Pentagon’s Cybersecurity Certification Program Still Working on Third-Party Auditors

The accreditation body implementing the Defense Department’s Cybersecurity Maturity Model Certification is rethinking its plan for answering industry questions after a premature end to a webinar Monday.

CMMC Accreditation Body Board Chairman Ty Scheiber apologized in an email citing capacity issues but also noted the forum would be restructured.

“To all who registered for and attended this important event….we apologize for any inconvenience associated with the technical issues that prevented us from providing you with the content that we prepared for today’s National Conversation with CMMC-AB,” he wrote. “The substantial interest and enthusiasm in CMMC exceeded our expectations, and although we carefully planned for this event the bandwidth we arranged for proved insufficient. We are restructuring our approach to provide the intended forum and will have details on our revised plan out to you shortly.”

The CMMC program would require contractors to certify their cybersecurity through audits conducted by independent third parties. The current policy allows them to pledge their compliance with practices detailed in documents such as National Institute of Standards and Technology’s Special Publication 800-171. 

Participants in Monday’s webinar could see panelists—DOD acquisitions office Chief Information Security Officer Katie Arrington in addition to the AB’s board of directors—but not hear them, except, perhaps, by using a phone line, as Nextgov did.

Board members did manage to field some of the questions they’d been collecting in preparation over the past couple of weeks before surrendering to the webinar woes.

Some answers were simple. For example, CMMC would not require contractors to employ a dedicated CISO or to conduct penetration testing for vulnerabilities on a regular schedule, although board members noted the latter was probably a good idea. Board members also noted that while classified information is outside the scope of the CMMC, prospective assessors would have to pass some manner of background check.

Officials said other questions, such as those about costs, criteria, vetting and the registration processes for those prospective auditors, referred to as CMMC Third-Party Assessment Organizations or C3PAOs, are still being worked out.    

James Goepel, chair of the CMMC-AB’s finance committee, did tell participants C3PAOs would eventually register through the CMMCAB.org website alone. Defense officials recently chided some entities for making spurious claims about certification. 

The CMMC-AB is working to deliver "an understanding of how ultimately you're going to be matched up with these organizations seeking certification," he said.

Some participants’ questions reflected a lack of familiarity with the intentions of the program—or perhaps wishful thinking—and prompted standards committee co-chair John Weiler to type in the Q&A function: Self-verification "did not work. We are implementing a no-trust, must verify approach.”

That is something Arrington has often had to reiterate when she discusses the program publicly.  

One question Arrington and the department will have to address is about how CMMC will apply to entities wanting to do business with the department while based outside the U.S.

Similar issues related to the scope of the program were also raised by a coalition of leading tech industry groups in a recent letter to Arrington.

“It is unclear whether certification would be required in cases in which a subcontractor handles no [controlled unclassified information] or is a non-U.S. company; for instance, computer chips are usually sourced offshore and acquired as commercial-off-the-shelf hardware products,” the groups wrote. “It also remains unclear whether the certification requirements will apply to non-procurement contracts such as cooperative agreements and grants.”

Weiler told webinar participants he’s been working on “some alliances and partnership agreements” for aligning the program’s outreach with international components of groups like AFCEA, which specifically asked about whether the AB’s website would facilitate its Asia chapter.

“Absolutely, it is in our intention to reach out to all communities of practice that have a strong affiliation to our national security agenda,” he said. “We'll be coming out with some guidance on how we'll be executing on that once the board approves the approach that we're working on.”