Compliance as Code and Improving the ATO Process
A wide-scale cyber-attack in 2020 impacted a staggering number of federal agencies, including the agency that oversees the United States nuclear weapons arsenal. Government officials are still determining what information the hackers may have accessed, and what they might do with it.
The fundamental failure of federal technology security is the costly expenditure of time and resources on processes that do not make our systems more secure. Our muddled compliance activities allow insecure legacy systems to operate longer, increasing the risk of cyber intrusions and other system meltdowns. The vulnerabilities introduced by these lengthy processes have grave consequences for the nation at large.
In federal technology, the approval to launch a new Information Technology (IT) system is known as an Authority to Operate (ATO). In its current state, the process of obtaining an ATO is resource-intensive, time-consuming, and highly cumbersome. The Administration should kick-start a series of immediate, action-oriented initiatives to incentivize and operationalize the automation of ATO processes (also known as “compliance as code”) and position agencies to modernize technology risk management as a whole.
Challenge and Opportunity
While the compliance methodologies that currently comprise the ATO process contribute to managing security and risk, the process itself causes delays to the release of new systems. This perpetuates risk by extending the use of legacy—but often less secure—systems and mires agencies with outdated, inefficient workflows.
To receive an ATO, government product owners across different agencies are required to demonstrate compliance with similar standards and controls, but the process of providing statements of compliance or “System Security Plans” (SSPs) is redundant and siloed. In addition, SSPs are often hundreds of pages long and oriented toward one-time generation of compliance paperwork over an outdated, three-year life cycle. There are few examples of IT system reciprocity or authorization partnerships between federal agencies, and many are reluctant to share their SSPs with sister organizations that are pushing similar or even identical IT systems through their respective ATO processes. This siloed approach results in duplicative assessments and redundancies that further delay progress.
The next administration should shift from static compliance to agile security risk management that meets the challenges of the ever-changing threat landscape. The following Plan of Action advances that goal through specific directives for the Office of Management and Budget (OMB) Office of the Federal CIO (OFCIO), General Services Administration (GSA), Technology Transformation Service (TTS), and other agencies.
Plan of Action
The Office of Federal Chief Information Officer (OFCIO) should serve as the catalyst of several of activities aimed at addressing inefficiencies in the ATO attainment process.
OFCIO should draft an OMB Compliance as Code Memorandum that initiates two major activities.
First, the Memorandum will direct GSA to create a Center of Excellence within the Technology Transformation Service (TTS). The goals and actions of the Center of Excellence are detailed under “Action Two” below. Second, the Memorandum should require Cabinet-level agencies to draft brief “exploration and implementation plans” that describe how the agency or agencies might explore and adopt compliance as code to create efficiencies and reduce burden.1
OFCIO should offer guidance for the types of explorations that agencies might consider. These might include:
- The integration of development, security and operations (DevSecOps)2 in major systems to allow for the automated validation of security controls.
- The identification of a pilot system or application within each agency that can be leveraged for the conversion of SSPs into a machine-readable format that allows for experimentation with compliance automation.
- The appointment of a single, accountable leader within each agency to guide and oversee compliance as code explorations as well as provide regular reporting to agency Chief Information Officers.
During the plan review process, the OFCIO should collaborate with the Resource Management Offices (RMOs) at OMB to identify agencies that offer the most effective plans and innovations.3 Finally, OFCIO should consider releasing a portion of the agency plans publicly with the goal of spurring research and collaboration with industry.
The General Services Administration should create a Cybersecurity Compliance Center of Excellence.
OMB should commission the creation of a Cybersecurity Compliance Center of Excellence at the General Services Administration (GSA). Joining the six other Centers of Excellence, the Cybersecurity Compliance Center of Excellence (CCCE) would serve to accelerate the adoption of compliance as code solutions, analyze current compliance processes and artifacts, and facilitate cross-agency knowledge-sharing of cybersecurity compliance best practices. In addition, OMB should direct GSA to establish a Steering Committee representative of the Federal Government that leverages the expertise of agency Chief Information Security Officers (CISOs), Deputy CISOs, and Chief Data Officers (CDOs) as well as representatives from the National Institute of Standards and Technology (NIST) and the Department of Homeland Security (DHS) Cybersecurity and Infrastructure Security Agency (CISA).
