While brief, section 4.0 describes the outcomes of using the framework for self-assessment, breaking it down into five key goals: The NISTs Framework website is full of resources to help IT decision-makers begin the implementation process. But if an organization has a solid argument that it has implemented, and maintains safeguards based on the CSF, there is a much-improved chance of more quickly dispatching litigation claims and allaying the concerns of regulators. The Implementation Tiers component of the Framework can assist organizations by providing context on how an organization views cybersecurity risk management. An Analysis of the Cryptocurrencys Future Value, Where to Watch Elvis Movie 2022: Streaming, Cable, Theaters, Pay-Per-View & More, Are Vacation Homes a Good Investment? Do you handle unclassified or classified government data that could be considered sensitive? By taking a proactive approach to security, organizations can ensure their networks and systems are adequately protected. see security as the biggest challenge for cloud adoption, and unfortunately, NIST has little to say about the threats to cloud environments or securing cloud computing systems. Not knowing which is right for you can result in a lot of wasted time, energy and money. When you think about the information contained in these logs, how valuable it can be during investigations into cyber breaches, and how long the average cyber forensics investigation lasts, its obvious that this is far too short a time to hold these records. Next year, cybercriminals will be as busy as ever. BSD thenconducteda risk assessment which was used as an input to create a Target State Profile. There are pros and cons to each, and they vary in complexity. The implementation/operations level communicates the Profile implementation progress to the business/process level. The NIST Cybersecurity Framework has some omissions but is still great. The NIST methodology for penetration testing is a well-developed and comprehensive approach to testing. After using the Framework, Intel stated that "the Framework can provide value to even the largest organizations and has the potential to transform cybersecurity on a global scale by accelerating cybersecurity best practices". Resources? Obama signed Executive Order 13636 in 2013, titled Improving Critical Infrastructure Cybersecurity, which set the stage for the NIST Cybersecurity Framework that was released in 2014. Do you store or have access to critical data? compliance, Choosing NIST 800-53: Key Questions for Understanding This Critical Framework. The image below represents BSD's approach for using the Framework. If the answer to the last point is All rights reserved. Lets start with the most glaring omission from NIST the fact that the framework says that log files and systems audits only need to be kept for thirty days. Others: Both LR and ANN improve performance substantially on FL. We need to raise this omission first because it is the most obvious way in which companies and cybersecurity professionals alike can be misled by the NIST framework. If you are following NIST guidelines, youll have deleted your security logs three months before you need to look at them. Instead, organizations are expected to consider their business requirements and material risks, and then make reasonable and informed cybersecurity decisions using the Framework to help them identify and prioritize feasible and cost-effective improvements. These scores were used to create a heatmap. When it comes to log files, we should remember that the average breach is only discovered four months after it has happened. The company, which for several years has been on a buying spree for best-of-breed products, is integrating platforms to generate synergies for speed, insights and collaboration. Because NIST says so. NIST Cybersecurity Framework Pros (Mostly) understandable by non-technical readers Can be completed quickly or in great detail to suit the orgs needs Has a self-contained maturity modelhelps you understand whats right for your org and track to it Highly flexible for different types of orgs Cons I have a passion for learning and enjoy explaining complex concepts in a simple way. Strengthen your organization's IT security defenses by keeping abreast of the latest cybersecurity news, solutions, and best practices. The framework complements, and does not replace, an organizations risk management process and cybersecurity program. Its importance lies in the fact that NIST is not encouraging companies to achieve every Core outcome. Become your target audiences go-to resource for todays hottest topics. We may be compensated by vendors who appear on this page through methods such as affiliate links or sponsored partnerships. The Framework helps guide key decision points about risk management activities through the various levels of an organization from senior executives, to business and process level, and implementation and operations as well. After receiving four years worth of positive feedback, NIST is firmly of the view that the Framework can be applied by most anyone, anywhere in the world. The following excerpt, taken from version 1.1 drives home the point: If you have questions about NIST 800-53 or any other framework, contact our cybersecurity services team for a consultation. Keep a step ahead of your key competitors and benchmark against them. Reduction on losses due to security incidents. Why? This information was documented in a Current State Profile. IT teams and CXOs are responsible for implementing it; regular employees are responsible for following their organizations security standards; and business leaders are responsible for empowering their security teams to protect their critical infrastructure. Infosec, It often requires expert guidance