CMMC in GWACs

GSA is expected to begin applying the Department of Defense’s Cyber Maturity Model Certification (CMMC) at the order level to governmentwide acquisition contract vehicles. (Govconwire, November 10, 2020)

According to Keith Nakasone, deputy assistant commissioner for acquisition in the General Services Administration Office of IT, future Government Wide Acquisition Contracts (GWACs) will include CMMC requirements, layered in over time. In this video interview, Nakasone explains that the requirements are being added to make sure contracts are within scope for the Department of Defense, the largest GWAC customer. (Government Matters, November 8, 2020)

Nakasone hopes to educate and train industry partners on the CMMC requirements over time. Although he didn’t state outright that CMMC will become part of all future contracts, they are part of the Polaris draft RFP, scheduled for release in December. (ibid)

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Self-Assess No More

Cybersecurity for  Department of Defense (DoD) contractors is an ongoing issue. Now, DoD is issuing an interim rule to implement an Assessment Methodology and Cybersecurity Maturity Model Certification framework. This will assess contractor implementation of cybersecurity requirements and enhance the protection of unclassified information within the DoD supply chain. (Federal Register, DFARS Case 2019-D041 Action: Interim Rule)

The current self-attestation of NIST Special Publication (SP) 800-171 is not working due to a lack of DoD verification. Until the implementation of the interim rule, DoD did not have a mandate to verify contractor basic safeguarding or security requirements prior to contract award.  This regulation changes that. The interim rule adds a process for contractors to  implement cybersecurity requirements. This is to be accomplished while the DoD’s Cybersecurity Maturity Model Certification (CMMC) and the procedures with the Accreditation Body (AB) are solidified. (Meritalk, September 28, 2020)

Questions about how the new rule will affect your contract or upcoming bid and what you can expect? Give us a call.

CMMC Coming to Solicitations

Cybersecurity Maturity Model Certification (CMMC) requirements may show up in solicitations within six months. (GOVCONWire, May 12, 2020)

A Department of Defense spokesperson expects about 10 DoD RFIs in June to include the new requirements. She said, “As we release the RFIs, we’ll have the certified and trained auditors who will be able to go out to industry and certify companies at the level of maturity required for the work that they’re bidding on.” (ibid)

Additionally, changes to the Defense Federal Acquisition Regulation Supplement 252.204-7012 should be finalized by October. “You will not see the CMMC in any Department of Defense contracts or RFPs until the rule change is completed.” (ibid)

Questions on the Cybersecurity Maturity Model Certification and whether you can bid on upcoming solicitations? Give us a call.

CMMC not for COTS

A recent modification to DoD’s website spells out a small but very specific change about the Cybersecurity Maturity Model Certification (CMMC): it’s not applicable to DoD suppliers that only provide commercial-off-the-shelf products. (FedScoop, May 5, 2020)

Originally, DoD and CMMC administrators explained that all contractors and subcontractors must be certified under  CMMC by a third-party assessor. However, a few weeks ago, the Office of the Under Secretary of Defense for Acquisition and Sustainment changed the official website. The revised FAQ section states: “Companies that solely produce Commercial-Off-The-Shelf (COTS) products do not require a CMMC certification.” (ibid)

CMMC is in place to certify contractors have the cybersecurity practices in place to work with controlled unclassified information, the actual products themselves. (ibid)

Wondering if CMMC applies to the products and or services you provide? Give us a call.

New Cybersecurity Certification Requirements

The Office for the Under Secretary of Defense and Sustainment (OUSD (A&S)) recently released its Cyber Security Maturity model Certification (CMMC). DoD stakeholders, University Affiliated Research Centers (UARCs), Federally Funded Research and Development Centers (FFRDCs) and the Defense Industrial Base (DIB) all had a hand in developing the CMMC model. This model measures cybersecurity maturity using five levels (from basic to advanced) and aligns a set of processes and practices with the type and sensitivity of the information to be protected and any associated threats to that information. (CMMC Model v1.0, January 30, 2020)

DoD’s CMMC enhances the protection of:

  • Federal Contract Information (FCI) provided or generated by the government, but not intended for public release
  • Controlled Unclassified Information (CUI), which requires safeguarding or dissemination consistent with laws, regulations and government-wide policies. (ibid)

The CMMC model includes the safeguarding requirements for FCI spelled out in FAR clause 52.204-21 and the security requirements for CUI stated in the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 per DFARS clause 252.204-7012 [3,4,5].

Included in the CMMC model is a certification piece verifying the implementation of cybersecurity maturity measure processes and practices. This is intended to deliver assurance to the DoD that contractors and subcontractors can sufficiently protect CUI at a level equal to the risk. (ibid)

To obtain a full overview of the CMMC Model, domains, practices, and processes, please review the Cybersecurity Maturity Model Certification.

Have questions about the effect on your current contract or one in works? Give us a call.