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U.S. General Services Administration
Presentation to: ITIC
Improving Cybersecurity
through Acquisition
Emile Monette
Senior Advisor for Cybersecurity
GSA Office of Mission Assurance
[email protected]
January 29, 2014
Background: We Have a Problem
 When the government purchases products or services with inadequate
in-built “cybersecurity,” the risks created persist throughout the
lifespan of the item purchased. The lasting effect of inadequate
cybersecurity in acquired items is part of what makes acquisition
reform so important to achieving cybersecurity and resiliency.
 Currently, government and contractors use varied and nonstandard
practices, which make it difficult to consistently manage and measure
acquisition cyber risks across different organizations.
 Meanwhile, due to the growing sophistication and complexity of ICT
and the global ICT supply chains, federal agency information systems
are increasingly at risk of compromise, and agencies need guidance to
help manage ICT supply chain risks
Executive Order 13636
 On February 12, 2013, the President issued Executive Order (EO) 13636 directing Federal
agencies to provide stronger protections for cyber-based systems that are critical to our
national and economic security. Section 8(e) of the EO required GSA and DoD to:
“… make recommendations to the President, … on the feasibility, security benefits,
and relative merits of incorporating security standards into acquisition planning and
contract administration”
 GSA and DoD recommended six acquisition reforms:
I. Institute Baseline Cybersecurity Requirements as a Condition of Contract Award for
Appropriate Acquisitions
II. Address Cybersecurity in Relevant Training
III. Develop Common Cybersecurity Definitions for Federal Acquisitions
IV. Institute a Federal Acquisition Cyber Risk Management Strategy
V. Include a Requirement to Purchase from Original Equipment Manufacturers, Their
Authorized Resellers, or Other “Trusted” Sources, Whenever Available, in
Appropriate Acquisitions
VI. Increase Government Accountability for Cyber Risk Management
White House Response to 8(e) Recommendations
“DoD and GSA did an outstanding job engaging with public and private sector
stakeholders to craft the report and provided realistic recommendations that
will improve the security and resilience of the nation when implemented.
Moving forward, we highlight that:
– We view the core recommendation to be the focus on incorporating cyber risk
management into enterprise acquisition risk management, built on “cybersecurity
hygiene” baseline requirements for all IT contracts.
– DoD and GSA must now move quickly to provide an implementation plan that
includes milestones and specific actions to ensure integration with the various
related activities like supply chain threat assessments and anti-counterfeiting.
– DoD and GSA should ensure the highest level of senior leadership endorsement,
accountability, and sustained commitment to implementing the recommendations
through near and long term action. This should be communicated clearly to the
Federal workforce, government contractors, and the oversight and legislative
8(e) Recommendations & Potential Impact
Potential Impact
FAR 4.17 – Basic Safeguarding of Contractor Information (not
in FAR yet) could be updated to add definitions and solicitation
provisions/contract clauses.
Basic cybersecurity hygiene is broadly accepted across the
FAR Part 7 – Acquisition Planning, could be updated to more
government and the private sector as a way to reduce a
explicitly require the government to consider cybersecurity
significant percentage of cyber risks. For acquisitions that
requirements in the technical requirements of contracts.
present cyber risks, the government should only do
FAR Par 12 – Acquisition of Commercial Items could be
business with organizations that meet such baseline
updated to require solicitation provisions/contract clauses to
requirements in both their own operations and in the
apply to commercial items.
products and services they deliver. The baseline should be FAR 52 – Development of solicitation provision(s) and contract
expressed in the technical requirements for the acquisition
clause(s) for cybersecurity.
and should include performance measures to ensure the
FAR4.4 – Safeguarding Classified Information Within Industry
baseline is maintained and risks are identified.
should also be reviewed for updates related to cybersecurity.
FAR Part 39.102 Management of Risk – could be updated to
address certain types of cyber risk associated with IT
I. Institute Baseline Cybersecurity Requirements as a
Condition of Contract Award for Appropriate Acquisitions –
8(e) Recommendations & Potential Impact (cont’d)
II. Address Cybersecurity in Relevant Training –
As with any change to practice or policy, there is a concurrent
need to train the relevant workforces to adapt to the changes.
Incorporate acquisition cybersecurity into required
training curricula for appropriate workforces. Require
organizations that do business with the government to receive
training about the acquisition cybersecurity requirements of
the organization’s government contracts.
Potential Impact
FAR 52 – clauses might be developed to require specific
training for certain types of contracts where cyber risks are
Note: OFPP, GSA (FAI), DHS (HSAI), and DoD (DAU) are
meeting Jan 16th to start implementing this recommendation.
Ms. Joanie Newhart, Associate Administrator for Acquisition
Workforce Programs in the Office of Federal Procurement Policy,
has agreed to convene/charter this informal group with the purpose
that the initial training be developed and provided to Acquisition
Workforce personnel government-wide.
The meeting will gather stakeholder representatives from the
relevant acquisition training communities to begin development of
(1) course curriculum, (2) training policy, and (3) project plans.
