Module 1 Discussion 1 The PMHNP as a Psychotherapist Psychotherapy is often misunderstood or devalued. D

Module 1 Discussion 1 The PMHNP as a Psychotherapist Psychotherapy is often misunderstood or devalued. Discuss your views of the PMHNP as a psychotherapist Discuss whether it is feasible to provide psychotherapy at each patient encounter Submission Instructions: Your initial post should be at least 500 words, formatted, and cited in current APA style with support from at least 2 academic sources. From within the last 5 years and should be scholarly articles. Your initial post is worth 8 points Grading Rubric Post substantively accurate. Identifies and demonstrates a sophisticated understanding of the issues, problems, and concepts surrounding the assignment. Provides exceptional and thought-provoking analysis that directly addresses details and/or examples of the main topic. The reference page contains at least the required current scholarly academic reference and text reference. Follows APA guidelines of components: double space, 12 pt. font, abstract, level headings, hanging indent and in-text citations.
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Here is a complete APA-style discussion post suitable for your Module 1 Discussion 1 assignment:


The PMHNP as a Psychotherapist

Abstract

Psychotherapy remains an essential component of comprehensive mental health care, yet it is often undervalued or misunderstood in clinical settings. Psychiatric Mental Health Nurse Practitioners (PMHNPs) are uniquely positioned to deliver psychotherapy due to their advanced training in both medical and therapeutic interventions. This paper explores the significance of the PMHNP as a psychotherapist and examines whether it is feasible to provide psychotherapy at every patient encounter. It also highlights the challenges and strategies to integrate psychotherapy meaningfully into PMHNP practice.

PMHNP as a Psychotherapist

PMHNPs possess the training and licensure required to assess, diagnose, and treat psychiatric conditions through both psychopharmacology and psychotherapy. The American Psychiatric Nurses Association (APNA) recognizes psychotherapy as a core component of advanced practice psychiatric nursing (APNA, 2019). PMHNPs are trained in evidence-based psychotherapies such as cognitive-behavioral therapy (CBT), interpersonal therapy (IPT), and motivational interviewing (MI), allowing them to provide holistic and individualized treatment approaches.

Despite their capacity to deliver psychotherapy, PMHNPs often find themselves limited by role misunderstandings or system-level constraints. There remains a prevailing notion that their primary responsibility is medication management. This misconception devalues the psychotherapeutic capabilities of PMHNPs and perpetuates fragmented care, particularly when patients are referred elsewhere for therapy, leading to disjointed treatment plans and reduced continuity of care (Raines et al., 2020).

Moreover, psychotherapy is an important tool that allows PMHNPs to form therapeutic alliances, uncover underlying psychosocial stressors, and promote long-term recovery rather than symptom suppression alone. The dual role of the PMHNP—offering both medication and psychotherapy—makes them especially suited for integrated care, which is increasingly recognized as best practice in mental health treatment (Thomas et al., 2022).

Feasibility of Providing Psychotherapy at Every Encounter

While the clinical value of psychotherapy is indisputable, it is not always feasible to provide it during every patient encounter. Clinical realities such as high caseloads, limited appointment durations, and administrative burdens often interfere with the ability to deliver full-length psychotherapy sessions. In many outpatient settings, encounters may be limited to 15–30 minutes, especially during medication follow-ups, making it challenging to provide in-depth psychotherapeutic interventions (Delaney & Vanderhoef, 2019).

However, the integration of brief psychotherapeutic techniques can still be feasible. For example, motivational interviewing or elements of CBT can be incorporated into medication management sessions. PMHNPs can also leverage group therapy, telepsychiatry, and stepped-care models to extend psychotherapy access efficiently (Thomas et al., 2022). Collaboration with therapists and social workers may also allow for comprehensive care planning, reserving in-depth psychotherapy for specific sessions or rotating appointments.

