Do You Know Your Incident Reporting Compliance Responsibilities Under NIST 800-171?



By Rich Selvidge, CISSP, Solutions Architect at Redhawk Network Security

One thing is hard to argue in today’s complex cyber world: cyber incidents are part of doing business. Chances are, your organization’s data will be—or already has been—breached. With an employee clicking on malware every 81 seconds in the U.S., according to a study by Check Point, it’s no surprise that cyber incidents that expose sensitive data are spreading like wildfire. Most organizations focus on mitigation: you remove viruses, launch employee “don’t click” training programs, and try to secure your network from hackers. But what is your organization doing to be ready when the inevitable happens?

Are you prepared to successfully respond to incidents, whether they stem from malware, denial-of-service (DoS) attacks, stolen passwords, or lost laptops? It’s one thing to have security efforts in place to protect your data, but it’s another to have incident response planning in place. Incident response is one of the 14 requirements outlined in the National Institute of Standards and Technology’s (NIST) Special Publication (SP) 800-171—Protecting Controlled Unclassified Information (CUI) in Nonfederal Information Systems and Organizations, and enforced by the U.S. Department of Defense (DoD). If your organization contracts for the government, you must implement all 14 of these security requirements and controls by December 31, 2017. Simply put, if you do not comply, you risk losing your contracts, costing your organization millions of dollars in lost revenue.

In the article Are You Ready for NIST 800-171 Compliance Marathon?, I walked through the NIST 800-171 security requirements. Now, I will tackle what compliance requirements are required for incident reporting.

But first, what is a cyber incident? A cyber incident is defined as actions taken through the use of computer networks that result in a compromise or an actual or potentially adverse effect on an information system and/or the information residing therein.

Incident Reporting Compliance Requirements

According to NIST SP 800-171 section 3.6, the Incident Response family of security requirements focuses on establishing an operational incident-handling capability for organizational information systems that includes adequate preparation, detection, analysis, containment, recovery, and user response. You must acquire a medium assurance certificate to access the reporting site. So, this is the first step.

Cyber incidents that impact a system within the scope of Defense Acquisition Regulations System (DFARS) must be reported within 72 hours of detection. To report cyber incidents, you must have a medium assurance certificate. A review must be conducted so that the scope of the compromise can be understood. At a minimum, this review must cover:

  • Identification of affected systems
  • Affected users accounts
  • Affected data
  • Other systems that might have been compromised

Who Should Report and Why?

  • DoD contractors report cyber incidents in accordance with the DFARS Clause 252.204-7012
  • DoD contractors report in accordance with other reporting requirements identified in a contract or other agreement
  • DoD Cloud Service Providers report cyber incidents in accordance with clause 252.239-7010, Cloud Computing Services
  • DoD’s Defense Industrial Base Cybersecurity Program (DIB CS) Participants report cyber incidents in accordance with the Framework Agreement (FA)

The DoD has the right to request further information in order to investigate the cyber incident. To this end, the contractor:

  • Should take images of affected systems and any relevant monitoring/packet capture data for at least 90 days from the submission of the cyber incident report to allow the DoD to request the media or decline interest.
  • Provide access to the DoD in order to carry out forensic analysis.
  • Work with the DoD to provide any additional information that is required to complete the investigation.

What Do DoD Contractors Need to Report?

DoD contractors shall report as much of the following information as can be obtained to DoD within 72 hours of discovery of any cyber incident:

  1. Company name
  2. Company point of contact information (address, position, telephone, email)
  3. Data Universal Numbering System (DUNS) Number
  4. Contract number(s) or other type of agreement affected or potentially affected
  5. Contracting Officer or other type of agreement point of contact (address, position, telephone, email)
  6. USG Program Manager point of contact (address, position, telephone, email)
  7. Contract or other type of agreement clearance level (Unclassified, Confidential, Secret, Top Secret, Not applicable)
  8. Facility CAGE code
  9. Facility Clearance Level (Unclassified, Confidential, Secret, Top Secret, Not applicable)
  10. Impact to Covered Defense Information
  11. Ability to provide operationally critical support
  12. Date incident discovered
  13. Location(s) of compromise
  14. Incident location CAGE code
  15. DoD programs, platforms or systems involved
  16. Type of compromise (unauthorized access, unauthorized release (includes inadvertent release), unknown, not applicable)
  17. Description of technique or method used in cyber incident
  18. Incident outcome (successful compromise, failed attempt, unknown)
  19. Incident/Compromise narrative
  20. Any additional information

Report the Fire Before It Spreads

While you may be doing what you can to prevent cyber fires from spreading and causing damage, there are procedures to follow to report the fire. If your clothes catch on fire, we all know about “Stop, Drop, and Roll.” In the case of cyber incidents, it’s more like “Stop, Assess, and Report.” Knowing and implementing the NIST 800-171 requirements—all 14 of them including incident response —is not only a good way to mitigate risk and minimize data exposure but critical to maintaining your organization’s compliance and status with the federal government.

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About the Author: As Solutions Architect at Redhawk Network Security, Rich Selvidge is a catalyst to developing solutions in collaboration with clients. Rich has a background in Cybersecurity, Information Security, and Risk Management for various Department of Defense and federal government agencies that provide the required experience needed to develop customized solutions tailored to client needs. Rich is CISSP certified, and holds a Bachelor of Science in Information Technology and a Masters in Information Technology as well as several other certifications focused on IT and IS. Rich has experience with various compliance requirements such as DoD, NIST, FISMA, PCI, HIPAA, and SOC/Cert.


  1. Seems many are waiting until the last minute or maybe even after the deadline to get their compliance in order. Thanks for keeping the community informed.

  2. Thanks for helping me understand some responsibilities regarding incident reporting. It’s good to know that you need to take images of affected systems. I wonder if you should take multiple images at different angles, just to be on the safe side.

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