Is it time to test the limits -- and potential -- of expanding CMMC?
Calls for a certified baseline of cybersecurity seem to increase with every cyberattack. Is the CMMC model the right template for a universal and independently verifiable way to protect supply chains?
Calls for a certified baseline of cybersecurity seem to increase with every cyberattack. And the recent ransomware attack that shut down the East Coast's largest fuel pipeline, Colonial Pipeline, is no exception.
The Cybersecurity Maturity Model Certification program is one of several Defense Department efforts to improve both its own cyber defenses and those of its industry partners. CMMC has been touted as a potential standard that could expand beyond the Defense Industrial Base (DIB) to cover all government contractors. But the core CMMC program is still taking shape, and it's unclear how that will look in the future.
"You could be completely CMMC compliant and you still would have been compromised by SolarWinds," David Simpson, former chief of the Federal Communications Commission's Public Safety and Homeland Security Bureau, told FCW, echoing a sentiment that has been stressed by DOD officials. "It's onerous in a way that removes the risk piece of what was intended originally from NIST and the risk management framework, which is we should be incenting companies to apply the resources where the risk is greatest, where either the probability or the impact of a breach is greatest."
CMMC is still in its early stages. DOD is expected to put its requirements in pilot contracts later this year, and there has been substantial industry pushback on both the requirements the means of certifying compliance. But with the urgent need for an independently verifiable way to measure an organization's cybersecurity and protect supply chains, the CMMC program offers a template to bring that to reality.
Eric Crusius, a partner in Holland and Knight's government contracts practice, told FCW that CMMC could be expanded to other fields.
"There's not really another way to verify compliance if there is not compliance except having a third party do it," Crusius said. That third party could be the government or it could be this kind of CMMC body and the trained assessors ... I think the system is the best that the government can do at this point."
Crusius continued, saying that third-party verification format could be expanded to include compliance with supply chain requirements, like section 889 of the 2019 defense policy bill that bars use of telecommunications equipment by key Chinese manufacturers, such as Huawei and ZTE, and to civilian government agencies and private sector organizations to ensure that they have good cyber hygiene.
"But I don't think there's anything in the model right now that speaks to anything beyond what boils down to a check-the-box scenario," Crusius said. "That's not a criticism of DOD, that's just how any kind of system like this would have -- it's tough to avoid it. In fact, with present-day technology it's difficult to get beyond that."
Simpson said that, to be effective, DOD will have to make CMMC -- or any security certification standard -- easy for small tech companies to implement.
"CMMC is not a perfect animal," Simpson said. "It will improve the DIB security posture, but at what cost? If the cost includes driving emerging technology companies out of the DOD business, then that not only has a monetary cost for DOD, but that has a mission readiness cost as our forces become less and less competitive with peer adversaries around the world."
CMMC likely won't -- and shouldn't -- be shelved because so much work is underway, Simpson stressed. But adjustments to the program, how it is used and how it shapes policy could help ameliorate security and supply chain concerns.
"I think that we need to change our approach to cyber policy in a way that is more like what we're trying to manage," Simpson said, like adopting an approach that "builds the right government policy in stream with building minimum viable products."
CMMC covers both specific practices, which pull from a number of standards like Risk Management Framework and ISO 27001, and broader security processes. The process requirements don't kick in until CMMC Level 2, however, and Simpson argued that those should come first.
"Let's recognize that we want these emergent technology companies, at gestation, to begin working with the federal government," Simpson said.
The first process requirement being to have a cyber program, Simpson said. From there, companies would focus on developing cyber acuity alongside developing the technology instead of cybersecurity being a forgotten cost or an "investment that they got to make" for a certification program they have probably never heard of."
That expansion could start with rapid acquisition contracts as DOD moves to embrace new technologies at the enterprise level.
"One of the goals of [other transaction agreements] is to increase the participation in these projects and these initiatives for small and innovative emerging technology businesses; the people inventing stuff," Simpson said. "And if we're not careful and...bring that CMMC litmus test before companies can participate in OTAs...it'd be a real step backwards in the DOD."
Looking beyond CMMC
Terry Halvorsen, the former DOD CIO turned IBM general manager for the federal and public sector, told FCW he expects DOD to take a broad look at all of its cybersecurity and supply chain efforts this year -- especially when it comes to making sure that cybersecurity can be executed by everybody
"How do we get a more comprehensive view of [those] key security elements," Halvorsen said.
"We're going to need to see more cooperation and more sharing of the data so that every agency and every company isn't trying to do every aspect of cybersecurity."
To get there, DOD and the federal government overall, will have to share threat data better, which means increasing cloud adoption and reliable policy enforcement. But while CMMC will likely be a part of the equation, a broad compliance mechanism, may not be the whole answer.
"Zero trust is a mindset that has standards; there are some things we do today but they will change tomorrow, but that mindset should not change," Halvorsen said.
"I think what you're going to see is a set of acceptable standards and options....There's not going to be here's the way to do this; it's going to take multiple ways," Halvorsen said.
The former DOD CIO said more policy, like the executive order on supply chain, that encourages or supports the need for standards is vital for increased information sharing.
"We need to write policy so that it can be inclusive of things that haven't been invented yet," Halvorsen said. "I'm beginning to see that. You're 'seeing much more come out and policy that, instead of being prescriptive, talks about, well if you can do these type of capabilities, then that's okay, that'll work."
Corbin Evans, the National Defense Industry Association's principal director for strategic programs, told FCW that zero trust was "one piece of the puzzle" and that "no one of these compliance regimes or set of regulations is going to solve all of the problems related to data loss; it's going to be an additional part."
The question comes back to defining the data, Evans said, and which data deserves protection, particularly with CMMC.
"Defining exactly what information needs to be protected --- that's been a huge issue with CMMC, the definition of controlled unclassified information and how that plays into what levels of protection each set of industry needs," Evans said. He added that he's looking for the government to get to a place where a contractor can look at the government data it gets and know what needs to be protected.
"You have to have the government folks actually right-sizing the information that they hand over to industry," he said. That right-sizing "requires more effort, requires more training, it requires more attention to detail...that's just a sea change in the way that we're thinking about government contracting."