Ultimately, the goal is not to provide extensive psychotherapy at every visit but to ensure that every interaction is therapeutic. Whether through active listening, validation, or reframing techniques, PMHNPs can offer psychological support in every encounter—even if full psychotherapy sessions are not always possible.

Conclusion

The PMHNP as a psychotherapist holds a vital and underutilized role in mental health care. With their dual expertise in medical and psychological treatment, PMHNPs can address the complex needs of patients in a more comprehensive manner. While it may not be feasible to offer full psychotherapy in every encounter, incorporating psychotherapeutic principles into each interaction can significantly enhance patient outcomes. Systemic changes, including improved reimbursement models, role education, and collaborative practices, are necessary to fully realize the potential of the PMHNP as a psychotherapist.


References

American Psychiatric Nurses Association. (2019). The PMHNP as psychotherapist: Scope of practice. https://www.apna.org

Delaney, K. R., & Vanderhoef, D. (2019). Psychiatric mental health advanced practice nurses: Impact on access to mental health care. Nursing Outlook, 67(4), 312–315. https://doi.org/10.1016/j.outlook.2019.01.001

Raines, D. A., Haber, J., & Hohener, R. (2020). Advancing PMHNP practice through psychotherapy integration: A model for clinical and academic settings. Archives of Psychiatric Nursing, 34(2), 76–81. https://doi.org/10.1016/j.apnu.2019.11.001

Thomas, C. M., Bertram, J. E., & Allen, R. S. (2022). Incorporating psychotherapy into PMHNP practice: A collaborative and integrative approach. Journal of the American Psychiatric Nurses Association, 28(1), 45–54. https://doi.org/10.1177/10783903211024667

Module 1 Discussion 1 The PMHNP as a Psychotherapist Psychotherapy is often misunderstood or devalued. Discuss your views of the PMHNP as a

Module 1 Discussion 1 The PMHNP as a Psychotherapist Psychotherapy is often misunderstood or devalued. Discuss your views of the PMHNP as a psychotherapist Discuss whether it is feasible to provide psychotherapy at each patient encounter Submission Instructions: Your initial post should be at least 500 words, formatted, and cited in current APA style with support from at least 2 academic sources. From within the last 5 years and should be scholarly articles. Your initial post is worth 8 points Grading Rubric Post substantively accurate. Identifies and demonstrates a sophisticated understanding of the issues, problems, and concepts surrounding the assignment. Provides exceptional and thought-provoking analysis that directly addresses details and/or examples of the main topic. The reference page contains at least the required current scholarly academic reference and text reference. Follows APA guidelines of components: double space, 12 pt. font, abstract, level headings, hanging indent and in-text citations.

Module 1 Discussion 1: The PMHNP as a Psychotherapist

Abstract

Psychotherapy is a fundamental component of psychiatric-mental health care, yet its integration into practice, particularly by Psychiatric Mental Health Nurse Practitioners (PMHNPs), is often misunderstood or undervalued. This discussion explores the role of PMHNPs as psychotherapists, examining their training, scope of practice, and the feasibility of providing psychotherapy at each patient encounter. Drawing on recent scholarly literature, the paper highlights the importance of psychotherapy in mental health care and discusses strategies to enhance its delivery within PMHNP practice.ResearchGate+4APNA+4Nursing Depo+4

if you need this paper send mail to joselucky91@gmail.com

Dream Interpretation Freud viewed dreams as the “royal road to the unconscious.” Discuss a memorable dream from your childhood. Provide as much detail about the dream as possible. Interpret the dream of two peers using the psychodynamic dream of Freud or Jung Submission Instructions: Your initial post should be at least 500 words, formatted, and cited in current APA style with support from at least 2 academic sources from within past 5 years and should be scholarly articles. Grading Rubric Post substantively accurate. Identifies and demonstrates a sophisticated understanding of the issues, problems, and concepts surrounding the assignment. Provides exceptional and thought-provoking analysis that directly addresses details and/or examples of the main topic. The reference page contains at least the required current scholarly academic reference and text reference. Follows APA guidelines of components: double space, 12 pt. font, abstract, level headings, hanging indent and in-text citations.

