Adding a short-order cook to a crowded kitchen: OMB guidance creates a sense of urgency for cybersecurity in federal acquisitions

Aug 14

Phillip R. Seckman, Erin B. Sheppard and Michael J. McGuinn | Dentons

The Office of Management and Budget (OMB) on August 11, 2015 released proposed guidance, available here, that takes “major steps” towards – and likely accelerates – the implementation of cybersecurity requirements in federal acquisitions. OMB’s proposed guidance directs agencies, among other things, to impose security controls and reporting requirements on contractor information systems on which Controlled Unclassified Information (CUI) is present. OMB provides some fairly clear guidance in this area for contractors seeking to understand their future cybersecurity compliance obligations.

OMB indicates its guidance will be finalized in the fall of 2015. In light of the high profile breach of the Office of Personnel Management and the National Archives and Records Administration’s (NARA) related efforts to address the identification and safeguarding of CUI, contractors should expect OMB’s proposed guidance to be adopted in short order, with applicable cyber requirements appearing in government contracts shortly thereafter.

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