Your score in the Supplier Performance Risk System (SPRS) starts at 110 and loses the point value of every NIST SP 800-171 requirement you have not fully implemented, down to a floor of minus 203. Each requirement is worth 5, 3 or 1 points under the Department of Defense (DoD) Assessment Methodology, so the 5 point controls SPRS weights most are both why a score is low and the fastest way to raise it. The arithmetic is covered in our guide to calculating your SPRS score, and you can run your own numbers on the free SPRS calculator. This post is the fix list.

The count, verified. Annex A of the NIST SP 800-171 DoD Assessment Methodology, version 1.2.1 (June 24, 2020) lists 42 requirements at a flat 5 points: 23 basic and 19 derived. Two more, 3.5.3 multifactor authentication (MFA) and 3.13.11 FIPS-validated cryptography (FIPS is the Federal Information Processing Standards series), score 3 or 5 depending on how far you got. Those 44 account for 220 of the 313 points you can lose.

How many 5 point controls SPRS scoring has, and why they come first

Three reasons, and only the first is arithmetic. One 5-point requirement moves your score as much as five 1-point requirements, usually for less work than five separate fixes.

The second reason is the CMMC rule. Under 32 CFR 170.21, Conditional Level 2 (Self) status requires a score of at least 80 percent (88 of 110) and nothing on the plan of action worth more than 1 point, with one exception for 3.13.11 when encryption exists but is not FIPS validated. Every open 5-pointer therefore blocks Level 2 (Self) outright. SPRS accepts any score with a plan of action and a date for reaching 110, but the same list drives both.

The third reason is the methodology's own logic. Section 5 says that basic requirements left unimplemented render the more numerous derived requirements ineffective, with 3.1.1 as its example: fail to limit system access and the rest of access control stops meaning anything.

The requirement scored above the score: your system security plan

Requirement 3.12.4, the system security plan (SSP), has no point value in Annex A. It is marked NA, and Section 5(g) of the methodology explains why: the assessment is a review of the SSP, so without one the finding is that an assessment could not be completed due to incomplete information and noncompliance with DFARS (Defense Federal Acquisition Regulation Supplement) clause 252.204-7012. 32 CFR 170.24 repeats that wording for CMMC. No SSP, no score. Its neighbor 3.12.2, the plan of action, is worth 3 points and is not implemented if any unimplemented requirement lacks one. 3.12.1 (periodic assessment) and 3.12.3 (ongoing monitoring) are ordinary 5-pointers, evidenced by a dated self-assessment and a recurring control review.

All 42, grouped by how a small shop fixes them

Requirement text is from NIST SP 800-171 Revision 2, values from Annex A. "Suite" means the Microsoft 365 or Google Workspace admin settings you already pay for; CUI is controlled unclassified information.

RequirementShort nameTypical fix in a 5 to 50 person shop
Identification and inventory: free
3.1.1Limit access to authorized users and devicesUser, service account and device lists, reconciled to payroll
3.1.2Limit access to permitted functionsRole list plus the groups that enforce it
3.5.1Identify users, processes, devicesSame lists, unique identifier per entry
3.5.2Authenticate users, processes, devicesSuite sign-in everywhere, no shared logins
3.4.1Baseline configurations and inventoriesInventory plus a standard build per device type
MFA and access paths: suite settings
3.5.3Multifactor authentication (3 or 5)Suite MFA for all users, then local admin and server consoles
3.1.12Monitor and control remote accessOne logged VPN (virtual private network) or gateway, or prohibit it in writing
3.1.13Encrypt remote access sessionsSame gateway with current TLS (transport layer security) or IPsec
3.7.5MFA for nonlocal maintenanceMFA on the IT provider's remote tool, sessions closed after
3.1.16Authorize wireless accessWireless policy, guest network off the CUI network
3.1.17Wireless authentication and encryptionWPA2 or WPA3 with per-user or certificate authentication
3.1.18Control mobile device connectionsSuite device management, or a policy keeping phones off CUI
Encryption: the FIPS trap
3.13.11FIPS-validated cryptography for CUI (3 or 5)FIPS 140 validated modules only, each one documented
3.5.10Cryptographically protected passwordsDirectory passwords and a password manager; no spreadsheet
3.13.15Session authenticityTLS everywhere, VPN for internal apps, legacy protocols off
Logging and monitoring: cheap to start
3.3.1Create and retain audit logsSuite, firewall and endpoint logging on, retention set
3.3.5Correlate log review and responseA weekly written log review, or a managed detection service
3.14.6Monitor for attacksEndpoint detection and firewall alerts, with a named reader
3.14.3Act on alerts and advisoriesCISA (Cybersecurity and Infrastructure Security Agency) and vendor advisories, actions logged
3.12.3Monitor controls on an ongoing basisMonthly control checklist with dates and initials
Vulnerabilities, patching, malware: one purchase
3.11.2Scan for vulnerabilitiesA scanner, yours or your provider's, on a schedule, reports kept
3.14.1Identify, report, correct flawsManaged patching via device management, deadline per severity
3.14.2Malicious code protectionManaged antimalware on every endpoint, mail filtering
3.14.4Update malware protectionAutomatic updates, verified in the console
Boundary and configuration
3.13.1Protect communications at boundariesLogged business firewall at the edge and around the CUI segment
3.13.6Deny by default, allow by exceptionDeny-all rule set, inbound and outbound
3.13.5Separate public-facing subnetworksA DMZ (perimeter network) for anything public, or N/A with nothing public
3.13.2Security-minded architectureNetwork diagram and design principles in the SSP
3.4.2Secure configuration settingsHardening baseline pushed by device management
3.4.5Access restrictions for changesNamed admins only; written change procedure
3.4.6Least functionalityStandard build with unneeded features off
3.4.7Restrict nonessential programs and portsRemove unused software and ports, document what stays
3.4.8Allowlisting or blocklisting softwareApplication control policy; a blocklist is the minimum
3.8.7Control removable mediaUSB storage blocked by policy, exceptions listed
3.7.2Control maintenance toolsApproved remote management tools and who may use them
People, physical, incidents, program
3.2.1Security awarenessAnnual awareness training, completion recorded
3.2.2Role-based security trainingAdmin and CUI-handler training, recorded
3.9.2Terminations and transfersSame-day offboarding checklist: accounts off, devices back
3.10.1Limit physical accessLocked doors to servers and CUI areas, key or badge list
3.10.2Protect and monitor the facilityAlarm or cameras plus a visitor process
3.6.1Incident handling capabilityShort incident response plan naming who does what
3.6.2Report incidentsIncident log with the DFARS 252.204-7012 reporting steps
3.8.3Sanitize media before disposalWipe or destroy drives, with a record
3.12.1Periodically assess controlsDated self-assessment of all 110, on a schedule

