Get ready for the next wave of contractor compliance requirements
- By Keren Cummins, Marty Fischer
- Apr 11, 2018
With the DOD’s compliance deadline in the rearview mirror, here are a few things that civilian contractors can learn from their DOD counterparts and proactive steps they should be taking in advance of GSA publishing its final requirements:
Get familiar with 800-171
While GSA and other agencies have not yet published their final requirements, the likelihood that 800-171 will be the basis for all other government requirements is very high. For those contractors not targeting GSA or DOD, let this be a warning. While other agencies may not be telegraphing their plans for enforcing similar requirements, you never know when such requirements will suddenly appear in the next RFP.
If this happens, at a minimum you should be able to demonstrate that your company is working toward a more secure state and be able to provide a status of actual implementations taking place that support that goal.
Additionally, now would be a good time to make sure your security and compliance vendor partners/suppliers are not only well versed in 800-171 requirements, but that they can provide consulting services based on their experience helping other government contractors succeed.
Stand up an internal working group
Achieving compliance with 800-171 or a similar set of cyber requirements can’t be limited to either a technical approach or a management approach. It requires engagement from both areas. Contractors will be well served to seek diverse perspectives.
A good first step is to proactively establish an internal working group that includes a leader from each area that will be impacted by the requirements – reflecting both technical and managerial perspectives.
One of the first action items of the group should be to quickly establish communications with the agency point of contact (POC) and/or program office that is responsible for enforcing cyber requirements.
Assess your current state
Your team should review the Basic and Derived Requirements for the 14 “Security Families” itemized in 800-171.
Note that NIST has already tailored these requirements so as to omit the ones that are uniquely governmental.
For each requirement, identify where you already have a process or program that does or could be modified to address that requirement and where you will need to create one. Document this baseline, because you will want to be able to demonstrate progress against it.
If you don’t already have one, get familiar with those automation tools that can enable you to quickly (and continuously) ascertain your organization’s state of compliance and produce metrics and audit-ready information.
A surprising number of requirements can be managed, audited, or both, through the use of security and compliance automation tools that provide a far better alternative to a historically manual approach. Ideally, this tool will enable automated assessments specifically against the 800-171 policy. This will make it easier to start defining both technical and management processes and to demonstrate to an auditor that you are advancing to a more secure state.
After knowing your current state of security, determine what level of compliance is achievable with minimal investment vs. what a more comprehensive path to compliance might look like. In other words, identify and address the low-hanging fruit.
A good resource for guidance in this area is the Center for Internet Security (CIS) 20 Critical Security Controls. This guidance ranks foundational security controls according to impact and helps to identify which controls deliver the biggest bang for your security buck.
DOD and GSA should be commended for identifying standards that raise their overall state of security. Unfortunately, achieving compliance to those standards, in many cases, represents a significant change to the way contractors do business.
In order to set contractors up for future success and ultimately improve the government’s overall risk posture, leaders in other agencies that are planning for similar requirements should consider establishing a specific program office that has an in-depth understanding of the mandate’s specifications and timelines in order to provide clear guidance and to support successful implementation of these requirements.
As with all requirements, interpretation is seldom clear, and application is seldom universal. Having a dedicated government resource to help contractors successfully ride this wave will be a win-win for both government and contractor.
Keren Cummins is federal director at Tripwire where she works with federal customers on the complexities of managing critical security controls and on strengthening their risk management strategies.
Marty Fischer is the business director for Tripwire who is responsible for working with federal systems integrators.