Georgia Tech Procurement Assistance Center

DOD’s proposed cybersecurity maturity model certification requirements: what we know and how to prepare

By

The final DFARS cybersecurity rule promulgated in 2016, which included the latest changes to the DFARS clause at 252.204-7012, was a significant development for DoD contractors, in part because it mandates compliance with the 110 security controls in National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171.  DoD has been working with the contracting community since that time with respect to the implementation of the final rule, but has concluded that further compliance steps are needed in the form of cybersecurity certification standards.

The anticipated new cybersecurity certification standards for DoD contractors are quickly taking shape.  Katie Arrington, former South Carolina legislator and current special assistant for Cybersecurity to Assistant Secretary of Defense for Acquisition, recently announced that DoD is partnering with the Carnegie Mellon University Software Engineering Institute and the Johns Hopkins University Applied Physics Laboratory in developing the new certification standard: the Cybersecurity Maturity Model Certification or “CMMC.”  This Alert outlines what has been revealed thus far about the CMMC, how the CMMC will affect DoD contractors, and steps you can take to be ready when the CMMC goes live.

Continue reading at:  Miles & Stockbridge

7 steps for getting right with NIST 800-171

By

The deadline for defense contractors and subcontractors to implement the information security requirements listed in the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 has come and gone.  There are more than 100 information security requirements in NIST 800-171, and it is a good bet that many smaller companies without ample IT resources fall into the category of: “We missed the deadline… what now?”

If you want to continue working with the Department of Defense, the simple answer is you will have to be 800-171 compliant.  This includes secure file sharing and information exchange governance, namely how you store, access, exchange and govern sensitive (but unclassified) information with the agency.  And while the December 31, 2017, deadline was directed at DOD’s industry partners, NIST 800-171 applies to all non-federal organizations that work with U.S. government systems and data.  So the suggestions below are in no way limited to defense contractors!

Continue reading at:  Federal Computer Week

The importance of compliance with DFARS cybersecurity regulations

By

Clicking the “COMPLY” check box on the list of government requirement flow-downs may seem like a necessary evil of being a supplier to the defense market, but some regulations around information and cybersecurity provide the critical foundations of a trusted computing supply chain.

Cyber and information warfare are the hottest and possibly most contested battlefields in the race for military dominance. Case in point, the U.S. Navy recently changed the name of Space and Naval Warfare Systems Command (SPAWAR) to the Naval Information Warfare Systems Command (NAVWAR), in recognition of how important information warfare to defense strategy.

Similarly, earlier this year, the U.S. Army, announced the evolution of its Cyber Command into the Information Warfare Command, and the U.S. Air Force announced the merger of the 24th Air Force (Air Forces Cyber) and the 25th Air Force, to create a new information warfare focused command.

By all indicators, information currently sits near the top of the food chain of assets requiring protection.  To that end, the U.S. Department of Defense (DOD) upped the ante on regulations around what types of information need protection and how much suppliers must protect that information.

Continue reading here:  Military and Aerospace Electronics

NIST updates SP 800-171 to help defend sensitive information from cyberattack

By

An update to one of the National Institute of Standards and Technology’s (NIST) information security documents offers strategies to help protect sensitive information that is stored in computers supporting critical government programs and high value assets. 

The document, entitled Draft NIST Special Publication (SP) 800-171 Revision 2: Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations, now has a new draft companion publication, NIST SP 800-171B, that offers additional recommendations for handling Controlled Unclassified Information (CUI) in situations where that information runs a higher than usual risk of exposure.  CUI includes a wide variety of information types, from individuals’ names or Social Security numbers to critical defense information. 

When CUI is part of a critical program or a high value asset — such as a weapons system — it can become a significant target for high-end, sophisticated adversaries.  In recent years, these programs and assets have been subjected to an ongoing barrage of serious cyberattacks, prompting the Department of Defense to request additional guidance from NIST. 

