The Department of Defense recently sent defense contractors a clear signal: an update to the recently finalized CMMC 2.0 is likely coming and the time to prepare is now.
In April, the DoD released a memo defining values for organization-defined parameters (ODPs) in NIST 800-171 Revision 3, a revision that isn’t required under current CMMC 2.0 rules. For those reading between the lines, this memo suggests the DoD is preparing to reflect NIST 800-171 Rev. 3 in CMMC requirements to align with DFARS 252.204-7012.
For contractors, this represents both a warning and an opportunity. Those who act now can get ahead of the curve. Those who wait risk falling behind or, worse, completing CMMC 2.0 certification work only to have to start over when the next update is released.
Here’s how to prepare today for what’s to come.
- Master the Fundamentals of Organization-Defined Parameters
The biggest change in NIST 800-171 Revision 3 is the introduction of clearly formatted ODPs in 50 security requirements. These aren’t just bureaucratic additions, they’re game-changers that transform vague requirements into actionable controls.
Take requirement 3.1.8 as an example. In Revision 2, it simply stated: “Limit unsuccessful log-on attempts.” This left organizations guessing about specifics: How many attempts? Over what timeframe? What happens next?
Revision 3 clarifies this to: “Enforce a limit of [organizationally defined] unsuccessful log-on attempts during [organizationally defined] time periods and take [organizationally defined] actions after the maximum attempts.”
The DoD’s new memo fills in those blanks: limit to 5 consecutive unsuccessful attempts within 5 minutes, then lock the account for at least 15 minutes or until an administrator releases it.
Get your team familiar with the 50 requirements containing ODPs across all 17 control families listed in the memo. Understand that these parameters aren’t suggestions—they’re likely future requirements with specific DoD-defined values.
- Align Your Current Controls with DoD’s Defined Values for NIST 800-171 Rev. 3
The smartest move contractors can make right now is implementing the DoD’s ODP values in their existing NIST 800-171 Revision 2 configurations. This proactive approach means you’ll already be compliant when CMMC requires the NIST 800-171 Revision 3 baseline.
For instance, if you’re currently meeting requirement 3.1.8 in Revision 2, configure your systems now to enforce the DoD’s specified limits: 5 consecutive unsuccessful log-on attempts in 5 minutes, followed by account lockout.
To determine where you land, conduct a gap analysis comparing your current security controls against the DoD’s ODP values. Prioritize implementing changes for high-impact requirements first, particularly those in Access Control, Identification and Authentication, and System and Communications Protection families.
- Understand the Strategic ROI of Early Implementation
The DoD’s early release of these ODP values signals a broader alignment between CMMC and other federal frameworks like FedRAMP and NIST 800-53.
While implementing these DoD-defined parameters will require additional effort upfront, the strategic return on investment is significant. Some requirements will be more stringent than what organizations currently implement—for example, requirement 3.5.5 now specifies that organizations must prevent the reuse of identifiers for at least 10 years, significantly longer than most contractors currently require.
Brief your team and your executives on the business case: early adopters will gain competitive advantages in bidding processes and avoid the rushed compliance efforts that could jeopardize contract eligibility down the line.
- Build Out an Implementation Roadmap
The DoD didn’t release these ODP values randomly. They’re providing the Defense Industrial Base with advance warning and time to prepare.
Develop a phased implementation plan that gradually incorporates DoD ODP values into your existing security posture. Focus on requirements where the DoD values significantly differ from your current practices, and ensure your technical teams understand the specific configuration changes needed.
Moving Forward
The DoD’s memo defining ODP values for NIST 800-171 Rev. 3 isn’t just a policy update; it’s a roadmap to “CMMC 3.0.” The choice is clear: contractors need to prepare now for a smoother transition, or wait and risk scrambling to catch up when “CMMC 3.0” becomes mandatory.
About the Author
Shrav Mehta is founder and CEO of Secureframe, a security compliance automation platform. He previously held roles at Pilot.com, ScaleAI, Lob and Hired.com.
Shrav can be reached on LinkedIn and at www.secureframe.com
