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The pausing of Phase 2 is a response to several challenges that the United States Department of War faces.
1. The DoW cannot afford to impact the supply chain’s ability to deliver products and services.
2. The DoW has no real idea of how DFARS requirements have been met, or not, across the supply chain, and as such, no idea of how it will impact point 3. While having good intentions with regard to CMMC, it did not enforce compliance from the moment that DFARS 7012 left the gate in 2016. That has let the DIB move ahead and create weapon systems without embedding the cybersecurity required to protect digital and IP.
Back in 2021, we wrote the Augusta plan and presented it to the DoD. The plan was a proposal to design and enforce DFARS compliance using existing resources and phase in compliance based upon weapon system risk, with tax incentives and existing CPA/ IIA resources to qualify compliance, bolster DIBCAC, and enforce compliance. It also recommended passing supply chain compliance responsibility down to Primes. All of which follows, to a degree, industry best practice from other industry sectors and is proven to work to a lesser or greater degree.
A framework for DFARS compliance is not complex. However, compliance with DFARS is complex, and that’s where industry requires help (tax breaks).
@Thaddeus Dziekanowski maybe we should submit the Augusta Plan back to the DoW and their RFI.
Brian D. McCarthy
@Parava Security Solutions
#dfars #cmmc #dib
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