Government Contractor Security Assessment Template

Federal contractors handle Controlled Unclassified Information (CUI) worth billions in intellectual property and national security data. Your third-party risk program needs specialized assessment tools that speak the language of DFARS, NIST 800-171, and CMMC requirements.

Generic security questionnaires miss critical federal requirements. They don't ask about CUI data flows, FIPS 140-2 encryption standards, or mandatory 72-hour breach reporting to DIBNet. They don't verify whether your vendor's incident response plan includes the DoD Cyber Crime Center.

A purpose-built Government Contractor Security Assessment Template translates complex federal requirements into actionable assessment questions. Instead of asking "Do you encrypt data?", it asks "Do you implement FIPS 140-2 validated encryption modules for CUI at rest per NIST 800-171 3.13.11?"

This precision matters. Federal contract flow-downs make you responsible for your subcontractors' compliance failures. One vendor's NIST 800-171 gap becomes your DFARS violation, potentially triggering False Claims Act liability.

Core Template Sections

1. Organizational Security Requirements (NIST 800-171 Family 3.1-3.3)

Your template must verify access control implementation beyond standard role-based permissions. Federal contractors need:

CUI Access Controls

• Separation of duties for CUI system administration
• Privileged access management with session recording
• Automated de-provisioning within 24 hours of termination
• Quarterly access reviews with documented justification

Evidence Requirements

Control	Evidence Type	Verification Method
3.1.1 (System Access)	Access control matrix	Screenshot of AD groups + CUI markings
3.1.2 (CUI Transactions)	Transaction logs	30-day sample of CUI access logs
3.2.1 (Awareness Training)	Training records	Completion certificates + CUI modules

2. System and Communications Protection (Family 3.13)

Standard encryption questions fail federal audits. Your assessment needs granular verification:

Encryption Standards Matrix

• FIPS 140-2 Level 2 modules for CUI at rest
• TLS 1.2+ with approved cipher suites for transmission
• Key management procedures following NIST SP 800-57
• Certificate pinning for mobile CUI applications

Network Segmentation Requirements Ask for network diagrams showing:

• CUI enclave isolation from corporate networks
• DMZ architecture for internet-facing systems
• Jump box configurations for administrative access
• Data diode implementation for one-way transfers

3. Incident Response and Reporting (Family 3.6)

Federal contractors face unique reporting requirements absent from commercial frameworks:

DIBNet Reporting Verification

Required Evidence:
- DIBNet portal access screenshots
- 72-hour reporting procedures
- Cyber incident preservation protocols
- DoD CIO notification templates
- Practice drill documentation (quarterly)

Supply Chain Communication Your template must verify:

• Prime contractor notification procedures (4-hour SLA)
• Evidence preservation for DoD forensics
• Media sanitization certificates per NIST SP 800-88
• Chain of custody procedures for compromised systems

Industry-Specific Applications

Financial Services Federal Contractors

Banks processing military payroll or VA benefits need additional controls:

FFIEC Alignment Points

• Map NIST 800-171 to FFIEC CAT controls
• Verify dual compliance reporting structures
• Document CUI isolation from GLBA data
• Validate insider threat programs per NISPOM

Evidence Collection Priorities

1. Network segmentation between CUI and PII systems
2. Dual-control implementation for CUI modifications
3. Background investigation status (SF-86/e-QIP)
4. Visitor access logs for CUI facilities

Healthcare Federal Contractors

TRICARE processors and VA system integrators face overlapping requirements:

HIPAA-CUI Crosswalk

Requirement	HIPAA Reference	NIST 800-171 Control
Encryption	§164.312(a)(2)(iv)	3.13.11, 3.13.16
Access Logs	§164.312(b)	3.3.1, 3.3.2
Incident Response	§164.308(a)(6)	3.6.1, 3.6.2

Unique Healthcare Assessments

• Medical device CUI isolation procedures
• Clinical system segmentation architecture
• PHI/CUI data flow mapping
• Backup encryption for imaging systems

Defense Industrial Base

Traditional defense contractors need CMMC-aligned assessments:

CMMC Level 2 Preparation Your template should include:

• Self-assessment scoring per NIST 800-171A
• POA&M templates with 180-day timelines
• Evidence packages for C3PAO validation
• Inheritance models for FedRAMP services

