On February 12, 2013, President Obama issued Executive Order 13636, which directed federal agencies to undertake a broad range of tasks aimed at enhancing the security and resilience of the nation’s critical infrastructure.  One task directed the National Institute of Standards and Technology (“NIST”) to establish a technology-neutral, voluntary, risk-based cybersecurity framework. A year later, on February 12, 2014, NIST released its Framework for Improving Critical Infrastructure Cybersecurity, Version 1.0.  The Framework includes standards and processes that are intended to align policy, business, and technological approaches to addressing cybersecurity risks.

Since issuing the Framework, NIST has focused on raising awareness of the Framework and how it can be used to manage cyber risks.  Now, NIST is seeking a better understanding of how companies and organizations are using the Framework and what aspects of the Framework have been “helpful or challenging.”  Consequently, NIST has issued an RFI seeking information in three areas: (1) current awareness of the Framework; (2) early implementation experiences for those organizations utilizing the Framework; and (3) input on the utility of the Roadmap included within the Framework.  A series of suggested questions is included within each category; however, respondents are free to comment beyond the questions.

NIST intends to use the responses it receives to:

  • inform its approach to possible tools and resources that could be used to assist organizations in the efficient and effective use of the Framework;
  • inform subsequent versions of the Framework;
  • develop the agenda for an October 2014 workshop on the Framework; and
  • shape the Department of Homeland Security Critical Infrastructure Cyber Community C³ Voluntary Program.

Comments to NIST are due October 10, 2014.

 

 

Tags: Comments, Cyber Risk, Cybersecurity, Cybersecurity Framework, EO 13636, Framework, National Institute of Standards and Technology, NIST, Request for Information, RFI
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Photo of Susan B. Cassidy Susan B. Cassidy

Susan is co-chair of the firm’s Aerospace and Defense Industry Group and is a partner in the firm’s Government Contracts and Cybersecurity Practice Groups. She previously served as in-house counsel for two major defense contractors and advises a broad range of government contractors…

Susan is co-chair of the firm’s Aerospace and Defense Industry Group and is a partner in the firm’s Government Contracts and Cybersecurity Practice Groups. She previously served as in-house counsel for two major defense contractors and advises a broad range of government contractors on compliance with FAR and DFARS requirements, with a special expertise in supply chain and cybersecurity requirements. She has an active investigations practice and advises contractors when faced with cyber incidents involving government information. Susan relies on her expertise and experience with the Defense Department and the Intelligence Community to help her clients navigate the complex regulatory intersection of cybersecurity, national security, and government contracts. She is Chambers rated in both Government Contracts and Government Contracts Cybersecurity. In 2023, Chambers USA quoted sources stating that “Susan’s in-house experience coupled with her deep understanding of the regulatory requirements is the perfect balance to navigate legal and commercial matters.”

Her clients range from new entrants into the federal procurement market to well established defense contractors and she provides compliance advices across a broad spectrum of procurement issues. Susan consistently remains at the forefront of legislative and regulatory changes in the procurement area, and in 2018, the National Law Review selected her as a “Go-to Thought Leader” on the topic of Cybersecurity for Government Contractors.

In her work with global, national, and start-up contractors, Susan advises companies on all aspects of government supply chain issues including:

  • Government cybersecurity requirements, including the Cybersecurity Maturity Model Certification (CMMC), DFARS 7012, and NIST SP 800-171 requirements,
  • Evolving sourcing issues such as Section 889, counterfeit part requirements, Section 5949 and limitations on sourcing from China
  • Federal Acquisition Security Council (FASC) regulations and product exclusions,
  • Controlled unclassified information (CUI) obligations, and
  • M&A government cybersecurity due diligence.

Susan has an active internal investigations practice that assists clients when allegations of non-compliance arise with procurement requirements, such as in the following areas:

  • Procurement fraud and FAR mandatory disclosure requirements,
  • Cyber incidents and data spills involving sensitive government information,
  • Allegations of violations of national security requirements, and
  • Compliance with MIL-SPEC requirements, the Qualified Products List, and other sourcing obligations.

In addition to her counseling and investigatory practice, Susan has considerable litigation experience and has represented clients in bid protests, prime-subcontractor disputes, Administrative Procedure Act cases, and product liability litigation before federal courts, state courts, and administrative agencies.

Susan is a former Public Contract Law Procurement Division Co-Chair, former Co-Chair and current Vice-Chair of the ABA PCL Cybersecurity, Privacy and Emerging Technology Committee.

Prior to joining Covington, Susan served as in-house senior counsel at Northrop Grumman Corporation and Motorola Incorporated.

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