Dream Interpretation: A Psychodynamic Perspective

Abstract

Sigmund Freud’s assertion that dreams are the “royal road to the unconscious” underscores the significance of dreams in revealing repressed desires and unresolved conflicts. This paper explores a personal childhood dream, analyzes it through the psychodynamic frameworks of Freud and Carl Jung, and examines how these interpretations shed light on unconscious processes. By integrating scholarly perspectives, the paper aims to provide a comprehensive understanding of dream analysis.

It is essential for every organization to communicate with their employees, customers, and other stakeholders

Description

 

 

It is essential for every organization to communicate with their employees, customers, and other stakeholders. How can communication from an organization may change based on the audience and communication method used? Be sure to include some of the employee communication options and contrast how the message may be similar or different to what is publically released. Share any examples you may have to demonstrate this difference.

Question Description I’m working on a health & medical discussion question and need the explanation and answer to help me learn.

Question Description

I’m working on a health & medical discussion question and need the explanation and answer to help me learn.

 

1. Telehealth and telemedicine exploits technology to broaden the reach of healthcare to include rural and medically underserved communities. APRNs are poised to play a vital role in delivery of telehealth care. Schlachta-Fairchild, Varghesej, Deickman, and Castellik (2010) discuss policy issues relevant to APRN practice and telehealth care. Which of those issues do you consider most critical? What actions should be taken by APRNs to remain compliant with local and national practice regulations and reimbursement policies?  If you are a healthcare administrator, what is the role of an organization in providing access to telehealth services to the community?

2. How would you as a health administrator, train your staff to ensure that they are capable of helping patients of all health literacy levels use patient portals to obtain and understand basic information needed to make decisions about their care?

PROBLEM: You have been directed by your corporate or organizational president to research one of the following situations/problems and prepare a formalized research paper. This paper should be addressed

PROBLEM: You have been directed by your corporate or organizational president to research one of the following situations/problems and prepare a formalized research paper. This paper should be addressed to the president, board of directors, and your professor. For this research, you should conduct a review of literature based on the current practices being used in today’s organizations (in terms of your selected research problem/situation).

For your research project, your topic is below.. As you conduct your secondary and/or primary research, you should also develop a well-developed strategy as to how to implement your strategy into this organization. One way to view the selected problem is to think of a current or previous organization, in which you might focus your research efforts towards. For example, you may be facing the same problem in your current organization – so you could write this paper, based on addressing this particular problem with your current organization. If you do not see the relevance of any of these problems with your current or past employers – just write your paper as if you were employed with a Fortune 500 company or an organization currently in the news.

HERE IS YOUR RESEARCH TOPIC:

Creation and implementation of a new performance appraisal system or method of conducting performance appraisals.

AUDIENCE:
Please write your research paper as if your organizational or corporate president and/or board of directors would review and consider its findings and recommendations. However, your professor will be the final reviewer for this paper.

Description For the Week 4 Discussion, a word cloud featuring terms relating to the Enlightenment and Classical music is used.

Description

 

 

For the Week 4 Discussion, a word cloud featuring terms relating to the Enlightenment and Classical music is used.

  • Complete the Week 4 reading and listening, which includes Chapter 4 “The Classical Era” in the course text and the Week 4 Content.
  • Choose an example from the listening list below.
  • Listen carefully to your selection.
  • Using at least 10 words from the Classical Music word cloud, describe specific elements that relate to your musical selection. Note that the following words do not count towards the 10-word requirement: music, musical, composer/s and Classical. Write in complete sentences. The ten terms need to be used in a way that relates to music and/or culture in the Classical era. Initial posts are to be a minimum of 250 words.
  • Bold or highlight the ten words in your answer chosen from the Classical Music word cloud.
  • Post your completed answer to the WK4 Discussion.