Where the traps are

3.5.3 and local admin. One of its four assessment objectives is MFA for local access to privileged accounts: the server console, the local administrator account on a laptop. Suite MFA covers email and cloud apps, not that keyboard. Cover remote and privileged users but not the general user and the methodology subtracts 3 instead of 5. Any other gap, including a rollout that is 75 percent done with a plan of action, is scored as not implemented. More in our post on whether CMMC requires MFA.

3.13.11 and FIPS. Section 5(i) of the methodology is blunt: an approved algorithm such as AES is not sufficient, the module implementing it must be validated under FIPS 140. No encryption costs 5, encryption that is not FIPS validated costs 3, and an isolated non-validated case with a plan of action is a temporary deficiency scored as implemented. Note that 3.13.8 (CUI in transit) is a 3-point requirement and 3.8.6 (CUI on media in transport) is 1 point, so the 5-point exposure sits in 3.13.11 alone. Our FIPS guide covers finding a validated module.

Remote, wireless, mobile. Annex A subtracts nothing for 3.1.12, 3.1.13, 3.1.16, 3.1.17 or 3.1.18 when that kind of access is not permitted, but Section 5(i) expects a written policy and procedure keeping it from being enabled by accident.

What needs a purchase. For most shops this size: a business-grade firewall if you are on a consumer router (3.13.1, 3.13.6), a vulnerability scanner or a provider who runs one (3.11.2), endpoint detection or managed monitoring (3.14.6, 3.3.5), and longer log retention than the suite default (3.3.1). Everything else is settings and paperwork.

The order to work them

  1. Identification first, because it is free. Users, service accounts, devices, roles and an inventory cover objectives across 3.1.1, 3.1.2, 3.5.1, 3.5.2 and 3.4.1, and every later group depends on knowing what you have. Twenty-five points for a few afternoons.
  2. MFA second. Enforce it for everyone in the suite, then chase local admin and the remote support tool: 3.5.3, 3.7.5 and the remote access pair.
  3. Encryption third. List every place CUI is encrypted, confirm each module's FIPS 140 validation, retire what does not qualify or put the isolated case on a plan of action.
  4. Logging fourth. Turn logging on everywhere before you buy anything, then decide whether a person or a service reads it.
  5. Then patching and scanning, boundary and configuration, people and physical. Steadier work with more line items and purchases, and faster once the first four groups exist, because the inventory tells you what to patch, scan and harden.

What to do this week

  1. Print the 42 and mark each one implemented, not implemented or not applicable, honestly, against the 800-171A assessment objectives.
  2. Write the three lists: users, service accounts and processes, devices. Date them and name an owner.
  3. Turn on MFA for every suite account, then sign in at a server console and see whether anything asks for a second factor.
  4. List every place CUI is encrypted and look up whether the module is FIPS 140 validated.
  5. Confirm you have a signed, current SSP. If not, it comes before everything above, because without it there is no score to improve.

The score is not the goal. The three self-assessed paths that matter right now, CMMC Level 1 (Self), CMMC Level 2 (Self) and the SPRS score, all run on the same implemented or not implemented judgment, and eleven of the 42 five-pointers are also Level 1 safeguards under FAR 52.204-21. CMMC Map, CMMC compliance software for small defense contractors, scores all 110 requirements with the DoD weights and sorts the gap list by points lost, so the 5-pointers sit at the top. The assessment and the live score are free. The generated SSP, plan of action, policies and readiness report are the one paid plan at $149 a month.

This is explanatory content about contractual requirements, not legal advice. Your contract clauses and your prime's flowdown letter govern.

See which 5-point requirements you are still losing

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