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Tag: FedRAMP

New GSA requirement – attest to software safety

According to a recent GSA memo, software vendors will be required to ensure that only approved software is acquired and used by GSA. GSA plans to use a Cybersecurity and Infrastructure Security Agency form to collect the letters. The forms will be available in early June. (FEDSCOOP February 1, 2023)

The Cybersecurity and Infrastructure Security Agency (CISA), Chief Jen Easterly recently urged industry to take responsibility to ensure the safety of its products. The CISA Chief also recommended shareholders make sure c-suite executives are viewing cyber risk as a board-level issue. (ibid)

GSA is collecting the letters of attestation in an effort to implement a memo signed by the White House. The memo requires all federal agencies to verify that all distributed third-party IT software adheres to the National Institute of Standards and Technology (NIST) supply chain security requirements. (ibid)

The Federal Acquisition Council has under consideration, embedding the requirement for software providers to attest to the security of their products within the Federal Acquisition Regulation (FAR). (ibid)

According to the memo, “GSA’s acquisition regulations (GSAM 511.170(d)) require GSA’s Information Technology (IT) Office to approve new software before its use at GSA. To comply with Executive Order 14028 and OMB Memorandum M-22-18, which require federal agencies to only use software that complies with Government-specified secure software development practices, GSA IT will update its processes to approve software including requiring vendor attestations. GSA IT anticipates issuing an updated attestation process by June 12, 2023.” (Memorandum for the GSA Acquisition Workforce 1/11/23)

The memo also states, “Contractors providing GSA with a cloud-based solution are encouraged to work with the Federal Risk and Authorization Management Program (FedRAMP). The FedRAMP approval process will streamline the GSA IT Standards Process allowing for a timely contract start. GSA also anticipates that leveraging FedRAMP will ensure and streamline compliance with the requirements of OMB Memo M-22-18 in the future.” (ibid)

Have questions or need some guidance with your letter of attestation? Give us a call.

Improved FedRAMP

A new and improved FedRAMP now awaits users. The updated website is largely based on feedback from users and gives an in-depth description of the authorization process, enabling Cloud Service Providers and Third-Party Assessment Organizations a more user-friendly way to access relevant information on their role in the FedRAMP Authorization process. (FedRamp.gov February 16, 2021)

A few of the fundamental features include:

  • Authorization Process – the homepage highlights an interactive graphic to give participants a better understanding of the steps involved in the process of the various Authorization paths
  • Program Basics – this new page to FedRAMP details the mission, history, goals, and legal framework of FedRAMP
  • Documents and Templates – a new searchable function within FedRAMP
  • FAQs – functionality enabling participants to search for answers to the most common questions
  • Site notifications – participants are notified of updates, additions, and new blog postings
  • Enhanced Marketplace – design and accessibility and performance updates (ibid)

GSA plans to use web analytics and ongoing feedback to evolve the website over time to meet users’ needs.

Have questions about the new FedRAMP website? Give us a call.

Line Item: Cybersecurity

We knew it would eventually happen. DoD is finally looking to permit cybersecurity costs as “allowable” on certain types of government contracts. (Federal News Network, June 2019)

Katie Arrington, the special assistant to the Assistant Secretary of Defense for Acquisition for Cyber in the Office of the Under Secretary of Acquisition and Sustainment in DoD, recently spoke at the Professional Services Council (PSC) gathering in Virginia. Ms. Arrington is the lead for the DoD effort to develop and institutionalize the new Cybersecurity Maturity Model Certification (CMMC) standard for vendors. She told attendees that she wants to enact a legitimate standard for cybersecurity allowable costs. (ibid)

During a recent webinar, Arrington spoke about cyber attacks and the need for the defense industrial base to defend themselves against nation-state attacks. DoD is aiming at not just it’s 200,000 prime contractors but all vendors (approximately 300,000) that comprise the DoD supply chain. (ibid)

