Cybersecurity

Have contractors implemented the NIST 800-171 controls? DOD Inspector General (IG) audit suggests not, recommends third-party audits. Are you ready?

A recent audit conducted in response to a request from the Secretary of Defense determined that DOD contractors did not consistently implement DOD‑mandated system security controls for safeguarding Defense information. Specifically, Defense Federal Acquisition Regulation Supplement (DFARS) clause 252.204-7012 requires contractors that maintain Controlled Unclassified Information (CUI) to implement security controls specified in National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171, which lists security requirements for safeguarding sensitive information on non-Federal information systems. The requirements include controls for user authentication, user access, media protection, incident response, vulnerability management, and confidentiality of information.

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.

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.