06 Nov 2020

“CMMC certification is your Driver’s License on the Information Superhighway.”

-Katie Arrington

And if that’s the case (which it is), then the self-assessment required by the new DFARS Interim Rule is your permit… One that you must attain before December 1st, 2020 if you want to keep your car on the road- or your contract with the DoD.

Because Katie Arrington let everyone know, in a bit of a surprise announcement yesterday, that ALL federal contractors and subcontractors must upload a self-assessment onto the Defense Information Systems Agency-run database, the Supplier Performance Risk System (SPRS).

Every contractor who works with the DoD must have an assessment uploaded BY DECEMBER 1, 2020. Because, you know, 2020 just hasn’t thrown the US enough curve balls this year.

In other words, IF YOU DO NOT ENTER YOUR SELF-ASSESSMENT INTO SPERS YOU WILL NOT BE AWARDED ANY NEW CONTRACTS.

If you’re thinking to yourself, “That’s ok, my contract isn’t up for another x-number of years, so I can procrastinate a little bit longer!” then you are in for a rude awakening.  Not uploading your assessment puts you at risk for loss of contract.  If that happens, you not only lose that contract, but you could pay fines and penalties under the False Claims Act (FCA).

Under SPRS, contractors are required to fill out the self-assessment.  For each security control, you must have 2 pieces of evidence to back up your claim.  And for each control that you have not fulfilled, you must provide a Plan of Action & Milestone (POAM) stating how you are working towards correcting the issue, and when you expect it to be completed.

There are 110 security controls, from NIST 800-171. You have to assess yourself on each control, and give the DoD and expected date that you will be compliant on ALL 110 security controls.

It does not matter if you only need a CMMC Level 1.

This is about the DFARS Interim Rule that was enacted in October, 2020, and it applies to ALL federal contractors. 

THIS IS NOT A TEST.

The ONLY groups that are exempted from this DFARS Interim Rule are micro purchases and COTS.  They are using this Interim Rule to signify just how serious they are about cyber security, and per Katie Arrington this self-assessment requirement applies to ALL 300,000 federal DoD contractors.

Additionally, she noted that the number of CMMC ML3 contracts are going to be much higher than previously announced, which kind of makes sense because if everyone is expected to be NIST SP 800-171 compliant before the roll-out of CMMC, then all the contractors should be on track for ML3, given that it is essentially NIST SP 800-171, plus an additional 21 security controls. 

To reiterate: All contracts, including universities and non-profits, EVEN IF THEY DO NOT HANDLE CUI, must be self-assessed by/after Dec. 1.

Apparently the DoD’s sympathy has completely run out.  Contractors have been telling the federal government for over five years now that they were compliant with NIST SP 800-171.  The federal government has already paid its suppliers to become compliant, and they will not double pay.  They are willing to foot the cost it will take to tack on the new 21 controls for CMMC Maturity Level 3, but that’s it.

If you haven’t had a chance to look at the new assessment, you can complete a practice run with PTG’s new, FREE CMMC/NIST self-assessmentbut, fair warning, if you are not honest or make a mistake on the SPRS, you can now be held liable.  So what do you do?

We strongly urge all contractors to get in touch with a cyber security specialist by yesterday.  But seriously?  It needs to be post-haste.  There is a lot at stake here for you, including your contracts.  

Here at Petronella Technology Group, we will begin by helping you to complete the SPRS self-assessment, and then we will focus on completing the steps that make the biggest differences first, like secure data hosting.  

Secure data hosting is the FASTEST way to a solution. We can map the security controls at the data center for you, and you can upload your self-assessment and take a deep breath.

You can try to do this on your own, but putting your data at a secure data center is the fastest and most affordable way to get aligned.

The data center MUST be USA-based, per the CMMC model.

Our data center is getting CMMC ML3 certification, and has physical and cyber safety controls in place.

We also take an innovative, retainer approach to help our clients attain CMMC/NIST compliance.  It’s flexible, comprehensive, and tailored to fit YOUR company’s unique cyber security needs.

Many of our staff are getting accredited with the CMMC-AB as Registered Practitioners (RP), and Petronella Technology Group will be accredited as a Registered Practitioner Organization (RPO).

If you do not have a cyber security specialist in your corner, we are glad to help.  Call us at 919-422-2607, or reply to this email.

Regardless of which company you choose, you truly need to start this process as soon as humanly possible. Consultants can only help so many clients at once, and remember:

There are 300,000 of them.

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