Listening List

Mozart, “Piano Sonata No. 11 in A major, third movement”

Mozart, “Piano Concerto No. 21 in C major, K. 467”

Mozart, “Symphony No. 40 in G minor, K. 550, fourth movement”

Mozart, “Der Hölle Rach” from act 2 of The Magic Flute

Mozart, “The Marriage of Figaro, Overture”

Haydn, “String Quartet No. 62 in C major”

Haydn, “String Quartet No. 53 in D major, Op. 64, No. 5” (“The Lark”)

Haydn, “Symphony No. 94 in G major” (“The Surprise Symphony”)

Haydn, “Trumpet Concerto in E-flat major”

Beethoven, “Piano Concerto No. 4 in G major, Op. 58, second & third movement”

Beethoven, “Symphony No. 5 in C minor, Op.67, Allegro con Brio”

Beethoven, “String Quartet No. 6 in B-flat major”

Finally, respond substantively to two of your classmates’ answers. Use words from the Classical Music word cloud in your responses to others.

Fully develop your ideas. Add something meaningful to the discussion in a way that reflects your understanding of the course material. Your answer and responses to others will be graded as part of your Discussion participation for this week.

Question Description I’m trying to study for my Biology course and I need some help to understand this question.

Question Description

I’m trying to study for my Biology course and I need some help to understand this question.

 

Support the position that there could be as many as TEN times as many microbes living on and inside of you than there are cells that make up who you are?

Description 1A. In your own words, define the following terms:

Description

 

 

1A. In your own words, define the following terms:

-Euthanasia

-Active vs. passive euthanasia

-Voluntary vs. involuntary euthanasia

1B. What is physician assisted suicide and how does it differ from euthanasia?

Cybersecurity Compliance in Defense Considering the DoD Risk Management Framework (RMF) Dennis W. G. Hackney, B.A., M.B.A., Ph.D., CISSP, CMMC-RP In this module we will cover: Cybersecurity Compliance in Defense