 “We need to provide safeguards and countermeasures that can stand up to these attacks,” said NIST’s Ron Ross, one of the publication’s authors.  “We are requesting comments on this initial public draft, which we hope will help organizations protect CUI against our most advanced and persistent adversaries.” 

NIST is accepting comments on both SP 800-171 Rev. 2, which received minor editorial updates, and SP 800-171B until July 19, 2019.  In the future, NIST plans to issue  final versions of both publications.  In addition, a previously available companion document, NIST SP 800-171A, will be updated with new assessment procedures for the enhanced security requirements. 

Continue reading at:  NIST website

DoD unveils proposed cybersecurity capability model certification standards

By

Cybersecurity.  It’s never over, is it?  In what can only be described as a “soft” release, the Department of Defense (DoD) has slowly and quietly begun to reveal its intent to provide federal contractors with a formal cybersecurity certification as early as next year.  The program, known as the Cybersecurity Capability Model Certification (CCMC), is an effort to streamline the acquisition process by providing acquiring agencies and consenting contractors with more exacting cybersecurity requirements for forthcoming acquisitions.

Moreover, as announced clearly and repeatedly by the Special Assistant to the Assistant Secretary of Defense for Acquisition and Sustainment for Cyber, Katie Arrington, during events on May 23, 2019, and June 12, 2019, certain cybersecurity costs will be allowable under certain circumstances.  This means that not only is DoD again in the process of facilitating the acquisition of cybersecurity capabilities throughout its entire supply chain, but now the DoD recognizes that it should actually pay for what it requires of contractors.

Continue reading at:  McCarter and English

The cost to comply with DoD’s new cybersecurity requirements to be reimbursable on cost contracts

By

Law360 published an article recently with the title, “DoD Official Says Cyber is an Allowable Contractor Cost.”  The article states that the U.S. Department of Defense (DoD) will allow defense contractors to treat the costs of bringing their cybersecurity programs in line with DoD requirements as an allowable cost and, therefore, reimbursable.  Specifically, at the June 14, 2019 Professional Services Council’s Federal Acquisition Conference, DoD special assistant for cybersecurity Katie Arrington said, “security is an allowable cost.”

Further, Law360 reported that in May, DoD said it was developing a “Cybersecurity Maturity Model Certification” (CMMC) program to build on the Defense Federal Acquisition Regulation Supplement regulation (DFARS § 252.204-7012(b)(2)) that requires defense contractors to implement the security controls in the National Institute of Standards and Technology’s Special Publication (NIST SP) 800-171.  The security controls are intended to protect covered defense information on nonfederal systems.  DoD said the CMMC will require defense contractors to get third-party audits of their compliance with the NIST SP 800-171 controls, down through their supply chains.

Arrington told the conference attendees that the CMMC will be developed by DoD working in conjunction with the Johns Hopkins University Applied Physics Lab and Carnegie Mellon University Software Engineering Institute.  The goal is to develop one unified standard for cybersecurity.  This standard will include five different levels of required cybersecurity protections, from a level one of “basic hygiene,” which will be cheap and straightforward enough that a small business could meet it, to level five for “state-of-the-art” protections.  Arrington said that DoD has planned 12 related industry days across the United States in July and August to work in a collaborative manner with defense contractors to improve cybersecurity practices in the CMMC plan.  Acknowledgments to Daniel Wilson and Law360 for reporting these developments.

Continue reading at:  Taft Stettinius & Hollister LLP

Doing business with the U.S. Government in an era of cybersecurity, espionage and executive orders

By

In an era of trade wars, espionage, and executive orders, how can companies who wish to dive into government procurement or are already involved in procurement abide by Federal laws and data security regulations and increase the likelihood of proper procurement?

Recently, the D.C. law firm Sheppard Mullin hosted a podcast discussing various government contracting requirements, including those related to cybersecurity.  Topics discussed include:

What does the legal landscape look like for doing business with the U.S. government?

