Save the dates: The IT Modernization Report's many deadlines

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The American Technology Council on Dec. 13 released its final Report to the President on Federal IT Modernization, a little more than three months after the draft version was circulated for public comment.

The wide-ranging plan touches on shared services, Trusted Internet Connection (TIC) policies, the security of high-value assets (HVAs), acquisition of network services and various aspects of cloud migration. ATC Director Chris Liddell and Office of Science and Technology Policy Senior Policy Advisor Jack Wilmer, who headed up the effort, said the feedback from "more than 100 companies and individuals" was considered during the revision process.

Both the original draft and the final report have drawn cautious praise, as the report pulls together (and puts White House support behind) multiple recommendations that have long been discussed in the federal IT community. Trey Hodgkins, senior vice president of the industry group IT Alliance for the Public Sector, called the report's completion "a step in the right direction to begin an overhaul of the archaic IT that costs tax payers $60 million a year to maintain."

Subsequent steps, however, require action from across the executive branch, and the report outlines dozens of recommended actions and deliverables over the next year. Assuming President Donald Trump accepts the recommendations, below are the highlights of what's required of whom in the months to come.

By Jan. 31, 2018

  • The National Institute of Standards and Technology is to provide the Office of Management and Budget with a plan to "promote a risk management culture that focuses agency effort on the operational performance and compliance of their most valuable systems," while allowing lower-impact systems to operate in a "less burdensome and less costly manner."
  • OMB is to conduct data calls to agencies for information on their cloud migration projects, with particular emphasis on delays caused by current TIC policy and projects that can be migrated securely but have run into difficulties, real or perceived.
  • OMB is to gather data on agencies' current email contracts, and convene an inter-agency task force to "finalize a standard set of requirements for cloud email."

By March 2, 2018

  • The Department of Homeland Security is to report on "common areas of weakness" in government high-value assets.
  • NIST is to provide OMB with a plan to "improve cryptographic agility in the Federal enterprise."
  • The American Technology Council is to review agencies' cloud migration reports and "bucket them into three categories:" low-risk systems that should migrate immediately; high-priority systems that present a level of risk that requires external assistance; and high-risk systems that should not be migrated until further policy or capability enhancements are made.
  • OMB is to issue a "preliminary update to the TIC policy," lead a 90-day sprint to have select pilot projects test the new TIC requirements, and "establish a comprehensive strategy" for accelerating the migration of email and collaboration tools to the cloud.

By March 17, 2018

  • OMB is to issue updated identity policy guidance for public comment and recommend identity service areas suitable for shared services.

By April 1, 2018

  • OMB is to update its annual metrics for FISMA and cybersecurity cross-agency priority goals.
  • Low-risk cloud migration projects are to be given approval to begin. DHS, OMB, the General Services Administration, the National Security Council "and other relevant parties" are to launch a 90-day sprint focused on the high-priority systems that require assistance.
  • GSA, DHS, OMB and agencies with systems deemed currently un-migrate-able are to determine whether new offerings from cloud service providers could deliver some of the needed functionality. Those findings would be used by the FedRAMP program office to prioritize assessments of new cloud service offerings.
  • GSA is to "work with volunteer agencies" on pilots to improve the authority to operate (ATO) process for cloud-based SaaS and shared services.
  • GSA is to develop a "comprehensive acquisition strategy" to help small agencies utilize EIS services; determine whether the Managed Trusted Internet Protocol Services (MTIPS) baseline should be revised; identify opportunities outside EIS for improving agency cybersecurity; and explore the idea of a "centralized acquisition support function with GSA" for cybersecurity services.
  • OMB is to form an "Acquisition Tiger Team" tasked with creating a "quick start" acquisition package to streamline license and migration service acquisitions.

By May 1, 2018

  • OMB and DHS are to develop a strategy for reducing the risk to HVAs, including the lines of authority and operating procedures required to do so.
  • OMB is to update the Federal Cloud Computing Strategy that was first released in 2011.
  • OMB, GSA, DHS and the Federal Acquisition Regulatory Council are to develop clauses "that define consistent requirements for security, privacy, and access to data for use in cloud contracts." (Note: the report lists both a 120-day and 180-day deadline for this action. White House officials were not immediately able to clarify the duplication.)

By May 6, 2018

  • DHS is to obtain an initial ATO for the CDM Group F Platform, leveraging "all available departmental resources" to do so, and to submit a plan for bringing all non-CFO Act agencies onto that platform.

By May 31, 2018

  • Agency CIOs, chief information security officers and senior agency officials for privacy are to review and revise their submissions on HVAs, making sure that their system prioritizations and risk assessments are current.
  • DHS is to complete the data exchanges need to provide "enterprise-wide situational awareness of an agency's cyber posture."

By June 30, 2018

  • DHS, OMB and the National Security Council are to review agencies' HVA lists and produce a prioritized list of systems for governmentwide intervention, picking six to receive centralized staffing and technical support.
  • Agencies are to develop remediation plans for all HVAs that have major or critical weaknesses.
  • DHS, GSA and OMB are to deliver "rapid draft updates to the TIC policy."
  • OMB is to create teams of IT and acquisition specialists to help "early adopter agencies" with their license and migration acquisition efforts.
  • DHS and the CIO Council are to "implement a concept of operations for the Federal dashboard" to better manage cyber risk.
  • OMB, DHS and GSA are to identify opportunities to provide "Security Operations Center as a Service" to federal agencies.

By July 30, 2018

  • Agencies seeking to offer "SOC as a service" capabilities are to provide OMB and DHS with a pricing model and other details.

By Aug. 29, 2018

  • OMB and GSA are to "pilot new acquisition tactics for cloud email and collaboration licenses."

By Jan. 1, 2019

  • OMB, DHS and GSA are to develop a playbook for the protection of HVAs.

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