Cybersecurity Compliance in Defense Considering the DoD Risk Management Framework (RMF) Dennis W. G. Hackney, B.A., M.B.A., Ph.D., CISSP, CMMC-RP In this module we will cover: Cybersecurity Compliance in Defense • The foundational defense cybersecurity compliance processes, beginning with the RMF • Organization-wide risk management principals • Key roles in the DoD RMF process • Important activities to be performed in RMF The RMF is a risk-based compliance process Cybersecurity Compliance in Defense • NIST provides non-DoD specific guidance using SP 800-37R2 • The NIST SP 800-37R2 will provide a process overview • DoDI 8510.01 will provide DoD-specific considerations • Next, we’ll quickly review the RMF process steps NIST SP 800-37R2 RMF Process NIST RMF is a 7-step process Cybersecurity Compliance in Defense Prepare according to SP 800-37R2 Cybersecurity Compliance in Defense “Prepare to execute the RMF from an organization- and a system-level perspective by establishing a context and priorities for managing security and privacy risk.” Categorize according to SP 800-37R2 Cybersecurity Compliance in Defense “Categorize the system and the information processed, stored, and transmitted by the system based on an analysis of the impact of loss.” Select according to SP 800-37R2 Cybersecurity Compliance in Defense “Select an initial set of controls for the system and tailor the controls as needed to reduce risk to an acceptable level based on an assessment of risk.” Implement according to SP 800-37R2 Cybersecurity Compliance in Defense “Implement the controls and describe how the controls are employed within the system and its environment of operation.” Assess according to SP 800-37R2 Cybersecurity Compliance in Defense “Assess the controls to determine if the controls are implemented correctly, operating as intended, and producing the desired outcomes with respect to satisfying the security and privacy requirements.” Authorize according to SP 800-37R2 Cybersecurity Compliance in Defense “Authorize the system or common controls based on a determination that the risk to organizational operations and assets, individuals, other organizations, and the Nation is acceptable.” Monitor according to SP 800-37R2 Cybersecurity Compliance in Defense “Monitor the system and the associated controls on an ongoing basis to include assessing control effectiveness, documenting changes to the system and environment of operation, conducting risk assessments and impact analyses, and reporting the security and privacy posture of the system.” NIST RMF, Remember… Cybersecurity Compliance in Defense • We’ve just completed an overview of each of the RMF steps. • Remember, NIST works with DoD and other Federal agencies to produce standards that can be applied consistently throughout the government. • While both the NIST SP 800-37R2 and DoDI 8510.01 define the RMF, NIST is more generic guidance while DoDI is specific to the Military. • In the upcoming slides, we’ll explain concepts using NIST and then specific DoD requirements following those NIST concepts. NIST RMF Organization (1/3) Cybersecurity Compliance in Defense Security and privacy risk management is organization-wide as displayed in this image from NIST SP 800-37R2. NIST RMF Organization (2/3) Cybersecurity Compliance in Defense • Organization – All systems inherit a common set of controls from this level. • Mission/Business Process – Only systems in this process inherit from the organization and from this set of controls. • Information System – Each system inherits controls from the organization, its mission, and then a tailored set depending on the individual requirements of the system. NIST RMF Organization (3/3) Cybersecurity Compliance in Defense • Preparing for the RMF requires many inputs to name a few: • Representation from Level 1 and Level 2 • An understanding of the information types in Level 3 • The overall technology strategy and modernization initiatives for information systems • Assigning roles and responsibilities and identifying stakeholders • Establishing risk management strategy and risk tolerance • … following the RMF process! DoD RMF Governance (DoDI 8510.01) Cybersecurity Compliance in Defense Risk management activities are synchronized and integrated across the IT lifecycle and logical and organizational entities. DoD RMF Refresher (DoDI 8510.01) DoD RMF is a 6-step process Cybersecurity Compliance in Defense Step 1: CATEGORIZE System (1/2) Cybersecurity Compliance in Defense • Requires the use of (Committee on National Security Systems Instruction (CNSSI) 1253 to “Categorize” the Information