3.9.1Screen people before granting access in Rev. 3
Reworded: 03.09.01 Personnel Screening. Gains organization-defined parameters.
Status as of 2026-09-08
Rev. 2 is what a contract requires today. DFARS 252.204-7012 and the CMMC rule at 32 CFR 170 point at NIST SP 800-171 Rev. 2, and a standing DoD class deviation keeps it there. NIST has published Rev. 3, but publishing a revision does not change an obligation. A move to Rev. 3 would arrive through the Department's reform process and formal rulemaking, a change to that deviation or an amendment to the rule, not through publication. The Department has published its organization-defined parameter values for Rev. 3 in preparation; that is groundwork, not adoption.
Side by side
Rev. 2 · in force 3.9.1 Screen Individuals
Assessment objectives · 800-171A
- [a] individuals are screened prior to authorizing access to organizational systems containing CUI
Rev. 3 · not adopted 03.09.01 Personnel Screening
a. Screen individuals prior to authorizing access to the system.
b. Rescreen individuals in accordance with [Assignment: organization-defined conditions requiring rescreening].
Determination statements · 800-171A Rev. 3
- 03.09.01.a individuals are screened prior to authorizing access to the system.
- 03.09.01.b individuals are rescreened in accordance with the following conditions: <A.03.09.01.ODP[01]: conditions>.
Organization-defined parameters
- A.03.09.01.ODP[01] conditions that require the rescreening of individuals are defined.
Draws on Rev. 2 3.9.1.
Left: NIST SP 800-171 Rev. 2 and 800-171A, verbatim. Right: NIST SP 800-171 Rev. 3 and 800-171A Rev. 3, verbatim, with organization-defined blanks highlighted.
Word by word
The Rev. 2 requirement compared with its Rev. 3 successor. A mechanical comparison of the two verbatim texts, not an interpretation.
removed in Rev. 3 added in Rev. 3
Rev. 2 3.9.1 → Rev. 3 03.09.01 Personnel Screening
7 words kept, 4 removed, 12 added. Rev. 3 statement labels omitted for the comparison.
What NIST says changed
- New security requirement title
- Aligned with SP 800-53, Rev 5 to address rescreening individuals
- Added new ODP: conditions requiring rescreening
NIST, SP 800-171 Rev. 2 to Rev. 3 change analysis, class “Minor change”. At adoption, Bedrock files this under “Review”.
NIST's Rev. 3 discussion for 03.09.01
Personnel security screening activities involve the assessment of the conduct, integrity, judgment, loyalty, reliability, and stability of an individual (i.e., the individual’s trustworthiness) prior to authorizing access to the system or when elevating system access. The screening and rescreening activities reflect applicable federal laws, Executive Orders, directives, policies, regulations, and criteria established for the level of access required for the assigned position.
What this means for you now
Nothing changes in what you are assessed against until a class deviation or a published rule adopts Rev. 3. Keep meeting 3.9.1 as written in Rev. 2, and if you already choose a value for the parameters above in practice, write it down where your system security plan can find it.
Bedrock CMMC shows this same comparison against your own package, with your current status on the Rev. 2 side, so the day adoption lands the migration is a review, not a rewrite.
Where this page's facts come from
- Rev. 2 text and objectives
- bedrock-cmmc-api@89b8e8e:migrations/004_reference_requirements.sql#Requirement.basicRequirement@rev2; bedrock-cmmc-api@89b8e8e:migrations/005_reference_objectives.sql#AssessmentObjective.description@rev2
- Mapping and change class
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/r2_r3_transition_map.json#r2_to_r3
- Rev. 3 03.09.01
- bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/rev3.json#requirements[]