What 3.13.11 means in practice

When cryptography protects CUI, the module doing the work must be FIPS validated, meaning it has a certificate from NIST's Cryptographic Module Validation Program. Strong algorithms alone are not enough: confirm that the validated module is the one actually running, which often means turning on FIPS mode.

SPRS points and the CMMC POA&M

CMMC Level 2 practice
SC.L2-3.13.11
SPRS points
5 points, or 3 with partial credit. Not met subtracts 5 from the score of 110; partially met subtracts 3.
CMMC POA&M
Only when CUI is encrypted but not with FIPS-validated cryptography: scored Partial, it is worth 3 points, and 32 CFR 170.21(a)(2)(ii) makes that case the one exception to the 1-point rule. Without encryption it is worth 5 points and cannot go on a POA&M.
Scoring note
Partial: CUI is encrypted, but not with a FIPS-validated module. It loses 3 points instead of 5. Isolated non-validated use covered by a plan of action counts as Met.

Sources: NIST SP 800-171 DoD Assessment Methodology, version 1.2.1 (June 24, 2020), Annex A; 32 CFR 170.21, Plan of Action and Milestones requirements.

What an assessor checks for 3.13.11

NIST SP 800-171A gives one determination statement for 3.13.11.

Determine if FIPS-validated cryptography is employed to protect the confidentiality of CUI.

NIST SP 800-171A (June 2018), assessment objectives for 3.13.11

Evidence that shows 3.13.11 is met

  • A list of the places where cryptography protects CUI and the module used at each.
  • The CMVP certificate numbers for those modules.
  • Configuration showing FIPS mode turned on where a product needs it.

How PolicyCortex gathers the evidence

PolicyCortex reads this evidence with the collectors below, read only, and grades 3.13.11 from it. Each line says what the product checks.

  • Azure Policy: Assignments. Checks that an Azure Policy assignment enforces FIPS-validated cryptography.

Meet the requirement once. Keep the evidence current.

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