System (IS) or Platform IT (PIT) system • Define the system and boundary in a Security Plan • Register the system according to the DoD component (I.e., set up in eMASS) • Assign the qualified RMF Roles (PM/SM, ISO, IO, Mission Owners, ISSM, SCA, AO) Notes: CNSSI_No1253.pdf (dcsa.mil) is not required reading for this course. This provides a preset list of NIST 800-53 controls based on system designations, i.e., CIA ratings. Step 1: CATEGORIZE System (2/2) Cybersecurity Compliance in Defense • RMF Roles Defined • PM/SM. Program Manager/System Manager • ISO. Information System Owner • IO. Information Owner • Mission Owners • ISSM. Information System Security Manager • SCA. Security Control Assessor • AO. Authorizing Official from the DoD Component Step 2: SELECT Security Controls Cybersecurity Compliance in Defense • Common Control Identification (CCI) o Risk-based and provided by Tier 1 and Tier 2 levels • Select security controls and tailor o Based on the IS or PIT system categorization o Considers criterial such as Tactical, PIT, Personally Identifiable Information, Cross-domains, and Classified information • Develop system-level continuous monitoring strategy (CMS) • Review and approve security plan and CMS o ISO or PM/SM submits o AO approves if the proposed security requirements are met or rejects if not Step 3: IMPLEMENT Security Controls Cybersecurity Compliance in Defense • Implement security controls using technical guidance o Security Technical Implementation Guide (STIG) o Security Requirements Guide (SRG) • Security solutions consistent with DoD Component Cybersecurity Architectures o DoD Component is the “owning organization” • Common controls can be inherited by hosting or connected systems Step 4: ASSESS Security Controls Cybersecurity Compliance in Defense • Develop and approve Security Assessment Plan (SAP) • Ensure interoperability and supportability • Ensure reuse and maximize efficiency and effectiveness • SCA assess security controls • Record compliance status • Assign severity to vulnerabilities (not compliant controls) • Establish risk level • SCA prepares the Security Assessment Report (SAR) • Conduct initial remediation actions Step 5: AUTHORIZE System Cybersecurity Compliance in Defense • Prepare the Plan of Action and Milestones (POA&M) • Developed by the ISO or PM/SM • Maintained throughout the system lifecycle • Tracked by the AO • Must be executed and milestones met to maintain authorization • Submit Security Authorization Package to AO • Includes the security plan, SAR, and POA&M) • AO conducts final risk determination • AO makes authorization decision • Responses can be Authorization to Operate (ATO), Interim Authorization To Test (IATT), or Denial of ATO (DATO) • Can be 3 years if risk is not “Very High” or “High”, Authorization Termination Date (ATD) of less than 3 years is set otherwise Step 6: MONITOR Security Controls Cybersecurity Compliance in Defense • Determine impact of changes to the system and environment • ISSM monitors, assesses changes, and reports of risk-level changes to the AO • Assess selected controls annually • Annual review of a required subset of controls to ensure continued compliance • Conduct needed remediation (Based on monitoring) • Update security plan, SAR, and POAM • Report security status to AO • AO reviews reported status • Implement system decommissioning strategy Summary Cybersecurity Compliance in Defense • NIST provides non-DoD specific guidance, SP 800-37R2 • DoDI 8510.01 will provide DoD-Specific Considerations • The DoD RMF is made up of 6 steps (7 for NIST) • Security and privacy risk management is organization-wide • Risk Management include 3 levels (Tiers) ranging from strategic to tactical (system-specific) elements • Know the DoD RMF Steps Cybersecurity Compliance in Defense Considering the Cybersecurity Maturity Model Dennis W. G. Hackney, B.A., M.B.A., Ph.D., CISSP, CMMC-RP In this module we will cover: Cybersecurity Compliance in Defense • The Cybersecurity Maturity Model Certification Model • CMMC Accreditation Body and Ecosystem • Federal Contract Information and Controlled Unclassified Information • The CMMC Assessment Process Note: This course has not been endorsed by the CMMC AB and is not affiliated with the CMMC AB at this time. The instructor of this course is a CMMC Registered Practitioner, and authorized to consult on the CMMC. The information offered in this section is publicly available and can be found on the Web. If your organization is seeking CMMC training, refer to the CMMC Marketplace for more information about CMMC and a listing of Licensed Training