assessment

Cybersecurity Assessment Requirements for Federal Contractors

OVERVIEW


On September 29, 2020, the US Department of Defense (DoD) released the highly anticipated interim rule (“Interim Rule”) amending the Defense Federal Acquisition Regulation Supplement (DFARS) to implement the DoD Assessment Methodology and Cybersecurity Maturity Model Certification (CMMC). This new Interim Rule is effective November 30, 2020, in advance of promulgation of a future final rule. (DFARS Case 2019-D041; 85 FR 61505.)

IN DEPTH


NEW INTERIM COMPLIANCE OBLIGATION: COMPLIANCE CERTIFICATION UNDER NIST 800-171

The most significant change in the Interim Rule is the introduction of the new obligation for federal contractors to either self-certify or obtain a third-party assessment methodology to certify contractor compliance with cybersecurity requirements. (Click here for McDermott’s analysis.) Pursuant to the Interim Rule, beginning November 30, 2020, all contractors and subcontractors who accept contracts containing DFARS clause 252.204-7012 will need to comply with the National Institute of Standards and Technology (NIST) Assessment methodology for initial assessments, and update those assessments every three years.

This framework expands on existing requirements for federal contractors, as set forth by DFARS Clause 242.204-7012 and NIST Special Publication (SP) 800-171.

NIST SP 800-171 ASSESSMENT METHODOLOGY 

The NIST Assessment Methodology is designed to enable the federal government to assess its prime contractors and for the prime contractors to assess their subcontractors.

To qualify for new contract awards after the implementation date of the Interim Rule, contractors and subcontractors are required to have an assessment on record within the last three years (or more recently for certain contracts). (Interim Rule, 85 FR at 61506.)

The methodology provides for three types of assessments. (Assessment Methodology at 3-5.)

  • Basic. Basic Assessments are self-assessments performed by the contractor or the subcontractor against the 110 controls of NIST SP 800-171. A Basic Assessment provides only a minimum level of confidence in the resulting score because it

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The Block judge Darren Palmer issues a SAVAGE assessment on bathrooms

He’s known to speak his mind when critiquing the room reveals on The Block.

And judge Darren Palmer issued a savage assessment of two bathrooms from competing teams on Sunday night’s episode.

The interior design guru found the wall structure of Harry and Tash’s bathroom to be concerning, before admitting to ‘not liking anything’ about Daniel and Jade’s tiling. 

'It's a screw up!' The Block judge Darren Palmer (far left) issued a SAVAGE assessment of Harry and Tash's bathroom - before screwing his nose up at Daniel and Jade's tiling choices (pictured) on Sunday night's episode

‘It’s a screw up!’ The Block judge Darren Palmer (far left) issued a SAVAGE assessment of Harry and Tash’s bathroom – before screwing his nose up at Daniel and Jade’s tiling choices (pictured) on Sunday night’s episode 

Sunday’s episode saw the five teams choosing to style two rooms, one of which had to be a bathroom.  

Harry and Tash’s 1920’s bedroom started off on a positive note with all three judges, however their ensuite was a very different story.  

While Darren, Shaynna Blaze and Neale Whitaker were in awe of the colour palette and basin choice, Darren noticed a structural nightmare in builders having erected a straight frame crooked.

Positive: Harry and Tash's 1920's bedroom (pictured) started off on a positive note with all three judges, however their ensuite was a very different story

Positive: Harry and Tash’s 1920’s bedroom (pictured) started off on a positive note with all three judges, however their ensuite was a very different story 

Structural nightmare: However, with their bathroom, Darren noticed a structural nightmare in builders having erected a straight frame crooked

Structural nightmare: However, with their bathroom, Darren noticed a structural nightmare in builders having erected a straight frame crooked 

Design issues: What resulted was uneven tiling, meaning the entire wall beam would have to be taken out and reinstalled. Pictured: Harry and Tash

Design issues: What resulted was uneven tiling, meaning the entire wall beam would have to be taken out and reinstalled. Pictured: Harry and Tash

What resulted was uneven tiling, meaning the entire wall beam would have to be taken out and reinstalled.  

‘It’s a screw up! It’s sad that an error like that can undo all of this hard work, especially in this stressful environment,’ he said. 

Darren was also vocal when it came to assessing Daniel and Jade’s 1930’s bathroom. 

He was in awe of both kids’

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