What is Cuick Trac?
Cuick Trac, at its core, is a private hosted and pre-configured enclave that satisfies the technical requirements of NIST SP 800-171.
Because Cuick Trac is a virtual enclave, it allows for better control of CUI data flow, as CUI never touches the OSC’s (organization seeking certification) network or device. Cuick Trac’s technology and compliance advisory support guides you towards compliance with DFARS 252.205-7012, NIST 800-171, and the emerging CMMC 2.0 requirements.
Cuick Trac was purpose built for businesses who lack the bandwidth and resources to implement and manage the required controls themselves. The Defense Industrial Base (DIB) needs solutions that are affordable, practical and secure by default, that can also be implemented in a shorter amount of time.
How does Cuick Trac help me?
The purpose of Cuick Trac is to help businesses who currently work with, or want to do work with, the Department of Defense (DoD) and federal government to securely handle Federal Contract Information (FCI) and Controlled Unclassified Information (CUI).
Cuick Trac takes responsibility for 78% of the assessment objectives within NIST 800-171A/CMMC Level 2 assessment guides, and Cuick Trac’s compliance advisors guide our customers through the remaining 22%. This significantly decreases your Plan of Action and Milestones (POA&M) and internal responsibility burden for our customers.
Does Cuick Trac replace my IT provider?
No. Our goal, always, is to work with as much of your current business processes that are already in place, including your current MSP. Disruption to your business is detrimental, thus a collaborative approach will be key in regard to how CUI data is collected, stored and accessed.
Cuick Trac essentially becomes the OSC’s CUI Managed Service Provider (MSP).
Is Cuick Trac another tool or software application?
No, Cuick Trac is not a software.
It’s a CUI enclave solution, hosted in a private, fully managed virtual enclave/controlled environment on U.S. soil, managed only by U.S. persons. Cuick Trac’s enclave has everything from a SIEM, encryption at rest, encryption in transit, patch management, secure back-ups, and more. Unlike a single application or tool, Cuick Trac meets ALL technical controls for NIST 800-171 and CMMC Level 2 (per CMMC 2.0).
What is Controlled Unclassified Information (CUI)?
Controlled Unclassified Information (CUI) refers to unclassified information that is to be protected from public disclosure. The CUI designation replaces “sensitive but unclassified” and other similar control markings. To learn more, download our ebook or see examples of CUI.
What is DFARS, NIST 800-171 and CMMC?
The DFARS 252.204-7012 clause says that if you handle Controlled Unclassified Information, you should have implemented NIST SP 800-171 no later than Dec 31, 2017. Since this deadline has passed and many defense organizations don’t meet this current requirement, the DoD developed CMMC. Organizations within the DoD supply chain need a risk-based approach to become compliant, and more importantly, secure their environments where CUI is processed, stored and transmitted.
NIST SP 800-171 is the National Institute of Standards & Technology (NIST) special publication providing 110 recommended security controls for protecting the confidentiality of CUI (Controlled Unclassified Information – a subset of CDI).
The Cybersecurity Maturity Model Certification (CMMC) is the standard the Department of Defense (DoD) is using to verify the members of the Defense Industrial Base (DIB) fully meet their cybersecurity requirements, prior to contract awards.
What is an SPRS score, and how do I get one?
In September, 2020, the DoD released a new interim rule, approved by the Office of Management and Budget (OMB), that requires all contractors subject to DFARS 252.204-7012 within the DoD supply chain, to have an accurate assessment on record, prior to award. The interim rule becomes a bridge between the self-assessment process of DFARS 252.204-7012/NIST SP 800-171, and the verification/certification process of CMMC. The DFARS Interim Rule helps enforce full compliance and the importance it provides to our national security.
The results of Assessments are documented in the Supplier Performance Risk System (SPRS) at https://www.sprs.csd.disa.mil/ to provide DoD Components with visibility into the scores of Assessments already completed; and verify that an offeror has a current (i.e., not more than three years old, unless a lesser time is specified in the solicitation) Assessment, at any level, on record prior to contract award.
The score submitted to SPRS is based on the NIST SP 800-171 DoD Assessment Methodology. If an organization is not able to prove requirements are met, with objective evidence, should not receive credit for that specific requirement. Cuick trac™ provides a significant increase of an SPRS score, making the path to 110 much more manageable.
Do I need a System Security Plan (SSP) and Plan of Actions and Milestones (POA&M) Before Utilizing Cuick Trac?
No. If an organization knows it isn’t compliant, they need to focus on solutions that best fit their business. A Cuick Trac subject matter expert (SME) will help an organization identify CUI data flow, scope and boundary for free. Once the identified users in scope are using the Cuick Trac enclave, the customer and Cuick Trac conduct an assessment of the NIST SP 800-171 controls (and CMMC practices and processes using the latest version of the CMMC Assessment Guides) and create/update the SSP. All remaining gaps become the POA&M (physical and administrative controls outside of the Cuick Trac enclave, if applicable) and shortens the path to completing your plan of full implementation and on-going/continuous compliance.
What happens if I’m not compliant with DFARS/NIST 800-171?
Besides the risk of failing a future CMMC certification, organizations who fail to prove that they have NIST SP 800-171 fully implemented and continuously monitored, will lose the opportunity to be awarded new DoD contract awards, and potentially face fines or loss of contract.
Who mandates these requirements?
The Federal government. By law, businesses handling Controlled Unclassified Information (CUI) are required to become, stay and prove DFARS/NIST 800-171 compliance in order to be awarded and keep contracts. Also, primary (prime) contractors have the right to ask for proof of compliance through SSP and POA&M audits and reviews, before selecting sub-contractors.
We don’t have a SIEM or any way to monitor events/incidents/breaches, does Cuick Trac do that?
Yes. Under the DFARS clause, contractors must report cyber incidents within 72 hours of them happening. That’s a difficult thing to accomplish if your business doesn’t have the personnel or resources to always be monitoring your security information and event management solution (SIEM). Cuick Trac has a SIEM monitoring the enclave, and that information is reviewed by Cuick Trac security analysts and reviewed with Cuick Trac customers on a regular basis.