Providers. CMMC Program has Multiple Dimensions Cybersecurity Compliance in Defense • An Accreditation Body (CMMC AB) certifies CMMC Third Party Assessment Organizations (C3PAOs) • CMMC is a cost-effective approach for smaller companies, and scalable to larger companies • Built on FAR 52.204-21 & DFARS 252.204-7012 as well as NIST SP 800-171 and SP 800-172 • Maturity-based process including 3-Levels (CMMC V2) • Will be gradually introduced in DoD contract solicitations over the next few years CMMC Model Cybersecurity Compliance in Defense Image reference: https://www.acq.osd.mil/cmmc/about-us.html CMMC Accreditation Body and Ecosystem Cybersecurity Compliance in Defense • Organizations Seeking Certification (OSC) • Certified Professionals, Assessors (CP & CA) • CMMC 3rd Party Assessment Organizations (C3PAO) • Registered Practitioner (RP) • Registered Practitioner Organization (RPO) • Master Instructors (MP) • Licensed Training Providers (LTP) • Licensed Partner Publishers (LPP) Image reference: https://cmmcab.org/ Federal Contract Information (FAR 52.204-21) Cybersecurity Compliance in Defense • Information, • not intended for public release, • provided by or generated for the Government • under a contract • to develop or deliver a product or service to the Government Controlled Unclassified Information (Executive Order 13556) Cybersecurity Compliance in Defense • CUI Executive Agent (EA) is the National Archives and Records Administration (NARA) CUI is “information the Government creates or possesses, or that an entity creates or possesses for or on the behalf of the Government, that a law, regulation, or Government-wide policy requires or permits an agency to handle using safeguarding or dissemination controls. However, CUI does not include classified information” CMMC Assessments Cybersecurity Compliance in Defense • Four types of assessments • Level 1 = Annual self-assessment (FCI) • Level 2 type 1 = Annual self-assessment for select (CUI) programs • Level 2 type 2 = Triennial C3PAO for national security information • Level 3 = Triennial government-led assessments Note: At this time the CMMC rules are under development and these assessment guidelines are subject to change CMMC Requirements Summarized Cybersecurity Compliance in Defense • Access Control (AC) • L1=4, L2=18 • Awareness & Training (AT) • L2=4 • Audit & Accountability (AU) • L2=9 • Configuration Management (CM) • L2=9 • Identification & Authentication (IA) • L1=2, L2=9 • Incident Response (IR) • L2=3 • Maintenance (MA) • L2=6 • Media Protection (MP) • L1=1, L2=8 • Personnel Security (PS) • L2=2 • Physical Protection (PE) • L1=4, L2=2 • Risk Assessment (RA) • L2=3 • Security Assessment (CA) • L2=4 • System and Communications Protection (SC) • L1=2, L2=14 • System and Information Integrity (SI) • L1=4, L2=3 https://www.acq.osd.mil/cmmc/docs/ModelOverview_V2.0_FINAL2_20211202_508.pdf CMMC Assessments Cybersecurity Compliance in Defense This is the instructor’s depiction of the CMMC assessment process. There isn’t a published depiction at this time. All levels follow the same general process, while the numbers of requirements and the assessors will be different. Define Scope (FCI/CUI/critical national security) Implement Security Requirements (L1,L2, L3) Document Report of Compliance Request/Perform Assessment (L1), System Security Plan (Self-attestation, C3PAO, or Government Official) (L2&L3), POA&M (L1,L2, L3) Register Results in Supplier Performance Risk System (SPRS) Reassessment (Annual, Triennial, Level Increases) Summary Cybersecurity Compliance in Defense • The CMMC is a maturity-based assessment model • CMMC AB and Ecosystem are made up of multiple different organizations to support commercial companies contracting to the DoD • L1 is aligned to FCI while L2 is aligned to CUI, Level 3 is under development • The assessment process utilizes a cost-effective approach, including self-assessment, C3PAO, or Government assessors, depending on contract requirements Cybersecurity Compliance in Defense Contrasting and Comparing DoD RMF and the CMMC in Regulation and Practice Dennis W. G. Hackney, B.A., M.B.A., Ph.D., CISSP, CMMC-RP In this module we will cover: Cybersecurity Compliance in Defense • Simplified view of DoD RMF versus CMMC V2 • Divergence in Requirements • Regulations and Other Influences • Risk Assessment Considerations (Lessons Learned V. Industry Maturity) • Cybersecurity Compliance in Practice RMF versus CMMC V2: Process versus Practice Cybersecurity Compliance in Defense DoD RMF is a 6-Step Government Assessment and Authorization Process CMMC V2 is a 3-Level