Security and your supply chain: 5 steps to take right now

Gettyimages.com/ Baloncici

Every contractor, supplier and sub needs to take steps to protect their supply chain. Here are steps to take right now.

The future of contracting looks like an oasis, or rather an OASIS+ contract. Government contractors and companies in the defense industrial base just have one catch: They are on the hook to help secure the nation’s supply chains.

The Government Accountability Office published a series of reports recently that outlined the highest cybersecurity risks to the government, including those that need to be addressed urgently. The reports highlight the need to protect the nation’s critical infrastructures, the technology systems used to carry out fundamental operations and maintain these infrastructures, and the need for cybersecurity and supply chain risk management (C-SCRM) to address significant supply chain vulnerabilities.

The GAO reports have led to cybersecurity requirements for those wishing to bid on new contracts and a warning: The Government may perform a cyber-supply chain risk assessment of the awarded contractor at any time during the period of performance.

That might not sound impressive until you consider the impact.

Nearly every business in America will feel the effects—not just primes and subs. Any company that is a vendor to a prime or sub or that sells a commercially available product that a contractor uses is considered part of their supply chain—and therefore needs to demonstrate advanced cybersecurity—or risk being labeled as unsafe.

OASIS+ has a requirement upon submission for contractors to submit an initial cybersecurity supply chain risk management plan with their proposal. And if awarded, they must add to or improve that plan within 90 days.

This imperative is a wake-up call for contractors who have been hoping to skate by without investing in more rigorous or sophisticated cybersecurity. If OASIS+ is your vision, there are five steps you must take.

1. Know your security stance and requirements

Conduct an assessment of your current security profile and study up on what is required by your current contracts.

If you’ve got your ducks in order, this could be as simple as checking your latest Supplier Performance Risk System (SPRS) score, System Security Plan (SSP), and Plan Of Action & Milestones (POA&M) and providing the relevant information to your contracting officer. However, data suggests that many contractors and companies in the supply chains aren’t prepared, and their cybersecurity is severely lacking—unable to meet even the basic 15 controls outlined in FAR 52.204-21.

There are lots of free resources to help you understand the standards and break down the technical language, including resources from the National Institute of Standards (NIST), the gold standard for government cybersecurity. Dig in and keep going—security is a new operational area that every company will need to address.

2. Apply the standardsand prove it

Companies looking to do business are increasingly asked about their security stance. Your compliance score may have already replaced your company’s credit score as a requirement to transact.

For many companies, the process of becoming compliant can take six to nine months or more, underscoring the imperative of starting now. It won’t be enough to say you’ve improved security or even to have a senior executive self-attest to it. In order to meet contract requirements, companies need to prove their compliance, and that requires documentation and security monitoring. If all of this sounds foreign to you, spend some time reading up on digital trust.

3. Tough love: Vet your supply chain

As a contractor, you’re also responsible for verifying the security of those within your supply chain. That requires asking some pointed questions to determine if every vendor or supplier meets the standards—and making tough decisions to cut ties with those who don’t hold up or aren’t willing to invest in security. Many companies find a vendor screening process, often including some forms and a follow-up interview, allows them to cover all the bases from invoicing to security to personnel.

If you have subcontractors or vendors who are key to your delivery, you might decide to help them with their cybersecurity posture. That could mean technical or financial assistance to implement needed policies.

The government has made it easy to determine if cloud service offerings are compliant. If it’s FedRAMP® approved, you're good to go.

4. Decision point: Have you done enough?

Having oversight is a major theme in the GAO reports. Indeed, we’ve already seen a few cases where the Department of Justice has gotten involved to charge contractor companies that experienced a breach or attack because their security wasn’t up to standards under the False Claims Information Act. Some have even targeted the senior executives who attested to the security standards being met.

For OASIS+, the risk of noncompliance comes down to being removed from the contract, easily the largest in the last 20 years. No contractor or supplier can afford to lose the trust of customers, particularly one like the General Services Administration.

5. Get help where it counts: In your wallet

Few companies can afford to keep a cadre of cybersecurity professionals on the payroll. For the rest, consultants can make a world of difference, accelerating progress by using best practices and proven solutions to efficiently meet their cybersecurity requirements.

A strong security posture is its own reward, yet there will be readers who balk at having to spend thousands to comply.

In the latest IBM study (2022), the average cost of a data breach was $4.35 million, a figure that makes prevention sound downright affordable. There are plenty of other financial impacts to consider, too. The cost of cyber insurance doubled for companies that didn’t improve their cybersecurity stance in the past year, while those who did invest saw premiums drop. And the cost-saving for companies who have an incident response plan and regularly test it was estimated to be $2.66 million, the result of lower breach damages.

There's no upside to skipping out on security throughout your supply chain. We had the unique experience, during the COVID pandemic, of witnessing first-hand how important these links are, and how one disruption can cascade into a major crisis. Even worse than being unable to get our hands on toilet paper, baby formula, or masks, we saw the rolling impact of security disruptions within a supply chain, like Solar Winds (2020), Microsoft (2021), and WannaCry (2017). 

The GAO points out that it made over 4,000 recommendations to Federal agencies to address cybersecurity shortcomings stretching back to 1997. As of December 2022, over 880 of these had not been fully implemented, including 134 designated as priority recommendations. Now they’re asking contractors to lead the way, bringing their entire supply chains into a modern cybersecurity era. Without every company down the line helping to make security a real, national priority, we’ll be looking at a mirage instead of an oasis.


