The five readiness steps
- 1. Inventory the instruments. Contracts, grants, cooperative agreements, Space Act agreements, and subcontract flow-downs — each read for the CUI and security terms it actually incorporates. NASA's directive shapes what agreements say; the agreement is what binds you.
- 2. Find the NASA CUI. Technical data, research results, pre-decisional information — identify what you hold that NASA designates as CUI, where it enters your environment, and everywhere it travels. In research settings this is the hardest and most valuable step.
- 3. Draw the smallest defensible boundary. Shared lab infrastructure, collaboration platforms, student and visiting-researcher access — research environments sprawl by default. A deliberate enclave for NASA CUI (see enclave architecture) usually beats bringing the whole institution into scope, on both cost and credibility.
- 4. Implement and document to the incorporated baseline. 800-171 at the revision your agreement incorporates, with an SSP written from the live environment and evidence at the objective level — ready for whatever demonstration the agreement anticipates.
- 5. Operate for agreement churn. NASA work arrives as a stream of agreements with varying terms. A program with a maintained obligations matrix absorbs each new award as a delta review, not a fresh scramble.
The research-institution trap
Universities and research organizations often try to satisfy NASA terms with campus-wide general IT controls. Assessorial reality: a boundary you can't enumerate is a boundary you can't defend. The pattern that works is containment — a defined environment where NASA CUI lives, with the full control set implemented deeply there instead of shallowly everywhere.
Turn your NASA agreement into an operating program.
Send the agreement type and where you are — a practitioner will map the actual obligation and the smallest boundary that satisfies it. Or email rj@indirectit.com directly.