Maturity 3rd Party Certification Process RMF versus CMMC: Target Audience Expectations Cybersecurity Compliance in Defense • Both processes fall back on the NIST SP 800-53 controls • NIST controls are designed to be applied to Federal Information Systems • SP 800-53R5 comprises 20 control families and 1189 controls with enhancements! • Let’s take a look at the totals on the next slide. For more information: https://csrc.nist.gov/publications/detail/sp/800-53/rev-5/final RMF versus CMMC: The Numbers Say It All Cybersecurity Compliance in Defense Family ACCESS CONTROL AWARENESS AND TRAINING FAMILY AUDIT AND ACCOUNTABILITY ASSESSMENT, AUTHORIZATION, AND MONITORING CONFIGURATION MANAGEMENT CONTINGENCY PLANNING IDENTIFICATION AND AUTHENTICATION INCIDENT RESPONSE MAINTENANCE MEDIA PROTECTION PHYSICAL AND ENVIRONMENTAL PROTECTION PLANNING PROGRAM MANAGEMENT PERSONNEL SECURITY PERSONALLY IDENTIFIABLE INFORMATION PROCESSING AND TRANSPARENCY RISK ASSESSMENT SYSTEM AND SERVICES ACQUISITION SYSTEM AND COMMUNICATIONS PROTECTION SYSTEM AND INFORMATION INTEGRITY SUPPLY CHAIN RISK MANAGEMENT 800-53.5 800-171.2 147 22 17 3 69 9 32 4 66 9 56 0 70 11 42 3 30 6 30 9 59 6 17 0 37 0 18 2 21 0 26 3 145 0 162 16 118 7 27 0 1189 110 Divergence in Requirements: Quick Summary with History Cybersecurity Compliance in Defense • DoD 5200.28 (The Orange Book) included “Commercial Product Evaluation Process” in 1985 • Applied to DoD information systems, “Trusted Computer Systems” • Evaluations for COTS typically focused on DoD info., not non-DoD info. • However, DoD systems were being designed and built by non-DoD companies. • Companies that attempted the requirements were not able to due to expense and lack of expertise • The DoD could not enforce the requirements on non-DoD, no regulation • While the DoD cybersecurity process matured, there was still the question, “how do we apply this to non-DoD information systems?” Divergence in Requirements: Enter “CUI” Cybersecurity Compliance in Defense • Executive Order 13556 established CUI on November 4, 2010. • Protecting Controlled Unclassified Information in Nonfederal Information Systems and Organizations, NIST SP 800-171 was published in April 2015 • Part 2002 of 32 Code of Federal Regulations prescribed on September 14, 2016Government-wide implementation standards . • DoD Instruction 5200.48, “Controlled Unclassified Information,” established DoD CUI policy on March 6, 2020. Risk Assessment Considerations (1/2) Cybersecurity Compliance in Defense • In theory, cybersecurity risk assessments are used to determine control implementation strategy. • …the higher the risk, the more stringent the control implementation! • Both RMF and CMMC require risk assessments to be completed. • …but control selection is pretty much already done! • From week 1 we recall that the RMF references CNSSI 1253 while CMMC V2 relies on FCI, and CUI controls (i.e., SP 800171)! • If assessing the risk is so important, why don’t companies get to do it? Risk Assessment Considerations (2/2) Cybersecurity Compliance in Defense • … why don’t companies get to do the risk assessment? • Answer: Delegation of authority has caused subjectivity, confusion, and poorer security. • Therefore, the Federal Government defines the information and impacts, consequences, and severities if breaches of confidentially, integrity, or availability occur! • There are still some risk assessment considerations, i.e., whether an AO accepts a risk. • We’ll discuss that more in a later module. Cybersecurity Compliance in Practice Cybersecurity Compliance in Defense • DoD RMF is a “6-Step” process and CMMC V2 is a “3-Level” maturity model • Steps are important in the DoD because there are 1000’s of controls, many different DoD components, DoD information at stake (including classified), and the Government controls the certification process • As where in the CMMC, the contract specifies the Maturity Level (ML) to attain and the CMMC AB controls the certification process • In practice, for both processes we focus on assessing the implementation of controls to measure success. • That’s compliance! Summary Cybersecurity Compliance in Defense • Both the RMF and the CMMC references NIST SP 800-53 controls • RMF has over 1000 possible controls while the CMMC V2 is under 200 • DoD RMF process has matured for over 45 years! • CUI was defined in 2010 and the first CMMC-like process began in 2015 (SP 800-171 first release) • In both RMF and CMMC the information risk assessments have already been done. • CMMC AB manages the certification process while in the RMF, the Government manages the process.