Arrington is working with the Johns Hopkins University Applied Physics Lab and Carnegie Mellon University’s Software Engineering Institute to generate initial requirements. The draft will require DoD vendors to be certified through third-party assessment organizations. The standard incorporates existing requirements from NIST, the Federal Risk Authorization Management Program (FedRAMP), and other models.  (ibid)

Arrington expects DoD to carry out 12 webinars across the country over the summer. She aims to receive feedback from industry experts with a draft standard by the end of summer and third-party assessors to start certifying vendors in January. (CMMC requirements will be added to requests for information by June of 2020 and become a standard in solicitations by September 2020.) (ibid)

According to Alan Chvotkin, senior vice president and general counsel for PSC, the certification of contractors will be a very competitive discriminator in the marketplace. His main concern is whether DoD will only certify the big six contractors and what is going to take place for the prime and a subcontractor. (ibid)

Congress recognizes that risks to the supply chain need to be reduced. The Senate version of the 2020 National Defense Authorization Act, includes a provision requiring DoD to move to a broader cybersecurity standard with its contractors. Currently, DoD mandates defense contractors meet the requirements of NIST Special Publication 800-171; however, there is no current audit for compliance. Oversight of subcontractors by prime contractors is also a reasonable concern as is the lack of information available on subcontractors. The committee feels prime contractors should be held responsible and accountable for securing DoD technology and sensitive information and ultimately delivering uncompromised products and capabilities. This is seen as a first step in securing the supply chain. (ibid)

The Senate Armed Services Committee (SASC) believes DoD should provide direct technical assistance to contractors, based on risk, and in such a way as to not harm the industrial base while at the same time providing incentives/penalties for non-compliance of vendors’ cyber performance. DoD is being asked to provide the SASC with a briefing by March of 2020 and quarterly briefings on how the standard is being implemented by both vendors and the DoD. (ibid)

Although security has always been an allowable overhead cost, it will now be used as an incentive to get vendors to more quickly align themselves to the CMMC standard. The incentive doesn’t force companies to trade off security for other expenses. It appears the government will offer some reimbursement for some share of the cost, hopefully bringing all vendors up to the same level. (Firm-fixed-price contracts do not fall under the allowable cost umbrella in the same manner, as cyber is counted as general overhead in the final cost to the government.) (ibid)

Eager to learn a little more about the cyber standard and how it might affect your current contract or an upcoming bid? Give us a call at 301-913-5000.

 

 

We See the Future and it is … Single Sign On

By now you’ve likely heard of Single Sign On (SSO). It’s not exactly new, and it’s currently used by just a few agencies, but it is the wave of the future as agencies move to more cloud-based apps. In fact, 6 U.S. Code § 1523(b)(1)(D), a provision of law governing federal cybersecurity regulations, states that agency heads must “implement a single sign-on trusted identity platform for individuals accessing each public website of the agency that requires user authentication.” This provision was created by GSA working with the Department of Homeland Security. (FedTech, May 24, 2019)

What exactly is SSO? SSO allows a user to sign in one time with one high-strength password and access all that specific user’s authorized applications. With SSO, a user need not memorize a different password for each and every application they access. SSO uses the Security Assertion Markup Language protocol that gives the user the ability to log on once for affiliated but separate websites. According to Tracy David, a cloud client executive at CDW, SSO uses “highly complex encrypted keys, which the end user has no access to view or change.” Ultimately, this makes for a much higher level of security for each agency. (ibid)

At this time, you must log in to each app with a different password. More often than not, passwords across applications are similar (if not the same) and easily remembered. This weakens the security level of the agency as stolen credentials account for roughly 80 percent of breaches. With SSO, you have one complex, single-sign-on password protected with multi-factor authentication.  (ibid)

Many agencies are still using on-premises SSO, which will be more difficult as apps move to the cloud. Insiders believe that the Defense Department’s forthcoming Joint Enterprise Defense Infrastructure cloud contract signals cloud adoption becoming the “norm” in government.

Questions about how this affects your current government contract, or how you might work with the government on SSO Technology? Give us a call at 301-913-5000.