Implementation Best Practices

1. Risk-Based Scoping

Not all contractors need full assessments. Build tiering logic:

Tier 1: CUI Processors (Full 110 controls)

• Direct CUI creation/storage/transmission
• DFARS 252.204-7012 flow-down
• Annual assessments + quarterly validations

Tier 2: Covered Contractors (Subset)

• Incidental CUI access
• Focus on 3.1, 3.4, 3.13 families
• Annual self-attestation

Tier 3: Non-CUI Support (Baseline)

• No CUI access
• Basic cybersecurity hygiene
• Biennial reviews

2. Evidence Automation

Manual evidence collection kills TPRM velocity. Automate where possible:

API-Driven Collection

# Example evidence automation
evidence_requirements = {
    "3.1.1": ["AD group membership", "Last access review"],
    "3.13.11": ["Encryption status", "FIPS module version"],
    "3.3.1": ["Log retention policy", "Sample logs"]
}

Continuous Monitoring Integration

• BitSight/SecurityScorecard for external posture
• Whistic/Vanta for control attestations
• OneTrust/MetricStream for workflow automation

3. Control Inheritance Documentation

Federal contractors often inherit controls from cloud providers:

FedRAMP Inheritance Matrix

Provider	Inherited Controls	Customer Responsibility
AWS GovCloud	3.13.11 (infrastructure)	3.13.11 (application layer)
Azure Government	3.3.1 (CloudTrail)	3.3.2 (app logs)
Google Federal	3.6.1 (platform IR)	3.6.2 (data breach)

Document shared responsibility boundaries in your assessment.

Common Implementation Mistakes

1. Treating NIST 800-171 as Optional

"We'll implement controls after contract award" triggers False Claims Act liability. Your assessment must verify current-state compliance, not future promises.

2. Generic Security Questionnaires

SOC 2 Type II isn't NIST 800-171 compliance. Your template needs federal-specific questions:

• FIPS 140-2 validation numbers
• CUI marking procedures
• DIBNet reporting workflows
• CMMC self-assessment scores

3. Ignoring Flow-Down Requirements

Prime contractors remain liable for subcontractor failures. Verify:

• DFARS clauses in subcontracts
• CUI identification in flow-downs
• Subcontractor assessment procedures
• Remediation oversight processes

4. Static Annual Assessments

Federal requirements change quarterly. Build update mechanisms:

• CMMC rule monitoring
• DFARS clause updates
• Agency-specific bulletins
• Interim rule implementations

5. Insufficient Evidence Depth

"Yes, we encrypt data" fails audits. Require:

• Encryption certificates
• Key management procedures
• Algorithm implementation details
• FIPS validation certificates

Frequently Asked Questions

How does this template differ from standard security questionnaires?

It maps directly to NIST 800-171's 110 controls with federal-specific evidence requirements like FIPS 140-2 certificates, DIBNet reporting procedures, and CUI marking protocols that generic questionnaires miss.

Can I use FedRAMP compliance as a substitute for contractor assessments?

FedRAMP covers infrastructure controls but not CUI-specific requirements. You need supplemental assessment for controls 3.1.3 (CUI flow control), 3.4.2 (CUI marking), and 3.6.2 (federal reporting).

What evidence should I prioritize for CMMC preparation?

Focus on System Security Plan (SSP) documentation, POA&M tracking with remediation timelines, and technical evidence for encryption controls (3.13.11) and multifactor authentication (3.5.3).

How often should I reassess government contractors?

Annual full assessments for Tier 1 CUI processors, with quarterly validation of high-risk controls. Contractors under CMMC must maintain continuous compliance, not point-in-time certification.

Should international contractors complete the same assessment?

Yes, but add ITAR/EAR export control verifications and data residency requirements. Non-US contractors cannot use certain FedRAMP services and need alternative control implementations.

How do I handle classified contractor assessments?

This template covers CUI only. Classified contractors need DD-254 security specifications and NISPOM compliance verification through Defense Counterintelligence and Security Agency (DCSA).

What automation tools integrate with government contractor assessments?

CMMC-AB marketplace tools, GRC platforms with NIST 800-171 modules, and federal-specific vendors like Exostar and PreVeil offer API-driven assessment capabilities.