account may result in unchecked lateral movement of attacks by external threats in your environment. Limiting the scope of high-privileged access as much as is feasible, for both systems and data, helps to mitigate the risks related to compromise of high-privilege accounts.

  • Review authorization for access to systems from remote locations AC.3.021 – Authorize remote execution of privileged commands and remote access to security-relevant information.
  • Review authorization for access to sensitive data from remote locations AC.3.021 – Authorize remote execution of privileged commands and remote access to security-relevant information.


Ensure procedures are in place for the handling of sensitive data (controlled unclassified information, federal contract information, personal identifiable information, and other confidential/proprietary data)

Measures for secure handling of sensitive data should cover operations and activities both inside and outside controlled facilities and spaces. Certain types of data have more directed requirements for handling (e.g. CUI/FCI), but organizations should determine how other types of sensitive data should be handled—from receiving and processing, to storage, and disposal/destruction.

  • Establish CUI handling procedures for alternate work sites (including teleworking). Consider behaviors such as where/how data is stored, how physical media with sensitive information is stored and disposed of, and PE.3.136 – Enforce safeguarding measures for CUI at alternate work sites. MP.2.119 – Protect (i.e., physically control and securely store) system media containing CUI, both paper and digital.
  • Control CUI/sensitive information flows—what systems that information is allowed to move between, and how that data moves. AC.2.016 – Control the flow of CUI in accordance with approved authorizations.


Establish and enforce guidelines for system and device security

The systems used for remote work, whether company provided or BYOD, should have a level of security enforcement to mitigate risks from unauthorized installations and working in unsecured spaces and networks. Also, with corporate provided systems seeing more general use in remote work scenarios, control over physical media use help reduce risk of malware attacks and data breaches.

  • Control the use of external systems (including BYOD). Remote workers should use approved methods of collaborating, especially when dealing with sensitive information. Ensure cloud and SaaS based collaboration tools are functional while enforcing security. AC.1.003 – Verify and control/limit connections to and use of external information systems.
  • Use mobile device management to control/manage laptops and smart phones/tablets. AC.3.020 – Control connection of mobile devices.
  • Ensure inactivity screen-lock is enabled AC.2.010 – Use session lock with pattern-hiding displays to prevent access and viewing of data after a period of inactivity.
  • Ensure use of portable storage devices is controlled AC.2.006 – Limit use of portable storage devices on external systems. MP.2.121 – Control the use of removable media on system components.
  • Prevent the remote activation of collaborative devices (webcams, microphones) SC.2.178 – Prohibit remote activation of collaborative computing devices and provide indication of devices in use to users present at the device.


Other considerations for remote work security

  • Be aware of phishing and social engineering attempts related to IT support practices. With IT operations having to support remote workers using various tools and methods, more opportunistic threats are being seen, mimicking activities such as password resets/expirations, help desk remote access, and 3rd party vendor solution alerts.
  • Protect video and teleconference meeting confidentiality. Settings that require sign-in or have unique meeting IDs/codes help to prevent unauthorized parties from listening in to private communications.

Contact Cytellix: [email protected]