8(e) Recommendations & Potential Impact (cont’d)
III. Develop Common Cybersecurity Definitions for Federal
Acquisitions –
Unclear and inconsistently defined terms lead, at best, to
suboptimal outcomes for both efficiency and cybersecurity.
Increasing the clarity of key cybersecurity terms in federal
acquisitions will increase efficiency and effectiveness for both
the government and the private sector. Key terms should be
defined in the Federal Acquisition Regulation.
Potential Impact
One option is to consider efforts already underway dealing
with higher-level quality standards and detection and
avoidance of counterfeit electronic parts. (FAR Case 2012-032
Higher-Level Contract Quality Requirements). This case
revises FAR 46.202-4 to add new higher-level quality
standards developed by industry for counterfeit goods. Using
this case as an example, FAR 46 – Quality Assurance, could
also be revised to include industry standards for cybersecurity
in commercial items.
FAR 39 – Acquisition of Information Technology could be
updated to consider applicable definitions.
FAR 2 – Definitions of Words and Terms, is probably the most
obvious place to promulgate new acquisition definitions.
8(e) Recommendations & Potential Impact (cont’d)
IV. Institute a Federal Acquisition Cyber Risk Management
Strategy –
From a government-wide cybersecurity perspective, identify
a hierarchy of cyber risk criticality for
acquisitions. To maximize consistency in application of
procurement rules, develop and use “overlays” for similar
types of acquisition, starting with the types of acquisitions
that present the greatest cyber risk. An overlay is a fully
specified set of security requirements and supplemental
guidance that provide the ability to appropriately tailor security
requirements for specific technologies or product groups,
circumstances and conditions, and/or operational
Potential Impact
The FAR could be updated to provide standardized source
selection criteria, weighting for those criteria, and contract
performance measures for procurements that present high
levels of cyber risk.
Note: OMA/FAS/OGP are engaged in market research and
needs assessment with DHS , DoD OCIO, DIA, DISA and
NIST to develop a supply chain risk management function to
complement the processes used for National Security
8(e) Recommendations & Potential Impact (cont’d)
V. Include a Requirement to Purchase from Original
Equipment Manufacturers, Their Authorized Resellers, or
Other Trusted Sources, in Appropriate Acquisitions –
Potential Impact
The FAR could be updated to require consideration of cyber
risk when determining the type of acquisition method (best
value vs. LPTA) used.
The FAR could be updated to require purchases from a
In certain circumstances, the risk of receiving inauthentic or
reseller, distributor, wholesaler or broker that is a trusted
otherwise nonconforming items is best mitigated by obtaining supplier with the original equipment manufacturer (OEM) or
required items only from OEMs, their authorized resellers, obtain assurances that the supplier can guarantee the security
or other trusted sources. The cyber risk threshold for
and integrity of the item being purchased. Potential conflicts
application of this limitation of sources should be consistent
with competition rules would have to be addressed.
across the Federal government.
VI. Increase Government Accountability for Cyber Risk
Management –
Identify and modify government acquisition practices that
contribute to cyber risk. Integrate security standards into
acquisition planning and contract administration. Incorporate
cyber risk into enterprise risk management and ensure
key decision makers are accountable for managing risks
of cybersecurity shortfalls in a fielded solution.
The FAR could be updated to ensure contract administration
matters relevant to cybersecurity are considered (i.e., past
performance, Federal Awardee Performance and Integrity
Information Systems (FAPIIS), debarment/suspension, etc.)
Presidential Policy Directive 21
Designates GSA as Co-Sector Specific Agency (SSA) for Government
Facilities Sector with DHS
Requires GSA, in consultation with DoD and DHS, to:
– “[P]rovide or support government-wide contracts for critical infrastructure
systems and ensure that such contracts include audit rights for security of
critical infrastructure.”
– 1st next step - define which contracts are “for critical infrastructure
systems,” and what the “audit rights for security” specifically encompass
• Critical infrastructure systems could be any that support government essential
functions, agency mission essential functions, or any functions on the DHS list
of Critical Infrastructure at Greatest Risk of Cyber Attack
• GSAM 552.239-71 provides a good starting point for defining the limits of the
audit rights
Open Questions
Establish a govt-wide program/function at GSA?
– Is there an appetite in the community for starting to address the acquisition cyber
risk in “non-covered” acquisitions?
– Is it possible to define in a specific way which types of buys present cyber risks (i.e.,
– How do we prioritize? Is FIPS-199 high or moderate a good starting point?
– What about non-covered, non-IT acquisitions (i.e., those that would not get a FIPS
rating)? No doubt, many present at least the possibility of cyber risk, how do/should
those risks be assessed? Ranked by mission criticality? and if yes, how is that
Business Case needs:
– An articulation of need for "commercial" (OSINT-based) SCRM from customers, and
– A general scope of what types of acquisitions the need applies to (e.g., a list of
PSCs, NAICS, FIPS ratings, ???).

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