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There’s been allot of talk about CMMC over recent weeks and months and its impact on the Defence Industry Base (DIB). But CMMC only focused on the cybersecurity requirements of the Department of Defence.
To date the primary cyber regulation in the US are OMB – A130 and the Federal Information Security Modernization Act (FISMA). Regulation that has been in situ for 20 years requiring Federal Agencies to implement NIST SP 800-37R2 and whilst poorly managed, are enforceable. No doubt on the DoJs list regulations to be assessed against for compliance by Federal Agencies and the False Claims Act.
Trying to embed FISMA changes in the recent NDAA failed. However, the House Oversight and Reform Committee will discuss the draft legislation at a January 11‚Â hearing. With NASA, the FBI and GAO giving evidence at the hearing, its likely to be a good debate. FISMA has a much bigger impact on US Federal cyber regulation and C-SCRM than CMMC. Reviewing the deliverables for the FISMA legislation, it aims clearly to manage Federal Cyber, giving CISA appropriate Federal responsibility, strengthening OMB in cyber policy setting and codifying into law some of the May 2021 cyber EO.
If you want to understand FISMA and CMB A-130 and their impact on US Cyber regulation, read our paper (https://lnkd.in/dVdM3ZRq). We discuss their place in US cyber regulation and where CMMC fits in the regulatory landscape for the DoD, that is already implementing FISMA across its branches and procurement processes.
Ted Dziekanowski Brian McCarthy
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