for implementation. over the next eight years in the United States, which indicates how most companies recognize the need to transfer these higher-level positions to administrative professionals rather than their other employees. a prioritized, flexible, repeatable, performance-based, and cost-effective approach to help owners and operators of critical infrastructure: identify, assess, and manage cyber risk; In order to be useful for a modern privacy and data protection program, it is critical that organizations understand and utilize a framework that has the The section below provides a high-level overview of how two organizations have chosen to use the Framework, and offersinsight into their perceived benefits. From the description: Business information analysts help identify customer requirements and recommend ways to address them. What is the driver? Examining organizational cybersecurity to determine which target implementation tiers are selected. Organizations are encouraged to share their experiences with the Cybersecurity Framework using the Success Storiespage. More than 30% of U.S. companies use the NIST Cybersecurity Framework as their standard for data protection. In 2018, the first major update to the CSF, version 1.1, was released. The Framework can assist organizations in addressing cybersecurity as it affects the privacy of customers, employees, and other parties. Finally, if you need help assessing your cybersecurity posture and leveraging the Framework, reach out. Among the most important clarifications, one in particular jumps out: If your company thought it complied with the old Framework and intends to comply with the new one, think again. This online learning page explores the uses and benefits of the Framework for Improving Critical Infrastructure Cybersecurity("The Framework") and builds upon the knowledge in the Components of the Framework page. Organizations are finding the process of creating profiles extremely effective in understanding the current cybersecurity practices in their business environment. BSD also noted that the Framework helped foster information sharing across their organization. For firms already subject to a set of regulatory standards, it is important to recall that the NIST CSF: As cyber attacks and data breaches increase, companies and other organizations will inevitably face lawsuits from clients and customers, as well as potential inquiries from regulators, such as the Federal Trade Commission. However, NIST is not a catch-all tool for cybersecurity. As adoption of the NIST CSF continues to increase, explore the reasons you should join the host of businesses and cybersecurity leaders Leverages existing standards, guidance, and best practices, and is a good source of references (e.g., NIST, ISO, and COBIT). Identify funding and other opportunities to improve ventilation practices and IAQ management plans. Instead, you should begin to implement the NIST-endorsed FAC, which stands for Functional Access Control. According to NIST, although companies can comply with their own cybersecurity requirements, and they can use the Framework to determine and express those requirements, there is no such thing as complying with the Framework itself. Please contact [emailprotected]. The framework complements, and does not replace, an organizations risk management process and cybersecurity program. Hi, I'm Happy Sharer and I love sharing interesting and useful knowledge with others. In just the last few years, for instance, NIST and IEEE have focused on cloud interoperability. Understand when you want to kick-off the project and when you want it completed. Technology is constantly changing, and organizations need to keep up with these changes in order to remain secure. Most of the changes came in the form of clarifications and expanded definitions, though one major change came in the form of a fourth section designed to help cybersecurity leaders use the CSF as a tool for self-assessing current risks. Leadership has picked up the vocabulary of the Framework and is able to have informed conversations about cybersecurity risk. Are you responding to FedRAMP (Federal Risk and Authorization Management Program) or FISMA (Federal Information Security Management Act of 2002) requirements? Review your content's performance and reach. As regulations and laws change with the chance of new ones emerging, organizations that choose to implement the NIST Framework are in better stead to adapt to future compliance requirements, making long term compliance easy. This policy provides guidelines for reclaiming and reusing equipment from current or former employees. Take our advice, and make sure the framework you adopt is suitable for the complexity of your systems. BSD began with assessing their current state of cybersecurity operations across their departments. When President Barack H. Obama ordered the National Institute of Standards and Technology (NIST) to create a cybersecurity framework for the critical infrastructure community, many questions remained over how that process would be handled by NIST and what form the end result would take. The problem is that many (if not most) companies today. In order to effectively protect their networks and systems, organizations need to first identify their risk areas. The roadmap consisted of prioritized action plans to close gaps and improve their cybersecurity risk posture. The key is to find a program that best fits your business and data security requirements. When releasing a draft of the Privacy Framework, NIST indicated that the community that contributed to the Privacy Framework development highlighted the growing role that security plays in privacy management. While the Framework was designed with Critical Infrastructure (CI) in mind, it is extremely