Defense Contractor Certification Body Says Maintenance of Companies’ Cybersecurity Posture is Within its Role

The accreditation body overseeing the Defense Department’s cybersecurity certification for prospective contractors is also authorized to provide certified companies with cybersecurity services, according to members of the group’s board of directors. 

“A continuous monitoring capability could provide benefits to organizations in the defense supply chain by increasing their awareness of changes to their current cybersecurity posture,” Mark Berman, chairman of the board’s communications committee told Nextgov. “This initiative is a potential avenue where we can provide value add to enhance and maintain the security posture.”

Berman was responding to comments from observers who say an April 22 request for proposal the accreditation board issued for a “continuous monitoring solution” marks a departure from the training and certification functions the group is expected to perform. 

The Pentagon’s Cybersecurity Maturity Model Certification program is scheduled to take effect this fall following a change to defense federal acquisition regulations. Companies will have to attain third-party certification of their cybersecurity practices if they want to do business with the department. Defense contractors currently state whether they adhere to standards such as those outlined by the National Institute of Standards and Technology without any outside entity verifying their claims.

Katie Arrington, chief information security officer for the Defense Acquisition’s office, is heading up the program. She told Nextgov the department established the CMMC accreditation body due to the large scale of the initiative, which will involve in-person audits of about 300,000 prime and subcontractors. 

But new comments from the leader of the accreditation body are adding to the mystery and speculation surrounding the role of the accreditation board.

“My understanding is that the AB was originally formed to set the assessment and training standards as well as oversee the accreditation process,” Simone Petrella, CEO of the workforce development firm CyberVista, told Nextgov. “This RFP seems to expand that role to the active management of a vendor database—in addition to continuous monitoring of those vendors—on behalf of the DoD.”

Berman disputes this. He told Nextgov that characterizing the AB as a training or a monitoring organization “does not capture the full breadth of our mission which includes the development, maintenance, validation, protection of the CMMC Standard and using it to accredit entities, provide research, training, assessments, measurements, testing and more.” 

“We are tasked with implementing the CMMC model and supporting the efforts to improve the cybersecurity posture of the defense supply chain,” he said, noting there’s no plan for the continuous monitoring, if implemented, to affect a company's CMMC certification status. Certificates will be good for three years under the program, officials have said.    

Berman said the AB is interested in tools to “see what a hacker sees from the outside looking in” and that these would be used to aid the awareness of organizations that have undergone a CMMC assessment.

Johann Dettweiler, director of operations at the full-service cybersecurity, risk management and compliance firm TalaTek, defended the accreditation board seeking tools to provide cybersecurity services in addition to overseeing the process of verifying companies’ implementation of required security controls.

“We don’t believe this RFP is expanding beyond the original intent of the board and it is consistent with the goal of ensuring CMMC accredited vendors are maintaining their level of compliance in between reassessments,” Dettweiler told Nextgov. “It is definitely a logical step to ensure the security of the Defense Industrial Base (DIB) supply chain.”

Details of the plan and the accreditation board’s role might be clarified within the text of an undisclosed memorandum of understanding the group signed with the Defense Department. 

“We approach our mandate to implement CMMC in accordance with the terms of our MOU with DoD,” Ty Schieber, chairman of the board for the accreditation body, told Nextgov. But then he went further, asserting the right of the AB to pursue activities beyond the borders of the CMMC. 

“However,” he said, “the CMMC-AB is also a private and independent entity that is committed to looking to the future, and identifying and exploring tools, methods and concepts (some which are outside the direct and current scope of CMMC) that have potential to further enhance and reinforce the cybersecurity of the Defense Industrial Base and add value to stakeholders.”

That’s exactly the kind of statement Petrella argues has the ability to slow down the implementation of the program.   

“This RFP has raised additional questions about the level of power and influence the CMMC-AB has as an independent organization which [controls] a standard that will cost defense contractors a lot to implement,” she said. “Overall I believe this added complexity and the additional questions it raises could actually delay the implementation of the CMMC as it highlights aspects of the program, the assessment criteria, and the business model that don't appear to be entirely worked out.”

Arrington told Nextgov, while there is an effort to make the MOU public, public affairs officials and lawyers—busy with managing issues related to the COVID-19 crisis—need to sign off.

“We are working to release it, but like any relationship document between entities we need lawyers and PAO approvals. Our legal team has been focused on ensuring business continues in the current environment of covid as they are acquisition focused. [Keeping] them funded and working has been [the] highest priority,” she said, adding “transparency is important so we are working on it.”