Joint Association Letter to NIST on Protecting Controlled Unclassified Information SP800-171B

This memorandum, submitted by several major higher education associations, responds to NIST's request for public comment on SP 800-171B, expressing strong support for safeguarding Controlled Unclassified Information (CUI) but significant concerns about the lack of clear criteria and guidance for when the enhanced security requirements would apply to university-based research. The associations highlight the potentially prohibitive compliance costs, administrative burdens, and operational challenges posed by the requirements—particularly their ambiguous applicability, overlap with existing regimes, and lack of accommodation for university research environments—and request clearer criteria, consistency among agencies, and flexibility in implementation. They further urge NIST to state explicitly that SP 800-171B requirements are not appropriate for fundamental research, and recommend a revised draft with additional opportunities for public comment to ensure policies do not inadvertently impede vital academic research.