Georgia Tech Procurement Assistance Center

Readying contractors’ security plans for evaluation

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The Defense Department recently issued final guidance for requiring activities to assess contractors’ system security plans and their implementation of the security controls in National Institute of Standards and Technology Special Publication 800-171.

It includes a compliance guidance document, which explains how department entities will assess contractor implementation of its security controls, and an impact guidance document, which explains how the Pentagon will assess the risks of security controls not implemented.

The compliance guidance addresses three objectives pre-award: requiring a self-attestation of implementation of the special publication in all proposals; imposing enhanced security controls in certain situations; and providing alternatives for compliance as an evaluation factor.

Defense Federal Acquisition Regulation Supplement 252.204-7008, which is required in every noncommercial off-the-shelf solicitation, provides that “[b]y submission of this offer, the offeror represents that it will implement the security requirements specified by [NIST SP 800-171].” The Defense Department has interpreted “implementation” as having a completed security system plan and a plan of action and milestones for the relevant covered defense information.

If a requiring activity believes that enhanced security controls are required beyond those in NIST SP 800-171, the compliance guidance provides direction for adding the requirements to a solicitation.

The guidance does not define what constitutes “enhanced controls.” NIST is expected to issue a new appendix of enhanced controls in the first quarter of 2019.

Keep reading this article at: http://www.nationaldefensemagazine.org/articles/2019/1/30/readying-security-plans-for-evaluation

See GTPAC’s video, template and other resources designed to help contractors comply with the DoD/NIST cybersecurity rules at: http://gtpac.org/cybersecurity-training-video/

DoD continues to up the ante on cybersecurity compliance for contractors

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Compliance with the security controls in National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 is only the beginning for contractors that receive controlled defense information (CDI) in performance of Department of Defense (DoD) contracts and subcontracts.

Faced with an evolving cyber threat, DoD contractors have experienced an increased emphasis on protecting DoD’s information and on confirming contractor compliance with DoD cybersecurity requirements.  This includes audits by the DoD Inspector General (IG) “to determine whether DoD contractors have security controls in place” to protect CDI and enhanced security controls for certain high risk contractor networks.

And on September 28, 2018, the Navy issued a policy memorandum calling for enhanced cybersecurity requirements, including some that have generated opposition within the defense community such as the installation of network sensors by the Naval Criminal Investigative Service on contractor systems.

Other requiring activities are reportedly requiring similar enhanced protections, and NIST is expected to issue a public draft of Revision 2 to NIST SP 800-171 by the end of February, with an appendix of additional enhanced controls.

Keep reading this article at: https://www.insidegovernmentcontracts.com/2019/01/dod-continues-ante-cybersecurity-compliance-contractors/

See GTPAC’s video, template and other resources designed to help contractors comply with the DoD/NIST cybersecurity rules at: http://gtpac.org/cybersecurity-training-video/

The new rules of cybersecurity

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At this very moment someone, somewhere in the world may be plotting to hack into an organization’s critical network infrastructure.

Creativity, time and investment are never in short supply when determined attackers are intent on gaining access to networks. It’s created an environment whereby solutions to prevent attacks are being developed just after new hacking tactics are deployed. To solve this divergence, we need to focus on “cyber at machine speed” — implementing new tools simultaneously with or even before hackers.

In short, getting the basics right is no longer enough. Adversaries now have the tools, the motivation and certainly the persistence to overcome current standards and compliance protocols.

Simply put, adequacy is no longer adequate.

Keep reading this article at: https://www.nextgov.com/ideas/2018/12/new-rules-cybersecurity/153714/

See GTPAC’s video, template and other resources designed to help contractors comply with the DoD/NIST cybersecurity rules at: http://gtpac.org/cybersecurity-training-video/

DoD and other agencies seek to enhance contractors’ cyber and supply chain security

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The Department of Defense (DoD) and its component services and agencies are taking several independent steps to assess and enhance their cyber and supply chain security that will directly or indirectly affect DoD contractors and subcontractors.