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By Brian Berger • August 23, 2023
The Department of Defense (DoD) has formally presented the CMMC regulation for official evaluation, marking the start of its journey toward formal announcement. Every regulation proposed by the executive branch, including this one, undergoes scrutiny by OIRA, a division of the Office of Management and Budget (OMB). The significance of this step is that the previously mentioned "delays" in the CMMC process were due to the time taken for the DoD to forward the rule to OIRA. With this action now taken, the subsequent stages of the rulemaking procedure are underway. Nevertheless, due to the intricate nature of federal rulemaking, several more stages need to be navigated before the CMMC becomes a part of contracts. The following scenarios should be considered for preparation for compliance and certification for the Defense Industrial Base (DIB). Scenario 1: Proposed Rule Submission to OIRA: The Department of Defense (DoD) has officially submitted the CMMC rule for regulatory review to the Office of Information and Regulatory Affairs (OIRA). Review and Publication: After OIRA's review, which takes an average of 66 business days, the CMMC rule is expected to be published in late October 2023. Public Comment Period: A standard 60-day public comment period will follow, ending in December 2023. Finalization: The CMMC rule will be published as a "proposed rule", which means it will only become effective after the agency responds to public comments in a final rule. Based on historical data, the average time for DoD proposed rules to be published as final rules is 333 business days. This means the CMMC final rule is expected between February and April 2025 . Phased Roll-Out: The DoD plans a 3-year phased roll-out for CMMC contract clauses. Assuming the final rule is published in Q1 2025, all relevant DoD contracts will contain CMMC by 2028. Scenario 2: Interim Final Rule Immediate Effectiveness : If the CMMC rule is published as an "interim final rule", it will be effective before the agency responds to public comments . This means the rule would be in effect and appear in contracts in Q1 2024 . Rarity of Interim Final Rules: Such rules are rare and bypass the usual democratic process of "notice and comment" rulemaking. They are typically granted in urgent situations, like the need to enhance national security. So when should you start preparing? Before we start with the background and changes, let’s talk about the "Big Elephant” in the room. Clearly, the updated compliance and certification process developed by the DoD and the non-profit organization liaisons has been long overdue with a lot of anticipated deadlines that never materialized. And with the latest announcements it does seem to be mildly reminiscent of the movie comedy and colloquial meaning of Groundhog Day. Since the Library of Congress selected the film for preservation in the National Film Registry I found humor in relativity, not cynicism. Opinion: This is different and the information we have in the DoD supply chain must be protected from our adversaries. This is a serious issue and needs clear and precise guidelines as the supply chain will not spend money on the protection of the information that protects national security unless they must as it is deemed as a complex undertaking. That’s an unfortunate reality. We have seen the start and restart of the cyber programs for DoD for the past 5-years, what makes this different? The implementation of the CMMC rule in contracts will be phased in over a period of 3 years, with all relevant DoD Defense Industrial Base (DIB) contracts containing CMMC by 2028. For a company with 50-100 employees operating in the DoD supply chain, it takes an average of 12-18 months to prepare for assessment and audit for eventual certification, with certification being the ultimate requirement for compliance. Therefore, the time is now to start the process if you plan to hold government contracts in 2024/2025. There are also varied flow down requirements that need to also be taken into consideration. Understanding Plan of Action and Milestones (POAM) There is now the ability to present interim status vs 100% compliance as we have with the current DFARS and NIST requirements. These interim reports can be handled in the traditional manner by presenting a Plan of Action and Milestones (POAM) that have a less than 180-day completion date for allowed baseline gaps. Unallowed gaps will have a “No POAM” designation and need to be implemented. If you have any doubts, work with a highly skilled 3 rd party who has expertise in these standards and a track record of enabling comprehensive successful standards-based cyber programs. The information presented by the suppliers in POAM’s or claiming 100% compliance will be evaluated and can and will likely trigger audits if certain high-level cyber controls are not met or the 100% compliance score creates suspicion of a false claim. Be careful to present accurate and validated information. So, what does this all mean? You must be compliant with DFARS clause 252.204.7012 and NIST 800-171 today. This is a requirement of your current contracts, and the False Claims Act applies to all cyber compliance representations. If you are not compliant, you could be subject to civil penalties and criminal charges. You need to start preparing for CMMC 2.0 today. The deadline for the final rule is 18 months from now, and it will take an average company in the DoD supply chain 12-18 months to become assessment ready. Waiting is not an option. Waiting is a bad idea. Why you ask? It is very clear that most suppliers and Small and Medium Businesses are not cyber ready and nowhere near compliant with any cyber framework. The timeframe for a typical business to understand, develop and implement full compliance is more than 1-year assuming they have the skills and personnel to complete the objectives. CMMC 2.0 clearly aligns with DFARS and NIST, so it is the best way to protect your organization's sensitive data. Don't delay, start preparing today! *If you have any questions, please reach out to our experts – [email protected]
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