Edward Tuorinsky, managing principal of DTS, a government and commercial consultant business, brings more than two decades of experience in management consulting and information technology services.

X
This website uses cookies to enhance user experience and to analyze performance and traffic on our website. We also share information about your use of our site with our social media, advertising and analytics partners. Learn More / Do Not Sell My Personal Information
Accept Cookies
X
Cookie Preferences Cookie List

Do Not Sell My Personal Information

When you visit our website, we store cookies on your browser to collect information. The information collected might relate to you, your preferences or your device, and is mostly used to make the site work as you expect it to and to provide a more personalized web experience. However, you can choose not to allow certain types of cookies, which may impact your experience of the site and the services we are able to offer. Click on the different category headings to find out more and change our default settings according to your preference. You cannot opt-out of our First Party Strictly Necessary Cookies as they are deployed in order to ensure the proper functioning of our website (such as prompting the cookie banner and remembering your settings, to log into your account, to redirect you when you log out, etc.). For more information about the First and Third Party Cookies used please follow this link.

Allow All Cookies

Manage Consent Preferences

Strictly Necessary Cookies - Always Active

We do not allow you to opt-out of our certain cookies, as they are necessary to ensure the proper functioning of our website (such as prompting our cookie banner and remembering your privacy choices) and/or to monitor site performance. These cookies are not used in a way that constitutes a “sale” of your data under the CCPA. You can set your browser to block or alert you about these cookies, but some parts of the site will not work as intended if you do so. You can usually find these settings in the Options or Preferences menu of your browser. Visit www.allaboutcookies.org to learn more.

Sale of Personal Data, Targeting & Social Media Cookies

Under the California Consumer Privacy Act, you have the right to opt-out of the sale of your personal information to third parties. These cookies collect information for analytics and to personalize your experience with targeted ads. You may exercise your right to opt out of the sale of personal information by using this toggle switch. If you opt out we will not be able to offer you personalised ads and will not hand over your personal information to any third parties. Additionally, you may contact our legal department for further clarification about your rights as a California consumer by using this Exercise My Rights link

If you have enabled privacy controls on your browser (such as a plugin), we have to take that as a valid request to opt-out. Therefore we would not be able to track your activity through the web. This may affect our ability to personalize ads according to your preferences.

Targeting cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Social media cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.

If you want to opt out of all of our lead reports and lists, please submit a privacy request at our Do Not Sell page.

Save Settings
Cookie Preferences Cookie List

Cookie List

A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts. More specifically, we use cookies and other tracking technologies for the following purposes:

Strictly Necessary Cookies

We do not allow you to opt-out of our certain cookies, as they are necessary to ensure the proper functioning of our website (such as prompting our cookie banner and remembering your privacy choices) and/or to monitor site performance. These cookies are not used in a way that constitutes a “sale” of your data under the CCPA. You can set your browser to block or alert you about these cookies, but some parts of the site will not work as intended if you do so. You can usually find these settings in the Options or Preferences menu of your browser. Visit www.allaboutcookies.org to learn more.

Functional Cookies

We do not allow you to opt-out of our certain cookies, as they are necessary to ensure the proper functioning of our website (such as prompting our cookie banner and remembering your privacy choices) and/or to monitor site performance. These cookies are not used in a way that constitutes a “sale” of your data under the CCPA. You can set your browser to block or alert you about these cookies, but some parts of the site will not work as intended if you do so. You can usually find these settings in the Options or Preferences menu of your browser. Visit www.allaboutcookies.org to learn more.

Performance Cookies

We do not allow you to opt-out of our certain cookies, as they are necessary to ensure the proper functioning of our website (such as prompting our cookie banner and remembering your privacy choices) and/or to monitor site performance. These cookies are not used in a way that constitutes a “sale” of your data under the CCPA. You can set your browser to block or alert you about these cookies, but some parts of the site will not work as intended if you do so. You can usually find these settings in the Options or Preferences menu of your browser. Visit www.allaboutcookies.org to learn more.

Sale of Personal Data

We also use cookies to personalize your experience on our websites, including by determining the most relevant content and advertisements to show you, and to monitor site traffic and performance, so that we may improve our websites and your experience. You may opt out of our use of such cookies (and the associated “sale” of your Personal Information) by using this toggle switch. You will still see some advertising, regardless of your selection. Because we do not track you across different devices, browsers and GEMG properties, your selection will take effect only on this browser, this device and this website.

Social Media Cookies

We also use cookies to personalize your experience on our websites, including by determining the most relevant content and advertisements to show you, and to monitor site traffic and performance, so that we may improve our websites and your experience. You may opt out of our use of such cookies (and the associated “sale” of your Personal Information) by using this toggle switch. You will still see some advertising, regardless of your selection. Because we do not track you across different devices, browsers and GEMG properties, your selection will take effect only on this browser, this device and this website.

Targeting Cookies

We also use cookies to personalize your experience on our websites, including by determining the most relevant content and advertisements to show you, and to monitor site traffic and performance, so that we may improve our websites and your experience. You may opt out of our use of such cookies (and the associated “sale” of your Personal Information) by using this toggle switch. You will still see some advertising, regardless of your selection. Because we do not track you across different devices, browsers and GEMG properties, your selection will take effect only on this browser, this device and this website.