Other federal agencies, including the Department of Homeland Security (DHS), Commerce, and General Services Administration (GSA), are also considering or implementing measures to enhance cyber and supply chain security that will directly or indirectly affect government contractors and their supply chains.

These initiatives will intensify scrutiny of government contractors and subcontractors, increase their cyber and supply chain security compliance requirements, and affect their ability to compete for, and win, government contracts. This article summarizes these initiatives and states our view that, despite the proposal and likely adoption of a comprehensive new Federal Acquisition Regulation (FAR) cybersecurity clause next year, federal government contractors and subcontractors are likely to face multiple, overlapping, and possibly conflicting cybersecurity and supply chain requirements for some time to come.

Keep reading this article at: http://www.mondaq.com/article.asp?articleid=767144

See GTPAC’s video, template and other resources designed to help contractors comply with the DoD/NIST cybersecurity rules at: http://gtpac.org/cybersecurity-training-video/

Contractors are a bull’s-eye for hackers

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The U.S. defense industrial supply chain is vast, complex and vulnerable. Organic components, large-scale integrators, myriad commercial service providers, and tens of thousands of private companies sustain the Defense Department. According to the SANS Institute, the percentage of cyber breaches that originate in the supply chain could be as high as 80 percent.

Some progress has undoubtedly been made with regard to securing the supply chain. The Defense Federal Acquisition Regulation Supplement (DFARS) NIST SP 800-171 supply chain program, for instance, introduced 109 stringent requirements for Defense Department suppliers dealing with sensitive government data—53 related to technology and 56 related to security policy.

But while DFARS applies to all contractors and suppliers regardless of size, it has not yet been fully implemented and it is not bulletproof.  Still, it is a big step toward securing the supply chain at all levels.

Keep reading this article at: https://www.afcea.org/content/contractors-are-bulls-eye-hackers

See GTPAC’s video, template and other resources designed to help contractors comply with the DoD/NIST cybersecurity rules at: http://gtpac.org/cybersecurity-training-video/

Pentagon considers cybersecurity certification for its contractors

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In cybersecurity, you’re only as strong as your weakest link.

For the Defense Department, the area with the fewest cyber protections are the defense contractors the department works with, particularly the small businesses that don’t have the expertise or resources to build a robust security posture.

The Pentagon put together a task force to assess whether small businesses within the defense industrial base are complying with the cybersecurity framework published by the National Institute of Standards and Technology and provide assistance to companies that need help.

The department issued a new rule last year requiring vendors to show that they are in compliance with NIST standards or have a plan to get there quickly. Those plans were due Jan. 1.

Keep reading this article at: https://www.nextgov.com/cybersecurity/2018/12/pentagon-considers-cybersecurity-certification-its-contractors/153330/

See GTPAC’s video, template and other resources designed to help contractors comply with the DoD/NIST cybersecurity rules at: http://gtpac.org/cybersecurity-training-video/

DoD issues final guidance for assessing contractor compliance with NIST SP 800-171

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The Department of Defense (DoD) recently issued final guidance for requiring activities to assess contractors’ System Security Plans (SSPs) and their implementation of the security controls in National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171.

A draft of this guidance was made available for public comment in April 2018.  As noted in an earlier post on the draft guidance, DoD’s proposed approach raised significant questions as to what role offerors’ implementation of the security controls in NIST SP 800-171 would play in bid protests, contract performance, and post award audits.  In the memorandum accompanying the final guidance documents, DoD notes that it has incorporated comments it received from the public into the final guidance.  As discussed below, although the DoD has addressed some of the issues raised by the April draft, the final guidance adds some additional concerns and ambiguities.

The final guidance consists of two documents.  The first document is “Guidance for Assessing Compliance of and Enhancing Protections for a Contractor’s Internal Unclassified Information System,” which provides direction to requiring activities for including evaluation criteria in solicitations and in contracts for assessing contractor compliance with NIST SP 800-171.  The second document is “DoD Guidance for Reviewing System Security Plans and the NIST SP 800-171 Security Requirements Not Yet Implemented,” which addresses how DoD should assess the impact and risk of NIST SP 800-171 security controls that a contractor has not yet implemented.

