Background on the Risk Management Process
The steps in the process are as follows:
Step 1: Categorize Information System
The information systems’ owner, working with the AO, categorizes the system based on the potential impact on the organization if the information system, or the information within it, is jeopardized. The system will end up with a category of low, moderate or high, based on criteria described in FIPS Publication 199, which is summarized here.
Step 2: Select Security Controls
The information system’s owner, working with the AO, decides which controls should be implemented. NIST’s encyclopedic Special Publication 800-53 (currently on revision 4) is the definitive guide to security and privacy controls for federal information systems. Which controls are selected is based on the following:
- The impact level of the system (low, moderate or high). SP 800-53 provides a “baseline” set of controls for each level. The higher the level, the more controls or control enhancements are in scope. For systems running on cloud infrastructure, you should consult FedRAMP’s security control documentation.
- Which controls are already taken care of by your infrastructure. If you’re running in the cloud, many controls are taken care of at the infrastructure or platform layer. If your provider has received a FedRAMP P-ATO, it will provide a document called a customer responsibility matrix (CRM) or control implementation summary (CIS) listing the residual or hybrid controls that are the responsibility (or partial responsibility) of the applications running on the infrastructure or platform.
- What type of ATO you want to receive. The GSA provides a “lightweight” ATO process designed for pilot systems running on GSA authorized infrastructure, for which fewer controls are in scope.
- Tailoring. The information system owner, working with the AO and the agency’s information security team, can then add, remove or modify controls to achieve cost-effective, risk-based security, based on the agency’s mission or business need.
This step should happen as an integral part of any system design activities. The team should also develop a monitoring strategy to ensure that security controls continue to be effective once the system receives its authority to operate. The results of this step of the RMF are documented in a System Security Plan, or SSP. SSP templates are available for both GSA LATOs and FedRAMP ATOs.
Step 3: Implement Security Controls
As part of system development work, controls are implemented. The implementation is documented in the SSP.
Step 4: Assess Security Controls
Before your system can go live with government information, your contol implementation must be tested. Testing is often performed by the development team and infrastructure team working together with the agency’s information security team, based on a security assessment plan. The security assessment plan will depend upon the type of ATO. FedRAMP has a Security Assessment Framework for FedRAMP ATOs, as does the GSA for its LATOs.
The results of the assessment are documented in a security assessment report (SAR). Depending on the findings of the security assessment, remediation work may have to take place before the system receives its ATO. Other problems that are less critical can be remediated at a later date: these are listed in a document called a plan of action and milestones (POAM or POA&M). POAM templates are available for both GSA LATOs and FedRAMP ATOs.
Step 5: Authorize Information System
The SSP, SAR and POAM together form a security authorization package (FedRAMP requires a further document: a continuous monitoring strategy). The Authorizing Official will make a risk-based decision whether to grant an ATO based on the information in this package. This decision, made in consultation with other key stakeholders such as the CISO, balances security considerations with the mission and operational needs of the agency. If an ATO is granted, an authorization decision document is issued and signed by the AO which lists the conditions under which the ATO will remain valid, including the ATO’s expiry date.
Step 6: Monitor Security Controls
Once a system receives an ATO, it must be assessed at regular intervals to ensure the effectiveness of the control implementation. Any changes to the system’s security boundary or its environment should also be assessed to determine their impact.
An introduction to compliance
For an introduction to compliance for federal information systems, check out this video by 18F’s Aidan Feldman.