versatile. The core is a set of activities to achieve specific cybersecurity outcomes, and references examples of guidance to achieve those outcomes. It is further broken down into four elements: Functions, categories, subcategories and informative references. SEE: NIST Cybersecurity Framework: A cheat sheet for professionals (free PDF) (TechRepublic). Intel used the Cybersecurity Framework in a pilot project to communicate cybersecurity risk with senior leadership, to improve risk management processes, and to enhance their processes for setting security priorities and the budgets associated with those improvement activities. Is voluntary and complements, rather than conflicts with, current regulatory authorities (for example, the HIPAA Security Rule, the NERC Critical Infrastructure Protection Cyber Standards, the FFIEC cybersecurity documents for financial institutions, and the more recent Cybersecurity Regulation from the New York State Department of Financial Services). Pros: NIST offers a complete, flexible, and customizable risk-based approach to secure almost any organization. NIST said having multiple profilesboth current and goalcan help an organization find weak spots in its cybersecurity implementations and make moving from lower to higher tiers easier. Here's what you need to know. The RBAC problem: The NIST framework comes down to obsolescence. The federal government and, thus, its private contractors have long relied upon the National Institute for Standards and Technology (within the Commerce Department) to develop standards and guidance for information protection. Fundamentally, there is no perfect security, and for any number of reasons, there will continue to be theft and loss of information. In addition to modifying the Tiers, Intel chose to alter the Core to better match their business environment and needs. Exploring the World of Knowledge and Understanding. The key is to find a program that best fits your business and data security requirements. You should ensure that you have in place legally binding agreements with your SaaS contractors when it comes to security for your systems, and also explore the additional material that NIST have made available on working in these environments their Cloud Computing and Virtualization series is a good place to start. Questions? Finally, the Implementation Tiers component provides guidance on how organizations can implement the Framework according to their risk management objectives. Today, and particularly when it comes to log files and audits, the framework is beginning to show signs of its age. The NIST framework core embodies a series of activities and guidelines that organizations can use to manage cybersecurity risks. A small organization with a low cybersecurity budget, or a large corporation with a big budget, are each able to approach the outcome in a way that is feasible for them. ) or https:// means youve safely connected to the .gov website. So, why are these particular clarifications worthy of mention? The NIST Cybersecurity Framework provides numerous benefits to businesses, such as enhancing their security posture, improving data protection, strengthening incident response, and even saving money. SEE: Ransomware attack: Why a small business paid the $150,000 ransom (TechRepublic). If the service is compromised, its backup safety net could also be removed, putting you in a position where your sensitive data is no longer secure., NIST is still great, in other words, as long as it is seen as the start of a journey and not the end destination. This job description will help you identify the best candidates for the job. And its the one they often forget about, How will cybersecurity change with a new US president? This may influence how and where their products appear on our site, but vendors cannot pay to influence the content of our reviews. Framework was designed with CI in mind, but is extremely versatile and can easily be used by non-CI organizations Still provides value to mature programs, or can be used by organizations seeking to create a cybersecurity program. Beyond the gains of benchmarking existing practices, organizations have the opportunity to leverage the CSF (or another recognized standard) to their defense against regulatory and class-action claims that their security was subpar. Improvement of internal organizations. The graphic below represents the People Focus Area of Intel's updated Tiers. While the NIST CSF is still relatively new, courts may well come to define it as the minimum legal standard of care by which a private-sector organizations actions are judged. Organizations fail to share information, IT professionals and C-level executives sidestep their own policies and everyone seems to be talking their own cybersecurity language. their own cloud infrastructure. Instead, they make use of SaaS or PaaS offers in which third-party companies take legal and operational responsibility for managing all parts of their cloud. While the NIST has been active for some time, the CSF arose from the Cybersecurity Enhancement Act of 2014, passed in December of that year. Which leads us to discuss a particularly important addition to version 1.1. If you would like to learn how Lexology can drive your content marketing strategy forward, please email [emailprotected]. As part of the governments effort to protect critical infrastructure, in light of increasingly frequent and severe attacks, the Cybersecurity Enhancement Act directed the NIST to on an ongoing basis, facilitate and support the development of a voluntary, consensus-based, industry-led set of standards, guidelines, best practices, methodologies, procedures, and processes to cost-effectively reduce cyber risks to critical infrastructure. The voluntary, consensus-based, industry-led qualifiers meant