IT Compliance Checklist for Government Contractors and Public Sector Organizations

Working with government agencies comes with stringent IT compliance requirements. Whether you're a contractor, a municipal department, or a public sector organization, failing to meet these requirements can mean lost contracts, audit findings, or security incidents.

This checklist covers the key compliance frameworks and practical controls required for government IT operations.

Framework Overview

NIST Cybersecurity Framework

Who must comply: Federal contractors, many state agencies, organizations seeking best-practice alignment

Structure: Five functions—Identify, Protect, Detect, Respond, Recover

Key characteristic: Risk-based, flexible implementation

NIST 800-171

Who must comply: Contractors handling Controlled Unclassified Information (CUI)

Key characteristic: 110 specific security requirements

CJIS Security Policy

Who must comply: Anyone accessing FBI CJIS data (law enforcement, courts, certain contractors)

Key characteristic: Specific technical requirements with regular audits

FISMA

Who must comply: Federal agencies and contractors operating federal systems

Key characteristic: Risk-based, continuous monitoring focus

State-Specific Requirements

Vary significantly but often based on NIST frameworks. Check your specific state requirements.

Access Control

✅ 1. Unique User Identification

Every user has a unique identifier. No shared accounts.

All frameworks require this.

✅ 2. Authentication Management

• Minimum password requirements documented and enforced
• Account lockout after failed attempts
• Password history prevents reuse
• Periodic password changes (or risk-based approach)

✅ 3. Multi-Factor Authentication

• Required for remote access
• Required for privileged accounts
• Required for access to sensitive systems/data

CJIS specifically requires MFA for remote access to CJI.

✅ 4. Least Privilege

• Users have minimum access required for job function
• Privileged access limited and controlled
• Access reviewed regularly (quarterly recommended)

✅ 5. Account Management

• Documented process for creating accounts
• Approval required for access
• Timely termination when access no longer needed
• Regular review of active accounts

✅ 6. Remote Access Controls

• VPN or equivalent secure access
• Session timeout for inactive sessions
• Monitoring of remote access activity

Audit and Accountability

✅ 7. Audit Logging Enabled

• Login/logout events
• Failed access attempts
• Changes to security settings
• Access to sensitive data
• Privileged user actions

✅ 8. Audit Log Protection

• Logs protected from unauthorized modification
• Logs backed up to separate system
• Retention per requirements (typically 1-7 years depending on framework)

✅ 9. Audit Review

• Regular review of audit logs (automated alerting preferred)
• Investigation of anomalies
• Documented procedures for review

✅ 10. Time Synchronization

• All systems synchronized to authoritative time source
• Enables correlation of events across systems

Security Awareness and Training

✅ 11. Security Awareness Training

• All users trained on security policies and procedures
• Training upon hire and annually thereafter
• Documentation of completion

✅ 12. Role-Based Training

• Additional training for privileged users
• Training relevant to job functions
• Updated when threats/systems change

✅ 13. Training on Specific Requirements

• CJIS: CJIS-specific security awareness
• CUI: Handling of Controlled Unclassified Information
• Privacy: PII handling requirements

Configuration Management

✅ 14. Baseline Configurations

• Standard configurations documented
• Systems deployed from baselines
• Deviations approved and documented

✅ 15. Change Management

• Changes approved before implementation
• Changes tested before production
• Rollback procedures documented
• Changes logged and auditable

✅ 16. Security Configuration

• Unnecessary services disabled
• Unnecessary ports closed
• Default passwords changed
• Security features enabled

✅ 17. Software Inventory

• Authorized software documented
• Unauthorized software detected and removed
• Software versions tracked

✅ 18. Hardware Inventory

• All hardware inventoried
• Hardware changes tracked
• Unauthorized devices detected

Identification and Authentication

✅ 19. User Identification

• Users uniquely identified before access
• Identification verified at enrollment
• Identity credentials protected

✅ 20. Device Identification (where required)

• Devices identified before network access
• Unauthorized devices blocked or alerted

✅ 21. Authenticator Management

• Password/credential distribution secure
• Credentials changed when compromise suspected
• Default credentials eliminated

Incident Response

✅ 22. Incident Response Capability

• Documented incident response procedures
• Designated incident response personnel
• Regular testing/exercises

✅ 23. Incident Detection

• Monitoring for security events
• Alerting mechanisms in place
• Regular review of indicators

✅ 24. Incident Reporting

• Internal reporting procedures
• External reporting procedures (agency contacts, law enforcement)
• Timelines documented per requirements

CJIS requires reporting within 24 hours.

