Your Supply Chain Security Deadline is Looming

If your organization has a contract with DoD and that contract contains the DFARS 252.239-7018 clause you have until 31 December of this year to implement the requirements specified in NIST Special Publication 800-161.

What is driving this emphasis on supply chain security? An increasing trend in cyber-attacks on DoD contractors via the supply chain. For the production of major end items, the size and complexity of supply chains presents a large attack surface. So, the manufacturers of such items are endeavoring to meet the new requirements. However, the DFARS clause is not limited to large manufacturers. So almost all contractors that produce any end item for delivery will be forced to comply. And that deadline is looming.

Even if your organization is not presently subject to the clause, if you plan to bid on DoD contracts, you need to become NIST 800-161 compliant because you will only have a limited time after contract award to demonstrate compliance to the contracting officer. And, if you plan to bid with a large prime, it will almost certainly consider your company’s 800-161 compliance a pre-requisite to a subcontract (or even a teaming) agreement.

BSC systems has produced 800-161 compliant system security plans (SSPs) and Plans of Actions and Milestones (POA&Ms). So, we can help you meet the DFARS requirement even if you do not satisfy all of the 800-161 controls. The process begins with a brief analysis of your current security posture versus the 800-161 controls to document “gaps”. This is followed by modifying or creating a 800-161 compliant SSP that formally documents your processes and shows how you satisfy each control. Some controls might not apply to your situation. For these, we document the justification for excluding them. For others, the risk might be so slight that the cost of implementing the control is not justified. In these cases, we will perform a brief risk assessment required to support your decision to accept the small risk.

The existence of unsatisfied controls that do apply and for which risk acceptance is not justifiable does not mean that you automatically fail to be 800-161 compliant. But you must document a plan to eventually meet these controls. To that end, we will assist in the development of a POA&M which establishes the action to close each gap, who is responsible, and when it is expected to be completed.

The objective evidence of satisfied controls, the justification of non-applicable controls and risk acceptance together with a reasonable POA&M constitute a strong case for compliance. If these conditions are met, then BSC will issue a Letter of Attestation expressing our independent opinion that your organization is in compliance.

At this point, you might think that achieving and maintaining compliance is expensive and disruptive to your business processes. However, our experience, proven approach, and refined tools promote cost efficiencies while minimizing disruption.

Finally, we have two goals: for your organization to be recognized as 800-161 compliant by your customers and for you to have genuinely improved the security posture of your supply chain.