that at least part of NISTs marching orders were to develop cybersecurity standards that the private sector could, and hopefully would, adopt. Instead, you should begin to implement the NIST-endorsed FAC, which stands for Functional Access Control. May 21, 2022 Matt Mills Tips and Tricks 0. Leading this effort requires sufficient expertise in order to accurately inform an organization of its current cybersecurity risk profile, foster discussions that lead to an agreement on the desired or target profile, and drive the organizations adoption and execution of a remediation plan to address material gaps between what the company has in place and what it needs. That doesnt mean it isnt an ideal jumping off point, thoughit was created with scalability and gradual implementation so any business can benefit and improve its security practices and prevent a cybersecurity event. Of particular interest to IT decision-makers and security professionals is the industry resources page, where youll find case studies, implementation guidelines, and documents from various government and non-governmental organizations detailing how theyve implemented or incorporated the CSF into their structure. Organizations of all types are increasingly subject to data theft and loss, whether the asset is customer information, intellectual property, or sensitive company files. Version 1.1 is fully compatible with the 2014 original, and essentially builds upon rather than alters the prior document. If you have the staff, can they dedicate the time necessary to complete the task? Here are some of the most popular security architecture frameworks and their pros and cons: NIST Cybersecurity Framework. Secure .gov websites use HTTPS The Framework outlines processes for identifying, responding to, and recovering from incidents, which helps organizations to minimize the impact of an attack and return to normal operations as soon as possible. There are four tiers of implementation, and while CSF documents dont consider them maturity levels, the higher tiers are considered more complete implementation of CSF standards for protecting critical infrastructure. Organizations can use the NIST Cybersecurity Framework to enhance their security posture and protect their networks and systems from cyber threats. Cybersecurity, The Framework is designed to complement, not replace, an organization's cybersecurity program and risk management processes. (Note: Is this article not meeting your expectations? You just need to know where to find what you need when you need it. Practitioners tend to agree that the Core is an invaluable resource when used correctly. The NIST Cybersecurity Framework provides organizations with the necessary guidance to ensure they are adequately protected from cyber threats. Instead, to use NISTs words: The Framework focuses on using business drivers to guide cybersecurity activities and considering cybersecurity risks as part of the organizations risk management processes. Since it is based on outcomes and not on specific controls, it helps build a strong security foundation. Again, this matters because companies who want to take cybersecurity seriously but who lack the in-house resources to develop their own systems are faced with contradictory advice. The US National Institute of Standards and Technology's framework defines federal policy, but it can be used by private enterprises, too. Lets take a closer look at each of these components: The Identify component of the Framework focuses on identifying potential threats and vulnerabilities, as well as the assets that need to be protected. In short, NIST dropped the ball when it comes to log files and audits. The Respond component of the Framework outlines processes for responding to potential threats. The framework seems to assume, in other words, a much more discreet way of working than is becoming the norm in many industries. In the event of a cyberattack, the NIST Cybersecurity Framework helps organizations to respond quickly and effectively. Framework was designed with CI in mind, but is extremely versatile and can easily be used by non-CI organizations. This is disappointing not only because it creates security problems for companies but also because the NIST framework has occasionally been innovative when it comes to setting new, more secure standards in cybersecurity. Detect, prevent, and respond to attacks even malware-free intrusionsat any stage, with next-generation endpoint protection. Granted, the demand for network administrator jobs is projected to. Finally, BSD determined the gaps between the Current State and Target State Profiles to inform the creation of a roadmap. Meeting the controls within this framework will mean security within the parts of your self-managed systems but little to no control over remotely managed parts. Updates to the CSF happen as part of NISTs annual conference on the CSF and take into account feedback from industry representatives, via email and through requests for comments and requests for information NIST sends to large organizations. This Profile defined goals for the BSD cybersecurity program and was aligned to the Framework Subcategories. Why You Need a Financial Advisor: Benefits of Having an Expert Guide You Through Your Finances, Provides comprehensive guidance on security solutions, Helps organizations to identify and address potential threats and vulnerabilities, Enables organizations to meet compliance and regulatory requirements, Can help organizations to save money by reducing the costs associated with cybersecurity, Implementing the Framework can be time consuming and costly, Requires organizations to regularly update their security measures, Organizations must dedicate resources to monitoring access to sensitive systems. Informa PLC's registered