Why DFARS / NIST SP 800-171?
A few years back, the United States Department of Defense (DoD) released a new regulation, a Defense Federal Acquisition Regulation Supplement, or “DFARS” (DFARS 252.204-7012), which aimed to bolster cybersecurity in the Defense Industrial Base (DIB) by setting clear requirements outlined in the National Institute of Standards and Technology’s (NIST) Special Publication (SP) 800-171. The requirements serve to protect Controlled Unclassified Information (CUI) from falling into the wrong hands and was a positive step in the effort to strengthen U.S. national security.
The CMMC Accreditation Body Says DFARS is the First Step to Success
Although DFARS was in 2016, organizations that are part of the DoD supply chain are focusing on meeting the DFARS requirements years later, in 2020.
When the DoD first released version 1.0 of the CMMC and announced that the new Cybersecurity Maturity Model Certification (CMMC) framework would replace the DFARS standard in their effort to assess the cybersecurity posture of the defense industrial base, many organizations were left scrambling to learn how applicable their previous work on NIST SP 800-171 was to the new requirements. Thankfully, the CMMC Accreditation Body (AB) has made it clear that aligning with the DFARS standard is paramount to the Cybersecurity Maturity Model Certification from small business or prime DoD contractors.
The Cybersecurity Maturity Model Certification is slotted to be added to prime DoD contracts in 2020 as a unified standard for “go/no go” decisions at the time of award. It will require organizations in the DoD supply chain to undergo a CMMC audit by an official CMMC auditor. This program as outlined by the Office of the Under Secretary of Defense for Acquisition and Sustainment (OUSDA&S) will serve as verification ensuring that the defense supplier has adequate cybersecurity practices across basic cyber hygiene, processes, procedures, and policies in place. The Cybersecurity Maturity Model Certification naturally builds on DFARS cybersecurity requirements by adding the certification piece. Different levels of the CMMC security requirements or CMMC levels 1-5, include more advanced practices to reduce cybersecurity risk as more CUI is present, or further up the DoD supply chain up to the prime contractors, denoting a higher certification level requirement.
Ultimately, the DoD will require all DIB organizations to undergo the CMMC audits and CMMC assessments to validate their cybersecurity practices, performed by independent third-party certified organizations. Aligning with the DFARS standard, which naturally aligns with CMMC requirements outlined in Tier 3 - the Tier that most contractors will be required to comply with - is the best and most effective move for defense industrial base members looking to win contracts associated with the DoD in 2020 and beyond - so says the CMMC AB, Katie Arrington, and the writers of the Cybersecurity Maturity Model Certification among others.
View the infographic below to learn how to start with DFARS and achieve CMMC level 3.