✅ 25. Incident Response Testing

• Annual testing at minimum
• Tabletop exercises or simulations
• Lessons learned documented

Maintenance

✅ 26. Controlled Maintenance

• Maintenance activities approved and documented
• Maintenance personnel authorized
• Tools controlled

✅ 27. Remote Maintenance

• Remote maintenance sessions monitored
• Sessions terminated when complete
• Remote maintenance tools controlled

Media Protection

✅ 28. Media Access Control

• Removable media restricted
• USB controls implemented where required
• Media labeled per sensitivity

✅ 29. Media Sanitization

• Documented sanitization procedures
• Verification of sanitization
• Records retained

✅ 30. Media Transport

• Encryption for media in transport
• Chain of custody for sensitive media
• Approved transport methods

Physical Protection

✅ 31. Physical Access Controls

• Facilities with sensitive systems secured
• Access limited to authorized personnel
• Visitor controls in place

✅ 32. Physical Access Monitoring

• Access logged (badge systems, visitor logs)
• Surveillance where appropriate
• Logs reviewed

✅ 33. Environmental Controls

• Fire suppression appropriate for equipment
• Temperature and humidity monitoring
• Power protection (UPS, generator where critical)

Risk Assessment

✅ 34. Risk Assessment

• Documented risk assessment performed
• Updated when significant changes occur
• At least annually reviewed

✅ 35. Vulnerability Scanning

• Regular vulnerability scanning (monthly minimum)
• Findings tracked and remediated
• High/critical findings addressed promptly

✅ 36. Penetration Testing (where required)

• Annual penetration testing for sensitive systems
• Findings remediated
• Retesting to verify remediation

System and Communications Protection

✅ 37. Boundary Protection

• Network perimeter defined and protected
• Firewall rules documented and reviewed
• Traffic monitored

✅ 38. Encryption

• Data encrypted in transit (TLS 1.2+)
• Data encrypted at rest (sensitive data/mobile devices)
• FIPS 140-2 validated encryption where required

CJIS requires FIPS 140-2 validated encryption.

✅ 39. Network Segmentation

• Sensitive systems separated from general network
• Guest/public access isolated
• Monitoring between segments

✅ 40. Malicious Code Protection

• Anti-malware/EDR on all endpoints
• Regular signature/behavior updates
• Centralized management and alerting

System and Information Integrity

✅ 41. Patch Management

• Patches applied within defined timeframes
• Critical patches expedited
• Testing before production deployment
• Documentation of patching status

✅ 42. Security Alerts

• Subscribed to security advisories
• Alerts reviewed promptly
• Relevant advisories acted upon

✅ 43. Integrity Monitoring

• Changes to critical files detected
• Alerting on unauthorized changes
• Baseline integrity documented

Personnel Security

✅ 44. Background Checks

• Appropriate screening before access granted
• Periodic rescreening where required
• Results documented

CJIS has specific fingerprint-based background check requirements.

✅ 45. Termination Procedures

• Access revoked immediately upon termination
• Equipment returned
• Exit procedures documented

✅ 46. Transfer Procedures

• Access modified when job duties change
• Old access revoked promptly

Backup and Recovery

✅ 47. Backup Procedures

• Regular backups performed
• Backup encryption
• Off-site storage

✅ 48. Backup Testing

• Regular recovery testing
• Test results documented
• Issues remediated

✅ 49. Contingency Planning

• Documented contingency/disaster recovery plan
• Contact information current
• Regular testing

Documentation and Policies

✅ 50. Security Policies

• Comprehensive security policies documented
• Policies reviewed and updated regularly
• Policies communicated to workforce
• Acknowledgment documented

How Did You Score?

45-50 checks: Strong compliance posture. Focus on continuous improvement and evidence collection.

35-44 checks: Good foundation with gaps. Prioritize missing controls based on framework requirements.

25-34 checks: Significant gaps. May face audit findings or contract issues.

Under 25 checks: High risk. Comprehensive remediation needed.

Getting Help

Government compliance requirements are complex and evolving. Most organizations don't have the internal expertise to navigate multiple frameworks while maintaining operations.

Layth Solutions has been supporting government contractors and public sector organizations in the Northeast for 30 years. We understand the compliance landscape and can help you achieve and maintain the requirements for your specific situation.

Request a compliance assessment to understand your current posture and develop a practical roadmap for meeting your requirements.