Keep reading this article at: https://www.insidegovernmentcontracts.com/2018/11/dod-issues-final-guidance-for-assessing-contractor-compliance-with-nist-sp-800-171/

See GTPAC’s video, template and other resources designed to help contractors comply with the DoD/NIST cybersecurity rules at: http://gtpac.org/cybersecurity-training-video/

GSA proposes new cybersecurity reporting rules for contractors

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The General Services Administration (GSA) is proposing new rules shaping how contractors protect government information on the IT systems they manage.

Tucked in a Friday Federal Register post detailing the Unified Agenda of Federal Regulatory and Deregulatory Actions, two proposed rules — GSAR Case 2016-G511 and 2016-G515 — call for amending the General Services Administration Acquisition Regulation to include requirements for contractors to safeguard GSA information in a solicitation’s statement of work, as well as the procedures for they inform the agency of a potential breach.

GSAR Case 2016-G511 allows contracting officers to implement agency cyber requirements and standards into each solicitation, providing a centralized cybersecurity guidance across the enterprise for contractors to adhere to.

Keep reading this article at: https://www.fedscoop.com/gsa-proposes-2-new-cybersecurity-reporting-rules-contractors/

Resources for complying with DoD’s current contractor cybersecurity rules may be found here: https://gtpac.org/cybersecurity-training-video/

Revisions coming for NIST’s data protection guide, will address ‘advanced’ cyber threats

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The National Institute of Standards and Technology (NIST) is planning to issue a draft second revision to its guidelines for controlled unclassified information handled by the Defense Department and government contractors, in order to better address “advanced persistent threats,” according to a key NIST official.

The upcoming draft revisions are based on recent assessments that information critical for national security requires “enhanced” protections, the NIST official said at a public meeting updating industry and government officials on the data requirements at NIST headquarters on Oct. 18, 2018.

NIST’s Ron Ross said a draft revision to NIST guideline 800-171 would be issued before the end of the year for public comment. The revisions are “just in the planning stages this week” and a formal announcement will be issued soon. Ross said the enhanced requirements would be proposed for comment as an appendix to the overall document to offer additional protections beyond “basic” controls outlined in chapter three of the guidelines.

The NIST guidelines are the basis for Defense Federal Acquisition Regulation Supplement, or DFARS, for cybersecurity risks issued in 2017 and still being implemented by DOD.

Keep reading this article at: https://insidedefense.com/insider/nist-official-revisions-coming-data-protection-guide-will-address-advanced-cyber-threats

See GTPAC’s video, template and other resources designed to help contractors comply with the DoD/NIST cybersecurity rules at: http://gtpac.org/cybersecurity-training-video/

Cybersecurity compliance: A key to future DoD contract awards

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In a recent address at the Air Force Association’s Air, Space & Cyber Conference, Deputy Secretary of Defense Patrick Shanahan emphasized that cybersecurity will become a “critical measurement” for making contract awards as well as a significant consideration in holding a government contractor accountable for its performance.

Shanahan noted that while DoD acquisitions currently focus on three critical measurements—quality, cost and schedule—cybersecurity is “probably going to be what we call the . . . fourth critical measurement.” The DoD is “going to work with [its] industrial partners to help them be as accountable for security as they are for quality.”

Shanahan also noted that adequate cybersecurity protection is part of the standard baseline of government contracting security—it is not an optional feature. He commented, “And it shouldn’t be that being secure comes with a big bill. It’s just like we wouldn’t pay extra for quality.” Consequently, government contractors should recognize that the government “shouldn’t pay extra for security,” he added. Rather, “security is the standard. It’s the expectation. It’s not something that’s above and beyond what we’ve done before.”

Keep reading this article at: http://www.mondaq.com/article.asp?articleid=742094

See GTPAC’s video, template and other resources designed to help contractors comply with the DoD/NIST cybersecurity rules at: http://gtpac.org/cybersecurity-training-video/

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