S6E2 - Jacob Horne - 171, CMMC and the Federal Compliance Landscape
- For folks not tracking, let's level set a bit, what exactly is NIST 800-171 and CMMC, and what is the succinct background on the evolution of the two?- Are there notable events that led the DoD to pursue CMMC, building on the history of 171?- Obviously the introduction of the 3PAO aspect brings more rigor than previously existed with self-assessments. Many in industry have bemoaned the burden, cost and complexity of the new program and the impact it will have on industry (myself included). What are your thoughts on the potential to impact the DoD supplier base and lead to further consolidation?- Many DIB suppliers are of course SMB's who rely on CSP's and MSP's to meet these requirements, or conduct their daily operations, leveraging various external parties. How does CMMC handle entities like CSP's and MSPs?- There was recently a memo from the DoD CIO clarifying some language around "FedRAMP equivalency" for DFARS 7012. First off, what is 7012, how does it tie to 171 and CMMC and what did the DoD CIO memo essentially say?- Most SMB's in the DIB lack internal cyber expertise and resources, and of course this has led to a booming industry of 171/CMMC consultants and 3PAO's. What are your thoughts on that growing ecosystem and how do SMB's ensure they're working with the right advisors and assessors?- What are some of the details on the timelines and rollout of the finalized CMMC rule? When and how should folks be preparing?- Many of course are quick to claim "compliance isn't security" when discussing stuff like 171 and CMMC. What's your initial reaction to those claims, and how do we help folks understand that industry will not just voluntarily spend and focus on security requirements without being required to do so?- CMMC of course has a ConMon aspect, right now that is does via annual self-assessments/reporting as I understand it. What do you think CMMC gets right on this front, and what could be done better?