What various layers of laws apply to government contracting?

When it comes to cybersecurity, what new developments have emerged that affect government contracts?

What type of security controls should contractors implement to protect data?

What are security control “families”?

What security rules are specific to government contractors and why are they important for companies of all types to be familiar with them?

Why is it important to be open to checking where your sensitive data and documenting your plan to protect that data?

The “Plan of Action” the Department of Defense requires.

What is the National Defense Authorization Act and what does it establish?

How has the 2019 Executive Order affected information and telecommunications technologies?

How are the Federal Acquisition Regulations playing a role in the trade war with China?

You can listen to the podcast at:  The Sheppard Mullin website

Pentagon to unveil new Cybersecurity Maturity Model Certification (CMMC) for defense contractors

By

The Department of Defense announced that it is developing a new cybersecurity standard and certification for defense contractors.  It is named the “Cybersecurity Maturity Model Certification” (CMMC).

Notably, the intent of the CMMC is to improve cybersecurity deficiencies in the defense industrial base and secure the supply chain.

The CMMC is expected to be based on NIST SP 800-171, as is the current Defense Federal Acquisition Regulation Supplement (DFARS) rule.  Specifically, DFARS Clause 252.204-7012 requires defense contractors handling sensitive, unclassified information to implement the 110 security controls of NIST SP 800-171.

However, the CMMC may incorporate or rely on frameworks in addition to NIST SP 800-171.

According to news reports, the CMMC will serve as the enforcement mechanism lacking in the current DFARS rule.

Although the draft CMMC has not yet been published, it’s been reported that there will be 5 levels of certification.  The levels will range from basic cyber hygiene to “State-of-the-Art.”  DoD contracts will require specific levels — and awards will be “go/no-go” based on the contractor’s certification status.

This is a fundamental change to how defense contracts are awarded today.

Read more at:  JD Supra

Northrop Grumman to provide free cybersecurity training to small businesses June 4th

By

Northrop Grumman, in collaboration with the USC Center for Economic Development, is offering FREE cybersecurity training to small businesses.  The workshop is open to all small businesses, but advance registration is required.

The primary purpose of the one-day 8-hour workshop is to ensure that small businesses are aware of the cybersecurity requirements mandated under Defense Federal Acquisition Regulations Supplement (“DFARS”) Subpart 204.73 (Safeguarding Covered Defense Information and Cyber Incident Reporting).  The workshop will focus on understanding the risks associated with safeguarding controlled unclassified DoD information. 

The workshop will focus on the groups of controls from NIST SP 800-171, with examples highlighting what happens when these controls are not implemented.  By the end of the workshop, small businesses will become familiar with all 110 controls and be able to better identify the areas where you may need greater focus to meet the DoD’s cybersecurity expectations.

Here are the details about the event:

Date:  Tuesday, June 4, 2019

Time:  8 a.m. to 5 p.m. ET

Location:  Loudermilk Conference Center, 40 Courtland Street NE, Atlanta, GA 30303

The training will also be available online via webinar.

For registration, visit:  https://events.r20.constantcontact.com/register/eventReg?oeidk=a07eg5xonme7588be26&oseq=&c=&ch=

Regional banker says Augusta government contracting boom imminent

By

The Augusta metro area is sitting on a powder keg of cybersecurity investment, and the fuse is getting shorter by the day.

Ed Spenceley, a government contracting specialist for Bank of America Merrill Lynch, said the nation’s growing defense budget and Augusta’s burgeoning cyber industry puts the region on a collision course with companies looking for government contracts.

The retired U.S. Army intelligence specialist, speaking at the Invest Augusta conference Thursday, said he sees Augusta as an “epicenter” for cyber-based industries well beyond the arrival of Army Cyber Command to Fort Gordon next year.

Continue reading at:  The Augusta Chronicle

Contracting News

Read More

Contracting Tips

Read More

GTPAC News

Read More

Georgia Tech News

Read More