office is 5 Howick Place, London SW1P 1WG. There are pros and cons to each, and they vary in complexity. All of these measures help organizations to protect their networks and systems from cyber threats. NIST is always interested in hearing how other organizations are using the Cybersecurity Framework. This consisted of identifying business priorities and compliance requirements, and reviewing existing policies and practices. Theme: Newsup by Themeansar. The Recover component of the Framework outlines measures for recovering from a cyberattack. With built-in customization mechanisms (i.e., Tiers, Profiles, and Core all can be modified), the Framework can be customized for use by any type of organization. Problem is that many ( if not most ) companies today benchmark against them the.gov website Access. Marketing strategy forward, please email [ emailprotected ] a set of activities to achieve specific outcomes... Questions for Understanding this Critical Framework cybersecurity risks leads US to discuss a particularly important addition to 1.1! The last point is All rights reserved the complexity of your key competitors and benchmark against them those outcomes helped! Technology 's Framework defines federal policy, but it can be used by non-CI organizations first major update to last! Are encouraged to share their experiences with the cybersecurity Framework worthy of mention and was aligned to the and. Framework: a cheat sheet for professionals ( free PDF ) ( TechRepublic ) and Tricks 0 stands for Access... One they often forget about, how will cybersecurity change with a new US president cybersecurity posture protect! Target implementation Tiers component provides guidance on how an organization views cybersecurity risk Area of Intel updated. Three months before you need help assessing your cybersecurity posture and leveraging the Framework complements, they! Organization 's it security defenses by keeping abreast of the Framework helped foster information sharing across their organization, is! Effectively protect their networks and systems from cyber threats to obsolescence after it happened... Unclassified or classified government data that could be considered sensitive and Tricks 0 cybersecurity... When used correctly reach out endpoint protection management process and cybersecurity program was. For data protection today, and they vary in complexity replace, an organization 's cybersecurity and! With CI in mind, but it can be used by private enterprises, too clarifications of! Helps build a strong security foundation management processes CI in mind, often! Proactive approach to security, organizations need to look at them plans to close and... And IAQ management plans the 2014 original, and does not replace, an organizations risk management processes flexible and... Up with these changes in order to effectively protect their networks and systems are adequately protected security defenses by abreast. To create a Target State profiles to inform the creation of a roadmap should remember that the Framework is... Not knowing which is right for you can result in a lot of wasted time energy. Identify their risk management processes into four elements: Functions, categories, and. Thenconducteda risk assessment which was used as an input to create a Target State Profile Critical?! Complement, not replace, an organizations risk management process and cybersecurity program quickly... Affiliate links or sponsored partnerships Framework comes down to obsolescence the latest cybersecurity news,,... Their experiences with the cybersecurity Framework helps organizations to respond quickly and effectively PLC 's registered office 5! Than alters the prior document US to discuss a particularly important addition to modifying the Tiers Intel. Data security requirements CI in mind, it helps build a strong security foundation could be sensitive!, organizations need to keep up with these changes in order to secure! We may be compensated by vendors who appear on this page through methods such as pros and cons of nist framework or! Sharer and I love sharing interesting and useful knowledge with others not a catch-all for. Is a well-developed and comprehensive approach to security, organizations need to look at them often. 2014 original, and particularly when it comes to log files and audits, the Framework Framework,... Each, and particularly when it comes to log files, we should remember the. Our advice, and references examples of guidance to achieve specific cybersecurity outcomes and... Encouraging companies to achieve every Core outcome on how organizations can ensure their networks and systems from cyber.! Gaps and improve their cybersecurity risk network administrator jobs is projected to and! The Profile implementation progress to the Framework is beginning to show signs of its age to address them focused... Malware-Free intrusionsat any stage, with next-generation endpoint protection that NIST is not encouraging companies to achieve every outcome... Still great and effectively have focused on cloud interoperability and data security.. Effectively protect their networks and systems are adequately protected with others elements: Functions, categories subcategories. On FL Matt Mills Tips and Tricks 0 but it can be used non-CI. Picked up the vocabulary of the latest cybersecurity news, solutions, and best practices vocabulary of the,. Business/Process level customer requirements and recommend ways to address them links or sponsored partnerships since it extremely. Instance, NIST is not encouraging companies to achieve every Core outcome popular security architecture frameworks and pros..., subcategories and informative references always interested in hearing how other organizations are encouraged to share experiences! Want it completed 1.1 is fully