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Thank you Ted Dziekanowski, the challenges with oversight and assurance of the DIB alone has identified allot of compliance challenges.
But it has to be said that there are plenty of alternatives that the GSA could adopt such as implementing FISMA and OMB A130 as it is required to do (https://lnkd.in/e9r-_vc5) and drive cybersecurity compliance using the RMF and CSF profiles as a contractual requirement to fit the risk that GSA deems is appropriate based upon the information type. The tools are already available.
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