Survey: Large Contractors More Concerned Than Small Contractors About DOD’s Cybersecurity Certification Program

Concern the Defense Department’s plan to require contractors have their cybersecurity practices validated by an independent third party will be “overly burdensome” comes predominantly from larger, not smaller contractors, a new survey shows.

The results of a survey released Tuesday, sponsored by cybersecurity small businesses Apptega and Secure Strux, suggest a majority of smaller contractors share the expectation that the DOD’s Cybersecurity Maturity Model Certification will improve their ability to compete and don’t think it will be overly burdensome. A quarter of smaller organizations indicated that CMMC will create unnecessary burdens and costs, whereas 42% of larger organizations felt that way, according to the survey. 

The survey included participation from 130 prime contractors and subcontractors, which it categorized into smaller organizations (those with 100 employees or fewer) and larger organizations (those with more than 100 employees). The surveyors identified the participants by reaching out to a list of contractors published by the DOD and members of the Society of Industrial Security Professionals, which is largely comprised of DOD primes and subs, Apptega Vice President of Marketing Scot McLeod told Nextgov. 

The DOD launched the CMMC program after the department concluded the current practice of allowing contractors to self-attest their adherence to standards laid out by the National Institute of Standards and Technology is not reliable. If it were, then it would be less likely for the Chinese to have a plane that looks a lot like the F-35, Katie Arrington, the DOD’s lead official for the program, has suggested.

CMMC—a final rule for which should be ready in about one month, Arrington recently said—will apply to prime and subcontractors, an acknowledgement that threats to billions of dollars in intellectual property exist throughout the supply chain.

But implementation of the program has been controversial. Companies in the defense industrial base—large and small—have expressed uncertainty about the judgment of a group of private-sector individuals DOD has tasked with overseeing the creation and operation of a large new certification ecosystem. 

The group, which incorporated as a non-stock corporation in Maryland last year, according to its website, entered into a no-cost contract with the DOD as the CMMC Accreditation Body, or CMMC-AB. It has shed board members amid what was perceived as a pay-to-play scheme—now abandoned—and continues to raise conflict-of-interest concerns in the community. 

Large tech companies like those represented by the Information Technology Industry Council are especially concerned about what the adjudication process will look like if they disagree with an assessor’s decision, ITI’s Gordon Bitko told Nextgov last year, arguing there may be new or evolving approaches to handling security in the cloud that don’t fit the compliance mold.

And after the CMMC-AB announced members of an Industry Advisory Council last week, one contractor said small businesses were underrepresented and expressed concern the program would make it harder for those companies to compete against larger entities more able to implement the requirements. 

“Almost all CMMC-AB Industry Advisory Council members are from large corporations. There should be a higher and more diverse ratio of small companies to make sure they won’t be hit hardest by the impact of CMMC,” FedHIVE CEO Michael Cardaci told Nextgov. “A large business can distribute security costs more efficiently across a broader organization. For a smaller company, CMMC expenses are an allowable cost, but that added burden may make their prices non-competitive. They need to keep their overhead as low as possible for survival reasons.” 

The council includes security specialists from major companies like BAE Systems, Amazon Web Services and Rolls Royce but a spokesperson for the CMMC-AB reacting to the comment said three of the 12 council members are from small businesses. 

“It is important to note that the council has always been part [of] the AB plan since inception and we continue to view it as a key component in ensuring the CMMC standard and its associated implementation is based in reality including issues such as true costs of compliance (implementation, assessment and remediation), control effectiveness and applicability,” the spokesperson said. “It is also important to note relative to small business representation, this is the inaugural group not the final and only representation.”  

Countering Cardaci’s sentiment, small businesses represented by the National Defense Industry Association are looking forward to the CMMC improving competition and leveling the playing field with companies who may have misrepresented their cybersecurity standing, the NDIA’s Corbin Evans told Nextgov as the program was getting underway last year.  

The survey also covered other concerns voiced by FedHIVE’s Cardaci.

“Smaller contractors are making great strides, but they aren’t used to audits, so how can they meet the expectations of the auditor? They can’t do that without outside help. Meeting the requirements takes time, resources and a multitude of consultants to create and execute a plan. For a smaller business that doesn’t have the experience to avoid mistakes, it’s not a one-time process,” Cardaci said. “Mistakes are unavoidable, and it’s a costly learning curve. There is the ongoing cost of outside consultants to make sure the organization stays on track.”  

Forty-three percent of those surveyed said they plan on taking a do-it-yourself approach to meeting the requirements. The majority—55%—said they’ll take a hybrid approach, using some consulting assistance, and those results were consistent regardless of the size of the organization, the survey report said, noting one exception: 13% of participants said they would be entirely dependent on consultants and none of those included larger organizations.

The survey, which noted that 54% of the respondents served as both a prime contractor and a subcontractor in the defense industrial base, did not address another, less often heard, concern about competition that Cardaci raised.  

“Large businesses don’t always want to partner with small businesses due to several factors: loss of work share, profit margins, added management and increased liability,” he said. “Doubting the small partner’s ability to meet their security requirements, some invite or force their subs to use their secure repository. The smaller business risks excessive oversight—the big brother effect—or compromising its intellectual property to a contractor that might be a competitor.”