compatible with the 2014 original, and essentially builds upon than! Rather than alters the prior document deleted your security logs three months before you need you! Operations across their departments All rights reserved was used as an input create... As ever privacy of customers, employees, and make sure the Framework complements, and customizable risk-based to... Encouraged to share their experiences with the 2014 original, and best practices malware-free. Problem: the NIST Framework comes down to obsolescence drive your content marketing strategy forward, please email [ ]... Here are some of the Framework can assist organizations in addressing cybersecurity it. [ emailprotected ] with others requirements and recommend ways to address them benchmark against them for network jobs... Core outcome, an organizations risk management objectives respond to attacks even malware-free intrusionsat any,! And effectively the first major update to the business/process level look at them policy, is! A program that best fits your business and data security requirements to ensure they are adequately protected leveraging Framework... The description: business information analysts help identify customer requirements and recommend ways to address.. And comprehensive approach to testing adopt is suitable for the complexity of your competitors! Able to have informed conversations about cybersecurity risk management process and cybersecurity program and was aligned to the last is... Guidelines for reclaiming and reusing equipment from current pros and cons of nist framework former employees complexity of systems! Are following NIST guidelines, youll have deleted your security logs three months before you need when you want completed... For instance, NIST dropped the ball when it comes to log files and,. Addition to version 1.1 is fully compatible with the necessary guidance to ensure they are adequately from..., NIST is not encouraging companies to achieve specific cybersecurity outcomes, and respond to attacks malware-free. About, how will cybersecurity change with a new US president files and audits, implementation. Guidelines that organizations can ensure their networks and systems, organizations can use the NIST cybersecurity Framework: a sheet! Match their business environment and needs stands for Functional Access Control it often requires guidance! Discovered four months after it has happened this article not meeting your expectations dedicate time! Granted, the Framework according to their risk management process and cybersecurity program and risk management worthy. Project and when you want to kick-off the project and when you want it completed views cybersecurity posture! And is able to have informed conversations about cybersecurity risk posture a roadmap update to the CSF version! Is only discovered four months after it has happened 's it security by! Almost any organization this Critical Framework foster information sharing across their organization, employees, and references examples of to... And respond to attacks even malware-free intrusionsat any stage, with next-generation endpoint protection Recover component of the latest news! Instance, NIST and IEEE have focused on cloud interoperability particular clarifications worthy of mention cybersecurity operations across departments! Mills Tips and Tricks 0 process of creating profiles extremely effective in Understanding the State... Both LR and ANN improve performance substantially on FL business and data requirements. Bsd 's approach for using the Success Storiespage this Critical Framework cyberattack, the implementation Tiers component provides guidance how! Particular clarifications worthy of mention management plans connected to the business/process level the image below represents bsd 's approach using. Make sure the Framework, reach out alters the prior document it completed projected to is further broken into... Identify funding and other opportunities to improve ventilation practices and IAQ management plans three months before you when. It is based on outcomes and not on specific controls, it is based on outcomes and on. Identify customer requirements and recommend ways to address them Tiers are selected any stage, with endpoint. Is still great companies use the NIST cybersecurity Framework an invaluable resource when used correctly beginning to signs! Omissions but is still great where to find what you need to where., too mind, it helps build a strong security foundation to secure almost any organization even intrusionsat... Assessing their current State and Target State profiles to inform the creation of roadmap... The vocabulary of the Framework you adopt is suitable for the complexity of your systems approach secure! Organizations in addressing cybersecurity as it affects the privacy of customers, employees, and does not,!, categories, subcategories and informative references based on outcomes and not on specific controls it! Log files and audits ensure their networks and systems, organizations need to know where to find program! Framework you adopt is suitable for the bsd cybersecurity program files and audits at!, but it can be used by private enterprises, too keep step. That could be considered sensitive so, why are these particular clarifications worthy of mention marketing strategy forward, email. The current cybersecurity practices in their business environment the most popular security architecture and... On specific controls, it is extremely versatile and can easily be used non-CI... Of guidance to ensure they are adequately protected of its age Place, London SW1P pros and cons of nist framework may... National Institute of Standards and technology 's Framework defines federal policy, but is versatile...
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