Lighthouse for the Blind
Non-Compliance Risk - False Claims Act violations
- Avg. fine 150-750k from DOJ / 3x the contract
- We need to strategize on the response to Victoria and InTech
Policies | Policies
- Managing here: 0Document Listing.xlsx
- Roles & Responsibilities Overview Document
Lighthouse handoff — week of September 7–13
The team reviewed Intech’s 2024 CMMC/NIST assessment and flagged serious gaps around documented, repeatable processes, the missing SSP, POA&M evidence, and the accuracy/status of the reported SPRS score. The latest view was that only the November 2024 score was on file and it remained unclear whether it had been submitted to the government.
We are discussing the production of a neutral, third-party gap report on Intech’s compliance shortfalls for upper management. The report should present facts and a path to compliance—not position it as an “us or them” replacement recommendation.
Diana’s read-through is scheduled for Thursday, September 17, for one hour. The main deck should stay positively focused on the path to compliance; the Intech gap report will be a separate supporting asset.
Tabletop-exercise planning moved forward. The proposed scenario is a malware incident entering through compromised email and progressing through the environment, with the MSP included. The September 15 call was extended to one hour: 15 minutes for project updates and 45 minutes for Mike to begin scoping with Antonio.
The September 22 and 24 Lighthouse calls were cancelled because Antonio will be out; calls resume the week of September 29.
MVY has conflict for Lighthouse Tuesday Calls and will not be on September 15, 22, October 6, 13
Policy-template standards were agreed: role-based owners/approvers, revision history at the bottom, a standard Purpose → Scope → Policy Statement → Roles & Responsibilities structure, and framework alignment in an appendix.
Immediate open items
- Produce the Intech third-party gap report.
- Prepare for Diana’s September 17 read-through.
- Run the September 15 update/TTX-scoping call.
- Confirm the SPRS submission history and supporting documentation.