Breaking the ‘Too Small to Fail’ Mindset: Modernizing Cybersecurity in the Defense Industrial Base with Sikich’s STARS CMMC Program

No organization is immune to cyber threats, regardless of size. This reality is particularly pressing for suppliers within the Defense Industrial Base (DIB). Many small and mid-sized companies operate under the assumption that their limited size makes them insignificant targets. As a result, DIB suppliers often deprioritize cybersecurity measures unless these are strictly enforced by government regulations or prime contractors. However, this mindset is increasingly risky as cyber threats evolve and regulatory expectations become more stringent.

The Risks of the “Too Small to Fail” Mentality

1. Supply Chain Vulnerabilities: Cyber attackers often exploit the weakest links in a supply chain. Small suppliers with less robust security measures become easy targets, potentially compromising the entire network, including larger contractors and sensitive government data.
2. Increasing Cyber Threats: Adversaries are aware that smaller organizations may lack comprehensive cybersecurity defenses. This makes them attractive entry points for initiating broader attacks that can ripple through the supply chain.
3. Regulatory and Contractual Demands: Frameworks like the Cybersecurity Maturity Model Certification (CMMC) are raising the bar for cybersecurity compliance. Failing to meet these standards can lead to contract losses, legal penalties, and reputational damage.

A Wake-Up Call: The Importance of Compliance

Recent legal actions underscore the consequences of neglecting cybersecurity obligations. Allegations against prominent institutions for failing to meet Department of Defense (DoD) cybersecurity requirements highlight that no organization is immune to scrutiny or enforcement actions. Notably, violations of cybersecurity compliance can result in lawsuits under the False Claims Act, which imposes liability on individuals and companies who defraud governmental programs. Noncompliance isn’t just a bureaucratic issue—it’s a legal risk that can lead to substantial financial penalties and damage to an organization’s reputation.

Understanding the False Claims Act

The False Claims Act is a federal law that allows the government to hold entities accountable if they knowingly submit false claims for government funds or fail to comply with contractual obligations, including cybersecurity requirements. Whistleblowers can also bring actions on behalf of the government, increasing the likelihood of enforcement. This adds an additional layer of risk for DIB suppliers who might overlook cybersecurity compliance, thinking they are too small to be noticed.

Prime Contractors Driving Compliance

While government regulations set the baseline, prime contractors are increasingly enforcing cybersecurity compliance throughout their supply chains. They conduct rigorous assessments to ensure suppliers adhere to required cybersecurity standards, especially when handling Controlled Unclassified Information (CUI). In addition to presenting regulatory risk, noncompliance can strain relationships with prime contractors, leading to lost business opportunities.

Modernizing Cybersecurity with Sikich’s STARS CMMC Program

For DIB suppliers facing these challenges, Sikich’s STARS (Scope, Training, Assessment, Remediation, Support) CMMC Program offers a comprehensive pathway to modernize cybersecurity practices and achieve compliance efficiently.

An Overview of the STARS CMMC Program Offerings

Through its STARS program, Sikich helps clients prepare to comply with CMMC requirements by benchmarking environments against the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 framework and determining the impacts that identified risks could pose.

Scope

Establishing a clear and manageable scope is the foundation of effective cybersecurity compliance. This phase involves minimizing the scope of compliance efforts to make the process more manageable and aligning cybersecurity initiatives with your overall business goals. It includes classifying CUI to determine necessary protection levels, visualizing your network and data flows to identify potential vulnerabilities, assessing your current technology stack for compliance readiness, and defining roles and responsibilities among stakeholders.

Training

Empowering your team with essential knowledge is crucial for maintaining robust cybersecurity practices. Sikich provides training that offers an overview of the Defense Federal Acquisition Regulation Supplement (DFARS) and dives deep into what CMMC compliance entails. Your team will learn best practices for managing sensitive information through CUI data classification and handling, as well as establishing protocols for effective documentation management.

Assessment

Determining your current compliance status and identifying areas for improvement are critical steps. This phase involves reviewing your controls against National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 standards and conducting interviews and documentation reviews to gather insights. Sikich validates the effectiveness of your existing cybersecurity measures, pinpoints areas that require improvement, and quantifies your compliance level by calculating your DoD basic self-assessment score.

Remediation

Developing actionable strategies to address identified compliance gaps is the focus here. Sikich helps design a strategic roadmap outlining a step-by-step plan to achieve compliance and prepare for the practical application of CMMC measures. You receive expert advice on how to close compliance gaps, create a Plan of Action and Milestones (POAM) to track progress, and develop a comprehensive System Security Plan (SSP) detailing your cybersecurity framework.

Support

Ensuring long-term compliance and adapting to evolving cybersecurity challenges is essential. Sikich offers continuous support to maintain compliance, assisting with integrating CMMC measures into daily operations. Regular advisory services address emerging risks through bi-weekly check-ins, and quarterly updates keep executive management informed of progress and challenges. Annual incident response training and testing prepare your team to respond effectively to incidents. Additionally, Sikich evaluates the compliance of your partners to secure the supply chain.

Benefits of the STARS CMMC Program

• Comprehensive Coverage: The program addresses every phase of the CMMC compliance life cycle, from initial scoping to ongoing support and management.
• Efficiency: Organizations can save significant time—over three months—in achieving and maintaining CMMC certification.
• Expert Guidance: Specialized advisory services and training ensure a thorough understanding and implementation of CMMC requirements.
• Continuous Improvement: Ongoing compliance support helps adapt to evolving requirements and maintain a strong security posture.

Enhancing Supply Chain Security with Due Diligence Services

Beyond internal modernization, securing the supply chain is crucial. Sikich’s supply chain due diligence services help identify and mitigate risks posed by suppliers and partners, ensuring a secure end-to-end supply chain. By fostering a culture of shared responsibility, organizations can work together to bolster overall security, benefiting all parties involved.

Transforming Compliance into Competitive Advantage

Investing in cybersecurity shouldn’t be seen merely as a cost but rather as a strategic business move.

• Strengthening Trust: Demonstrating robust cybersecurity practices builds credibility with prime contractors and the DoD, positioning your company as a reliable partner.
• Futureproofing: Staying ahead of regulatory changes ensures long-term viability and reduces the risk of sudden noncompliance issues.
• Avoiding Legal Risks: Proactive compliance minimizes the potential for legal actions under laws like the False Claims Act, safeguarding your organization from financial penalties and reputational harm.

Securing Your Future with Help from Sikich

The era of assuming you’re “too small to fail” in cybersecurity is over. Every supplier in the DIB has a role to play in safeguarding national security. By modernizing your cybersecurity practices with the help of Sikich’s STARS CMMC Program and supply chain due diligence services, you can meet compliance obligations, protect your business, and enhance your competitive position.

Don’t wait for a cyber incident or regulatory action to force your hand. Take proactive steps today to secure your operations and contribute to a safer, more resilient defense supply chain.

Contact Sikich to learn how we can support your journey toward cybersecurity excellence and compliance.