Tag Archives: CMMC

Preparing for DoD’s CMMC

DoD continues to take actions that lead us to believe that they are very serious about the Cybersecurity Maturity Model Certification process.

This process will require that all DoD contractors ultimately get a third party cybersecurity certification on an annual basis if they want to continue to be part of the DoD food chain.

When I say part of the DoD food chain, I mean at every level.  An example DoD used recently was a requirement for the companies that mow the lawn and tend to the bushes at DoD installations would need to be certified.  EVERYONE is the plan.

Reports are the there are plans underway to make changes to the DFARS, the DoD acquisition regulations, this summer to reinforce the certification requirement.

It is also possible that they may extend this to the more general FARs, the acquisition regulations for the rest of the government.  They have been talking about doing that for a couple of years, so if they really do that, it won’t be a real surprise.

One step forward is the naming of Ty Schieber as the head of the 13 member body that is charged with certifying auditors.  Ty is the senior director for executive education at Virginia’s Darden School Foundation.

A DoD spokesperson said that CMMC requirements will begin showing up in presolicitation documents around June of this year.  While that date is very aggressive and may slip, it does seem to indicate that DoD is very serious about this.

Some folks say that requiring contractors to get a certification that they are protecting DoD information might discourage some contractors from bidding on DoD work.

Getting sued by the DoD for breach of contract for not protecting DoD’s information in case of a breach could be a downer as well.  That seems to be the other alternative to me and far worse.

Ignoring situations where the Chinese and others can steal our intellectual property is not a viable option any more.

It is possible that DoD COULD skew the playing field by requiring a higher level of certification than is actually required on a specific contract because their favorite contractor has that level of certification, but DoD bidders are very familiar with disputing DoD contract awards, so that, ultimately, would backfire if they did that at any large scale.

There is a concern, and it is legitimate, that certifications from different auditors could produce different results.  That puts the onus on DoD to set good guidelines so that everyone knows how the process needs to work.

The important thing is to get started now.  While the next version of the spec might change a bit, the basics are locked in stone and it will take a while to get them  done.

The plan, as it has been explained to us, is that contractors who are not certified at the appropriate level will not be allowed to bid on contracts that specify a CMMC requirement.  There will likely be long queues once the final process is announced, so getting started now will put you in a place where you can request certification earlier and get a jump on those people who wait.

Source: Washington Technology

 

 

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It’s Going to be Painful, And It’s Going to Cost Money

These are the words right out of the mouth of Katie Arrington, The Pentagon’s Chief Information Security Officer for the acquistion policy office.  Katie reports up to Kevin Fahey, the Assistant Defense Secretary for Acquisition.  He is the guy who is responsible making sure that the Pentagon spends those hundreds of billions of dollars a year responsibly.

She has been leading the charge for the Pentagon’s new Cybersecurity Maturity Model Certification (CMMC).  The plan is for the Pentagon to require that EVERYONE in the DoD supply chain, from the company providing nuts and bolts to the company writing complex software.  There are 5 CMMC certification levels, depending on the risk that a supply chain provider represents.

The current plan is that the new standard will come out early next year, start being included RFPs in mid-2020 and part of contracts starting in late 2020 (FY22).  For more information check out our CMMC web site.

Currently, companies  who have classified contracts or handle controlled unclassified information have some cybersecurity requirements, but 290,000 defense contractors and suppliers have no requirements right now.

While it is likely that this will be phased in on new contracts and higher risk contracts, Katie says that by 2025 it will be fully rolled out across the entire defense contractor space.  Given the requirements to become certified, now is the time to start planning, even if you think you, as a supplier, won’t be required to be certified until, say 2022.

From a cost standpoint, DoD understands that contract awards today are based on cost, performance and schedule, but they plan to add security as a fourth pillar and they understand that it will cost both you and them money.  That does not mean that you will have a blank check – you won’t – but it does mean that since the DoD standards are higher than general industry, they will have to pay some portion of that cost.

Regarding the pain part, it will be painful.  Companies will need to implement new rules and those rules will affect employees and there are likely at least some things that they will not be able to do any more. In addition, companies will either need to add staff to manage these security requirements or outsource that management.

Katie is saying that the DoD has the ability to FINE companies for selling products with security defects and companies should not underestimate their willingness to use that legal ability.

DoD has struggled since 2013 with improving their Defense Industrial Base’s security practices first by changing the DFARS, the regulations that defense contractors have to follow, then by creating a NIST guide (which is self certified) and now with a standard that requires annual third party certification.  All the while China has been stealing $500 billion a year or more in intellectual property.  Third party certification is the kicker with this rule.  People tend to stretch the truth when they self certify, but a third party that runs the risk of getting their certification rights revoked if they stretch the truth is much less likely to stretch things.

CMMC does not have any exclusions for small contractors.  They have to meet the same standards as Lockheed does.  Since small business systems are less complex, it will be easier for small to meet those standards, but it will not be free and it will not be painless.  Small companies have less internal sophistication and less internal resources, hence the pain part.

So, if you are in the defense supply chain at any level, become educated and start getting compliant.  Or run the risk of getting kicked out of the DoD supply chain.

Source:  Cyberscoop.

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Navy Trying to Fix Their Cybersecurity Mess and Congress is Not Helping

After a horrifying independent review of the Navy’s current cybersecurity posture,  the Navy asked Congress to approve a new position of Assistant Secretary of the Navy to handle  cyber.  This comes after the Navy eliminated the role of CIO last year.

Congress turned them down, so now they are going around Congress to create a Special Assistant to the Secretary for Information Management/Chief Information Officer, which does not require Congressional approval.  They are also going to assign about 15-20 people to a team to work on the task.  Since there is no new money for this, many of these people will be getting additional jobs.  That, of course, will make them less effective, but at least the Navy is trying.

The Navy will also be hiring four senior leaders to run directorates inside this new office: a chief technology officer, a chief data officer, a chief digital strategy officer and a chief information security officer.  Congress has authorized special pay in certain areas like this at the rate of 1.5 times that of the Vice President of the US or about $300,000 a year per person.  They hope to attract folks from industry with numbers like this.

Their objective is to improve security across the Defense Industrial Base in light of the Chinese (and others) threat.  A key priority is to get second, third and fourth tier suppliers to implement strict cybersecurity regulations, specifically NIST SP 800-171.

Many contractors have ignored the requirements of 800-171, in part because of the cost and in part because the DoD has not been enforcing it.  In combination with the new proposed third party cybersecurity certification requirement (CMMC) that the DoD is talking about implementing next year, contractors who ignore these requirements may effectively eliminate themselves from getting any DoD contracts.  A good strategy would be to up your cybersecurity program effort in advance of these new rules going into effect, because it will take a while to get your program up to speed.

Source: Federal Computer Weekly.

 

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