The Defense Department's Cybersecurity Maturity Model Certification framework is ready for public comment.
A draft of the unified cybersecurity standard model Defense Department contractors must follow was just released, and a senior official wants vendors to "tear it up" in the comments.
Katie Arrington, DOD's chief information security officer for the Office of the Undersecretary of Defense for Acquisition and Sustainment, announced the release of the Cybersecurity Maturity Model Certification framework Sept. 4, during a panel discussion at the Intelligence and National Security Summit in National Harbor, Md.
Arrington said startups and small companies that DOD relies on for innovative solutions are the most vulnerable to cybersecurity threats in the supply chain.
Adversaries "aren't going after a Lockheed Martin, at the top prime level, they're going after the small business, that [Small Business Innovation Research awardee], that [other transaction authority firm] that's the most vulnerable," she said during the panel, adding that she hopes other federal agencies also adopt the model.
"We can't expect our companies in that paradigm to protect themselves against a nation state."
The framework's release follows watchdog reports that called out insecurity in the DOD supply chain because of contractors not following cyber standards.
DOD acquisition head, Ellen Lord, previewed the five-level certification model Aug. 26 in a news briefing, saying it "establishes security as the foundation to acquisition and combines the various cybersecurity standards into a unified standard."
The model is expected to be initially available in January 2020, with CMMC requirements becoming part of requests for information by summer of 2020, and included in requests for proposals later that fall, Lord said. Lord explained that an entire system doesn't have to achieve a single rating.
"Different parts can have lower and then higher amounts. So if you have a hardware portion that really doesn't have a cybersecurity requirement, there won't be much levied on that."
Arrington said DOD will release the model to an industry consortium in January 2020 to help certify the more than 300,000 companies in the DOD supply chain and ensure its scalability.
"Instead of looking at just one institution to place it with, we've asked industry to come together and create a consortium to take the model itself and then have the capability to train the trainers, to get the certifiers out there," Arrington told reporters following the panel.
The consortium would work with DOD, other federal agencies and academia to make sure the model doesn't become another checklist.
"That's what we do not want it to be. It needs to be robust as threats change and evolve; we need to be able to evolve with them in real time," she said.
Certifiers would come to every company -- not just in the defense industry base, but in its supply chain. That certification would be needed before even a startup could do business with the Defense Department.
Arrington also insisted that the needs and requirements of small businesses were top of mind when the framework was created and that companies would be able to build the cost of meeting the relevant cyber maturity standards into their rates when bidding on DOD contracts.
For example, CMMC Level 1, Arrington described as basic cyber hygiene and would run businesses around a few thousand dollars. Level 3 would be similar to NIST 800-171, which governs controlled unclassified information and Levels 4 and 5 are reserved for critical technologies and weapons systems.
"We built the model so it would be economically feasible for small businesses to achieve it. And then on the other side, when we say security is an allowable cost that we can actually put it in the technical requirements and that way they can say, 'Ok, we need to have CMMC Level 3, this is what [costs] would look like … and that rate is built in there."
Framework commenters can do so anonymously, without including company information, according to Arrington. She encouraged vendors at the event to "tear it up" and give DOD "honest input." That feedback will be considered as officials update the model for a November release, she said.