The CCCE Steering Committee will research potential paths to propagate compliance as code that are not overly burdensome to agencies, deliberate on these initiatives, and guide and oversee agency innovations. The ultimate goal for the Steering Committee will be to devise a strategy and series of practices to increase compliance as code adoption via the Cybersecurity Compliance Center of Excellence and OMB oversight.
The following sections detail potential opportunities for CCCE Steering Committee investigation and evaluation:
Study IT System Acquisition Rules for Vendor Compliance Information. The Steering Committee should review existing acquisition guidance and consider drafting a new acquisition rule that would require software vendors to provide ATO-relevant, machine-readable compliance information to customer agencies. The data package could include control implementation statements, attestation data and evidence guidance for the relevant NIST controls.4 In addition, the new system and process improvements should be agile enough to allow the incorporation of controls unique to a particular application or service.
Shifting the responsibility of managing compliance information from agencies to vendors
saves time and taxpayer dollars spent in the duplicative discovery, creation, and maintenance
of control implementation guidance for common software. The rule would be doubly
effective in time saved if the vendor’s compliance data package has common reciprocity
between agencies, allowing for faster adoption of software government wide.5 Finally, the
format of the data package should be open sourced, fungible and accessible.
Examine and Improve the Utility of System Security Plans (SSPs). System Security Plans are the baseline validator of a system’s security compliance and a comprehensive summary of an IT system’s security details.6 OMB and the CCCE Steering Committee should direct agencies to investigate the reusability and transmutability of System Security Plans (SSPs) across the Federal Government. A research-focused task force, composed of federal data scientists, compliance subject matter experts, auditors, and CISOs, should research how SSPs are utilized and draft recommendations on how best to improve their utility. The research task force would collect a percentage of agency SSPs, compare time-to-ATOs for various government organizations, and develop a common taxonomy that will allow for reciprocity between government agencies.
Create a Federal Compliance Library. The Steering Committee should investigate the creation of an inter-agency Federal Compliance Library. The library, most likely hosted by NIST, would support cross-agency compliance efforts by offering vetted pre-sets, templates, and baselines for various IT systems. A Federal Compliance Library accelerates the creation and sharing of compliance documentation and allows for historical knowledge and best practices to have impact beyond one agency. These common resources would free up agency compliance resources to focus on authorization materials that require novel documentation.
Explore Open Security Controls Assessment Language (OSCAL). The Steering Committee should explore the value added by mandating the conversion of agency SSP components to machine readable code such as Open Security Controls Assessment Language (OSCAL).7 OSCAL allows for the automated monitoring of control implementation effectiveness while making documentation updates easier and more efficient.
Conclusion
Federal compliance processes are ripe for innovation. The current system is costly and perpetuates risk while trying to control for it. The Plan of Action detailed above creates a crossagency collaborative environment that will spur localized innovations which can be tested and perfected before scaling government wide.
The research community lacks strategies to incentivize collaboration on high-quality data acquisition and sharing. The government should fund collaborative roadmapping, certification, collection, and sharing of large, high-quality datasets in life science.
In anticipation of future known and unknown health security threats, including new pandemics, biothreats, and climate-related health emergencies, our answers need to be much faster, cheaper, and less disruptive to other operations.
To unlock the full potential of artificial intelligence within the Department of Health and Human Services, an AI Corps should be established, embedding specialized AI experts within each of the department’s 10 agencies.
The U.S. government should establish a public-private National Exposome Project (NEP) to generate benchmark human exposure levels for the ~80,000 chemicals to which Americans are regularly exposed.