Best practices for agency implementation of CDM
- By Benjamin Liberty
- May 18, 2020
Over the last decade we have witnessed a shift in the cybersecurity landscape in the United States, which now includes cyberterrorism, ransomware, phishing along with threats to elections, critical infrastructure, the economy, and now, of course, our health with the coronavirus pandemic. However, these threats are not mutually exclusive, and the cascading impact of these interrelated threats is certainly far greater than the sum of its parts.
To make matters worse, the pandemic is creating a surge in cyberattacks, which require additional spending to support agency responses, further straining public- and private-sector organizations – even as the U.S. was already making significant investments into election security before COVID-19.
We must be more proactive, efficient and smarter in building cyber defenses to address these threats.
While the Department of Homeland Security's Continuous Diagnostics and Mitigation program can help, CISA alone cannot make each agency's implementation of CDM successful. There are many other stakeholders that play a role including the agency resources, DEFEND integrators, and the insights generated by the upgraded dashboard. With the recent award of the CDM DEFEND F contract, there will be many more agencies further engaged with CDM. Therefore, this article focuses on best practices agencies can use to optimize their implementations of CDM tools, policies and processes:
Take a centralized, enterprise approach: While many departments comprise a federated set of component agencies -- many of which receive their own congressional appropriations -- this does not mean an agency's CDM implementation should follow suit. It is no surprise that the overarching practices that the Government Accountability Office outlined for the Federal Information Technology Acquisition Reform Act are also directly applicable to CDM: "Obtain support from senior leadership, treat implementation of [CDM] as a program, establish [CDM] performance measures for component agencies, and appoint an executive accountable for [CDM] implementation in each component agency." Centralization results in more cost efficiencies, greater accountability and faster delivery of services through the use of repeatable processes.
Get buy-in from component agencies: The legislation that helps codify agency participation in CDM has not yet passed, and OMB M-20-04 mandates (e.g. those requiring agencies to procure cybersecurity capabilities through existing CDM acquisition vehicles and submit separate, CDM-specific line items in their FY 2021 budget documents) are difficult to enforce. So, while it is easy to say "centralize CDM," how are agencies supposed to do it?
Carrots, not sticks: We understand that the "what's in it for me" question is foundational because it drives decision-making. Agencies can look no further than WIIFM when identifying opportunities where CDM can make the lives of their component agencies easier. For example, many components are responsible for procuring cybersecurity tools on their own. While their already overburdened acquisition offices often require large amounts of paperwork, there are solutions. First, the CDM-based acquisition process only requires the completion of a two-page request form and an independent government cost estimate spreadsheet. This means faster procurements with less work for components (particularly, if the forms can be pre-populated, saving even more time). Secondly, by establishing a centralized CDM implementation at the enterprise level, many component agency's existing Plan of Actions & Milestones documents can be redirected to the department. They love that.
Creative problem solving: CDM creates certain challenges for many agencies because its capabilities are so broad and all-encompassing. However, many of these "challenges" are simply thinly veiled opportunities. This was the case for one agency that was struggling to get full buy-in on CDM. The CDM program manager identified an opportunity in which CDM capabilities could meet certain internal (non-CDM) data call needs using the CDM-based hardware asset management capability. Once leadership saw how quickly CDM addressed this challenge, they changed their attitude on CDM's value and have since invested more time, energy and support into the program, which is further helping them solve other (non-CDM) problems.
Leverage the DHS CISA partnership: While CISA is ultimately responsible for the program and its requirements as the CDM contracts holder for services delivered to agencies, this is not a directorship. Kevin Cox, the DHS CDM program manager at CISA, set up the CDM Customer Advisory Forum shortly after he took the lead at CDM. The CAF is intended to give a voice to departments and agencies and provide a collaboration mechanism to share challenges and lessons learned in order to influence the direction of the program to better serve agencies.
Secondly, Cox and his team have a lot on their plate managing a multi-billion-dollar cybersecurity program across the civilian agencies, so they encourage department and agency stakeholders to help fill in the gaps in other mutually beneficial ways. For example, the CDM PMO regularly offers agencies opportunities to pilot emerging capabilities, funding new capabilities that save money. Meanwhile, DHS leverages the lessons learned from the partnering pilot agency to better serve the rest of the government.
This arrangement is made possible under CDM DEFEND, which creates far more flexibility and agility for meeting agency cybersecurity needs than its predecessor, the Task Order 2 contract series. DHS understands that each agency has its own unique mission and cybersecurity strengths. Consequently, each agency has an opportunity to partner with DHS to couple agency mission with CDM capabilities. This results in improving, not just the agency's cybersecurity, but the cybersecurity capabilities of the federal government and the citizens it serves.
Benjamin Liberty is the founder of ideallogix and a former CDM program manager for the Department of the Interior.