When shopping for a Managed Security Services Provider (MSSP), there are plenty of checklists that you can download to help funnel you right to that vendor’s particular product. This isn’t that blog post, although at some point I am sure we have published one too. While checklists are helpful in narrowing down the capabilities and tools that you want to add to your probably already too big portfolio of tools, the focus should really be on the services that you will be adding to your existing team.
A recently released 10-month review consisting of 10 years’ worth of inspector general’s (IG) reports across eight federal agencies by the Permanent Subcommittee on Investigations of the Senate Homeland Security Committee found that “Agencies currently fail to comply with basic cybersecurity standards.” The full report can be found here and the major themes identified in the report highlighted yet again the fundamental work that isn’t being done to comply with basic cybersecurity standards. So why isn’t the work being done? Is it a lack of money, tools, people, all the above? Buried on page 46 of the report then-DHS CIO Richard Staropoli is quoted in a 2017 interview with the Subcommittee, on the state of the OCIO saying, “You can write this down and quote me, the problem is piss-poor management.”
That blunt assessment, it’s a management problem, is worth considering. Better outcomes can be achieved, across the Federal government and industry, with a disciplined, framework-based approach to cybersecurity. This approach and the guaranteed better outcomes that will follow require a recognition that many of the management disciplines inherent in other business supporting functions like finance and engineering are missing in cybersecurity. The problems in cybersecurity are different but the principles required to improve them are not.
Complying with DoD Cybersecurity Requirements: What do NIST 800-171 Revision 2 and 800-171B Drafts Mean for Your Business?
NIST 800-171 Revision 2 and 800-171B drafts were released for comment last week, and as expected there have been no major changes proposed to the controls in NIST 800-171 Revision 2. For DoD contractors waiting to implement the required security requirements of NIST 800-171 Revision 1 pending the latest updates, the proposed updates won’t buy you any time. The fact is enforcement is underway and compliance with DoD cybersecurity requirements is a go/no go decision if you are serious about being eligible to do business with the DoD.
The recently announced Cybersecurity Maturity Model Certification (CMMC) scheduled for completion by January 2020 has many DoD contractors scrambling to anticipate how to prepare. While there are many unknowns regarding what the CMMC will ultimately look like, DoD contractors should focus on what is already known and currently mandatory with DFARS 252.204-7012, which requires the implementation of NIST 800-171. Stop trying to read the tea leaves and doing the bare minimum by writing System Security Plans (SSP’s) and start implementing the 110 security requirements of NIST 800-171. Demonstrable action, that is NIST 800-171 control implementation, is the best way to prepare for the CMMC.
Recent News: Act Now to Achieve NIST 800-171 Compliance or Risk Your Ability to Contract with the DoD
The window of opportunity for achieving compliance with DFARS 252.204-7012, which requires the implementation of NIST 800-171 across the DoD supply chain, continues to get smaller as the ability to self-certify is set to expire.
CyberSheath attended the Professional Service Council’s 2019 Federal Acquisition Conference where Special Assistant to DoD’s Assistant Secretary of Defense Acquisition for Cyber Katie Arrington stated clearly that “…cost, schedule, and performance cannot be traded for security.” Security is the foundation of defense acquisition.