Top NISPOM Compliance Challenges Government Face

Understanding and Interpreting Complex Requirements

Understanding the requirements established through NISPOM is one of the more significant challenges. This framework includes numerous detailed requirements related to classified handling, personnel security, physical security safeguards, insider threat programs, and information system protection. For companies that are new to operating with classified information, the volume of guidance and requirements can be daunting.

Even experienced contractors face challenges when interpreting requirements. Many are relatively straightforward when looked at in isolation; however, when placed into the specific, unique operational environment of a contractor’s operations, it can be less clear-cut and more complicated. 

Meeting compliance requirements is also significantly affected by the government constantly evolving its security guidance as the threat landscape changes. In order to remain compliant with the changing policies and procedures set forth by the government, most contractors must routinely review all of their security processes and procedures to ensure that they comply with their own internal policies, as well as the latest government security requirements. Without an established way to manage compliance, companies can potentially lose use of older methods of compliance inadvertently.

Many companies may read and understand the security requirements outlined within NISPOM; however, translating or integrating these requirements into a company’s daily workflows is a significant hurdle. To do this, the business processes that a company has in place will require collaboration and approval from others in various organizations before a company’s ability to show compliance with NISPOM can be validated.

Building and Maintaining an Insider Threat Program

NISPOM has a very strong emphasis on detecting and preventing insider threats but although it is something everybody seems to understand, a good effort to create a program is not very easy for the majority of contractors. Many contractors are often confused about what roles are in an organization, how to monitor those roles, and how they can develop a mechanism for reporting concerns that will satisfy the expectations of NISPOM.

The employees must be properly trained in their ability to detect suspicious activities, report them, and have knowledge of why the insider threat programme exists. If employee training is highly technical, then employees will not be focused on being aware of potential threats. If the training is too basic, then employees will not notice the warning signs of a potential insider threat. An appropriate balance must therefore be achieved in the level of detail provided and training must be provided on a regular basis.

Documentation is another key area. Auditors will be looking for formal documentation of policies, training documentation, incident documentation and an evaluation cycle/history. Most contractors have developed an informal process for conducting and documenting their program, but have failed to adequately document their programs; therefore, they create a lack of compliance with NISPOM even though they have created their program with the intent of following the regulations”.

Managing Classified Information Systems

Handling classified information systems presents some of the most difficult challenges for compliance within technology environments. Classified information systems must comply with stringent configurations, access controls and monitoring requirements. Many contractors have difficulty integrating these compliance controls into their existing infrastructure.

User access management continues to create many challenges for contractors. Contractors must be able to determine who has been granted access rights to classified systems, and that their permissions are appropriate for the person’s position, and that access is removed when a person changes their position. The manual methods used for tracking user access very often result in errors, particularly in the case of high-growth companies.

The documentation related to the various systems (security plans, authorization documentation, configuration baselines, change management records) can become overwhelming. If any system does not have a centralized management structure, relevant documentation will quickly become outdated or inconsistent.

Training and Security Awareness Across the Organization

An organization’s overall compliance with the National Industrial Security Program Operating Manual (NISPOM) relies heavily upon its ability to provide security awareness to its employees. Unfortunately, many contractors do not appreciate the work involved to ensure that their training programs remain effective into the future. Initial training is only the starting point; employees need continual education that is reflective of both changes to the threat landscape and changes to the organization.

Each type of job has developed its own approach to dealing with the handling of information that is considered “sensitive.” For example, executives have a different way to deal with this information than someone who has been granted a government clearance does, and a government clearance holder has a different way of dealing with information than an administrative worker. Because of this, there is no one correct way to train someone on handling sensitive information; the training does not take into account how much risk there is for each group. Because of this, contractors must create training materials that fit the needs of each group.

Creating a strong security culture cannot be accomplished with only providing annual training. It takes communication, reminders, leadership support, and ongoing reinforcement of the message through daily business processes. Many contractors struggle with embedding these practices throughout the organization on a consistent basis.

Preparing for Audits and Maintaining Continuous Compliance

The most stressful challenge to contractors is generally preparation for security reviews/audits. Contractors need to be able to prove that the controls are not only in place but are also actively being maintained. To do this, they require organized documentation, established procedures, and the ability to provide evidence of oversight on an ongoing basis.

Many organizations do not start compiling and organizing their documentation until an audit is imminent. This results in hurried documentation updates, missing documents, and increased stress to the contractor. There is a clear advantage to having a proactive compliance posture; providing structured management is required for this approach.

An additional challenge lies in the need to identify gaps in controls prior to their being identified by auditors. Conducting internal reviews is essential to ensuring compliance, but contractors may not have the means to conduct thorough self-assessments. Smaller issues may snowball into much larger issues over time without external verification.

Continuous compliance is achieved by embedding security within the day-to-day operations of all functions through recurring evaluations, continued updates of policies, refresher training, and regular monitoring of systems within the organization. Contractors who utilize compliance as a continual process are better equipped to handle audits.

Conclusion

Without the proper Facility Security Officer Support Services, the combination of these challenges can slow progress, increase risk, and create unnecessary anxiety during audit periods. 

Partnering with experts has the potential to make a huge difference in this area. Through our Professional Facility Security Officer Services, Dive Deep Security assists government contractors in turning compliance from a burden into a strategic advantage by providing tailored guidance, practical assistance, and continued support. This confidence and experience allow customers to enhance their security posture while remaining laser-focused on the mission.

With Dive Deep Security’s expertise and support, you will be successful in achieving your goals, whether it’s your first classified contract or enhancing an existing compliance program – you will be able to confidently achieve NISPOM standards and have the clarity needed to proceed.