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The US Government Accountability Office (GAO) has issued its assessment of the CMMC program, required under the 2021 NDAA. It’s a synopsis of the history and current state of the CMMC program, highlighting concerns raised by industry and the challenges with the program such as the use of POAMS, hours required to comply and the impact of CMMC on small business.
Albeit it fails to identify a number of key omissions in the CMMC program namely the programs alignment with Federal Regulations such as FISMA, OMB A 130 or FEDRAMP. The international implications of the CMMC program are also profound, as the DoDs DIB is global, with a significant number of the estimated +200,000 mentioned DIB contractors within DoD Supply Chain based outside the US. Where reciprocity of cyber standards and compliance will be required to deliver the program. But is not addressed with any substance.
The GAO found that
1. DOD has not met initial implementation goals or sufficiently communicated key decisions to industry.
2. DOD has not established measures to monitor and ensure success of CMMC.
The GAO conclusion is to the point Confirming that the DoD implemented CMMC to increase cybersecurity posture of the DIB. The success of which relies on the DIB implementing cybersecurity practices and processes, and the DoD’s ability to effectively design and execute the CMMC process.
1. To meet these objectives clear communications and timely updates would help the DIB better prepare for certification.
2. Having plans to better assess the outputs of the CMMC pilot in the DoDs implementation gaols. Without which the DoD risks now know how successful the CMMC program is.
Ted Dziekanowski Jason Spezzano Brian McCarthy
#ransomware‚Â #fisma‚Â #ofac‚Â #theaugustagroup‚Â #theaugustaplan‚Â #cybersecurity‚Â #supplychainriskmanagement‚Â #cyberriskmanagement‚Â #compliance‚Â #regulatorycompliance‚Â #regulatoryoversight‚Â #esg‚Â #scrm‚Â #cscrm‚Â #fca‚Â #cybercompliance‚Â #cyberregulation‚Â #cybergovernance‚Â #falseclaimsact‚Â #aws‚Â #dhs‚Â #cisa‚Â #securitiesandexchangecommission‚Â #doj‚Â #falseclaimsact #cmmc
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