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The United States government and its agencies are actively engaged in strengthening cybersecurity across various sectors. Key agencies and initiatives actively contribute to the nation’s cybersecurity resilience and foster public-private collaboration.
First, the National Security Agency (NSA) is at the forefront of efforts to prevent and eliminate cyber threats to U.S. national security systems. The agency promotes public-private partnerships, emphasising collaboration between government entities and private-sector organisations. NSA’s commitment extends to cybersecurity education, research initiatives, and career-building to foster a skilled workforce capable of addressing evolving cyber challenges.
Further, the Government Accountability Office (GAO) oversees and addresses information security risks across the U.S. government. Designating information security as a high-risk area, GAO has issued over 4,000 recommendations to federal agencies. These recommendations are strategically aimed at addressing various cybersecurity challenges and enhancing the overall resilience of government IT systems. A particular emphasis is placed on safeguarding personally identifiable information (PII) and mitigating the increasing risks associated with IT systems.
The Cybersecurity and Infrastructure Security Agency (CISA) also provides timely information on cyber trends and threats to individuals and organisations. CISA’s role extends to offering guidance on managing cyber risks, strengthening defences, and implementing preventive measures. The agency emphasises operational resilience, promoting cybersecurity best practices, and facilitating effective organisational management of external dependencies.
In supporting and enhancing cybersecurity strides, the U.S. Department of Defence (DoD) has released a proposed rule for a 60-day public comment period regarding updates to the Cybersecurity Maturity Model Certification (CMMC) programme. This initiative, aimed at ensuring the compliance of defence contractors and subcontractors with information protection requirements, particularly for federal contract information (FCI) and controlled unclassified information (CUI), has undergone revisions to address public concerns and streamline its requirements.
The proposed rule, available for comment on https://www.regulations.gov/docket/DOD-2023-OS-0063, introduces several critical changes to the CMMC programme. It is designed to address cybersecurity threats, including advanced persistent threats. The revised programme emphasises simplified compliance, prioritisation of Department of Defence (DoD) information protection, and enhanced collaboration between the DoD and industry to counter evolving cyber threats.
Among the notable revisions is that the CMMC programme now allows self-assessment for some requirements, offering a more streamlined compliance process. The focus on protecting DoD information has been prioritised, reinforcing the cooperation between the DoD and industry stakeholders. These updates align with the evolving cybersecurity landscape and aim to protect sensitive, unclassified information.
The CMMC programme introduces a tiered cybersecurity assessment approach, requiring evaluations at three levels. Basic safeguarding of FCI falls under CMMC Level 1, while the general protection of CUI necessitates assessment at CMMC Level 2. For a higher level of protection against advanced persistent threats, assessment at CMMC Level 3 is required. The proposed rule also introduces flexibility by allowing limited use of Plans of Action and Milestones and a government waiver request process.
To minimise industry costs, the DoD estimates that the overall programme costs will be reduced by permitting self-assessments for Level 1 and some Level 2 assessments. Furthermore, for Level 3 assessments, the DoD plans to engage assessors from the Defence Industrial Base Cybersecurity Assessment Centre (DIBCAC).
The CMMC programme’s alignment with National Institute of Standards and Technology (NIST) Special Publications 800-171 and 800-172 reinforces its adherence to established cybersecurity standards. As part of the comment period, the DoD also seeks feedback on eight CMMC guidance documents and additional information collections. The proposed rule and related documents are accessible at https://www.regulations.gov/docket/DOD-2023-OS-0096 and https://www.regulations.gov/docket/DOD-2023-OS-0097.
In the future, the DoD anticipates releasing a follow-on Defence Federal Acquisition Regulation Supplement (DFARS) rule for CMMC in 2024, with modifications to the existing 48 Code of Federal Regulations (CFR) Rule to align with the 32 CFR rule for CMMC. More information on the timing of the proposed DFARS rule can be found at https://www.reginfo.gov/public/do/eAgendaViewRule?pubId=202310&RIN=0750-AK81.
The CMMC programme, now fully defined within the 32 CFR regulatory process, shows a significant step forward in enhancing the cybersecurity posture of defence contractors and subcontractors, contributing to national security and resilience against cyber threats. Stakeholders and the public are encouraged to participate in the comment period to provide valuable insights and feedback on the proposed revisions.
