A new report lays out where FedRAMP has gone wrong – and what can be done to fix it.
A new report argues that the Federal Risk and Authorization Management Program must evolve to better automate its laborious processes for approving cloud service providers and adapt to emerging technologies like Internet of Things and artificial intelligence.
The report by the Center for Cybersecurity Policy and Law, a trade association run out of the Washington D.C, law firm Venable, draws on documents and interviews with federal agencies and cloud service providers who have worked with FedRAMP. It characterizes the current state of the program as "well intended and partially successful" but also "no longer optimized for modern security solutions."
Government bureaucracy comes in for blame as one of the primary barriers to improving FedRAMP's speed and capacity. The report notes that multiple stakeholder, including the Office of Management and Budget, the National Institute of Standards and Technology, the Department of Homeland Security and Congress that have some role in how the program operates.
Program managers for FedRAMP have "worked diligently to balance its limited authority and resources against a CSP environment that has grown in scale and capability and a policy landscape that has been in flux," the authors wrote. However, "the current system is failing to keep pace with growth and change in commercial capabilities."
The report also argues that FedRAMP in was designed for legacy IT environments and is ill-suited for the increasingly complex security add-ons for cloud products as well as emerging technologies like connected IoT devices and artificial intelligence, which are nevertheless becoming more integrated and relevant to government cloud environments.
Add those problems up and you get something very close to what federal IT leaders have been saying about the program for years: it's simply too slow and does not have the capacity to meet demand among federal agencies.
"Because of the way the program is structured, the joint authorization board really right now can only review about three CSP packages per quarter," said John Banghart, Senior Director for Technology Risk Management at Venable, at a Feb. 21 event centered around the report's release. "That's not a lot, particularly given with the way the landscape is expanding, with the amount of companies that are introducing cloud services and cloud products."
The report recommends that government should redefine federal IT risk management and emphasize automated and continuous monitoring. This could be accomplished by identifying controls that are ripe for automation, developing automated standards for security assessments, aligning FedRAMP's assessment framework with NIST's Cybersecurity Framework and developing real-time dashboards to monitor cloud environments.
The government should also look for ways to consolidate and standardize risk acceptance processes across government. This was, after all, the primary problem FedRAMP was created to solve in the first place. The authors advocate for consolidating cloud ATOs processes into one place, perhaps a shared service center, group together agencies with similar risk profiles to make cross-agency ATO acceptance more seamless and develop clear guidelines for reciprocity.
Finally, the government should leverage emerging innovations in cloud and technology markets. This can be achieved through standard configurations for IT environments and components, compliance pathways for service providers looking to sell new technologies to the government.
"The broad message of the administration today that I'd like to share is that we hear you, we're listening to your feedback and we see a tremendous opportunity to work with you to evolve this program so that it's a framework not only that works today…but can really meet the needs of the next generation of technological innovation," Matthew Lira, White House Special Assistant to the President for Innovation Policy and Initiatives said at the event.
Anil Cheriyan, Deputy Commissioner of the General Services Administration's Federal Acquisition Service and Director of the Technology Transformation Services, who also spoke at the event, told FCW that he was not prepared to endorse any of the specific recommendations at this time.
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