Network Modernization & Consolidation

Summary of Efforts to Date

The Federal Government has engaged in several efforts to modernize existing IT systems, to improve processes for the acquisition and development of new solutions, and to restructure underlying frameworks for service and lifecycle management. The E-Government Act of 2002 recognized the importance of a well-managed, modern, and secure Federal IT ecosystem, building upon concepts captured in the Clinger-Cohen Act, the Paperwork Reduction Act, and OMB Circular A-130, Managing Information as a Strategic Resource.1 Additionally, the Federal Information Security Management Act of 2002 and its reauthorization in 2014 serve as the governing authority for OMB to provide overall guidance and policy for Government-wide Federal cybersecurity.

Pursuant to these authorities, OMB established the IT Infrastructure Optimization Line of Business, which developed common Government-wide performance measures for service levels and costs, identified best practices, and provided guidance for agency IT infrastructure transition plans. An Enterprise Architecture and Centralizing Infrastructure was constructed some years later, and in 2010, the Federal Data Center Consolidation Initiative (FDCCI) directed agencies to inventory their data centers, develop consolidation plans, and assess virtual or cloud alternatives.2

Between the launch of the FDCCI and its conclusion in 2015, the Cloud First Initiative and the Federal Risk and Authorization Management Program (FedRAMP) was activated in 2011 with FedRAMP providing a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services. Driven by the momentum of these and other efforts, in 2016 the Data Center Optimization Initiative arose as an update to the FDCCI based on requirements of the Federal IT Acquisition Reform Act (FITARA).3 These efforts have helped agencies to begin modernizing their IT. This report is intended to help resolve some of the impediments surfaced throughout implementation of these efforts and accelerate Federal IT Modernization.

Current State

In recent years, Government-wide initiatives and policies have focused on the transition to a more efficient, more secure, and customer-focused IT environment. The preponderance of efforts to protect Federal IT systems to date have been focused at the network level. This drove agencies to consolidate human and technical resources around a limited number of connections and standardized physical access points, with the intent of producing more robust security management.

Current policy, agency prioritization, and associated investments prioritized through the budget process have emphasized perimeter network-based security protections. This is manifested most visibly through the Trusted Internet Connections (TIC) and National Cybersecurity Protection System (NCPS) programs.4 This report recommends emphasizing a layered defensive strategy in Government-wide programs, through increasing emphasis on application and data-level protections. This shift in focus, coupled with lessons learned from the current implementation and advances in technology will drive strategic changes to the NCPS program, as described in Appendix C. It will also provide greater defense-in-depth capabilities that will help prevent malicious actors from moving laterally across linked networks to access large amounts of valuable information.

These well-intentioned initiatives have resulted in security implementations that negatively affect performance and create barriers to use of commercial technology. As an example, policy and existing implementation of enterprise cybersecurity tools drives the physical consolidation of all network traffic to and from Federal information systems. This hampers agencies’ ability to acquire new technologies like commercial cloud, which rely on a distributed network model and emphasize optimization of virtual rather than physical controls of data. In this case, policies and supporting capabilities which require routing all traffic through a limited number of on premise access points not only impacts service performance and availability, but it also undermines the value proposition of a distributed cloud architecture and flexible mobile access to services.

Consequently, in order to successfully meet their mission and business objectives, agencies often circumvent network-based security protections to use commercial cloud. Another negative consequence of overreliance on network-based protections is the emergence of operational capability gaps at other levels, such as the data and application levels. This has resulted in overlooked areas of the IT ecosystem, which are more vulnerable and at higher risk of attack or exploit.

Additionally, when individual agencies issue agency-specific IT contracts, they reinforce the current emphasis on boundary protections and limit opportunities for applying economies of scale in provisioning common network and security services for the Federal Government. Small agencies, especially, often lack staff resources and technical expertise to securely manage existing networks, migrate to new computing models, and navigate security acquisition processes. Enabling a new approach to modernization and consolidation of networks requires a strategy that addresses each of these challenges with associated recommendations for legal, policy, resource allocation, acquisition, and workforce interventions, as detailed further below.

Future State & Objectives

The future of Federal IT is one in which agencies move further toward a risk-based approach to securing their systems that places appropriate emphasis on data-level protections and that fully leverages modern virtualized technologies. This renewed focus on data-level protections for managing risk must be accepted and driven by agency leadership, mission owners, IT practitioners, and oversight bodies. Specific recommendations that will bridge to this future state are detailed in the next section, titled “Implementation Plan.” The following broad objectives will drive momentum toward the future state of IT:

Reduce the Federal attack surface through enhanced application and data-level protections.

Rather than treating Federal networks as trusted entities to be defended at the perimeter, agencies should shift their focus to placing protections closer to data, specifically through improved management and authentication of devices and user access, as well as through encryption of data – both at rest and in transit. This approach curtails an attacker’s likelihood of gaining access to valuable data solely by accessing the network, and it has the potential to better block and isolate malicious activity. As agencies prioritize their modernization efforts, they should implement the capabilities that underpin this model to their high value assets first.

Improve visibility beyond the network level.

Agencies will gain greater visibility and resilience against more sophisticated attacks, including insider threats that may have access to agency-owned networks by enhancing protections closer to the data. Expanding visibility beyond the network level – for instance, through collecting security logs at the application level – provides security teams with other information feeds, which they can use to better understand, process, and triage information security events and possible incidents. This information can provide insight into the gaps in security that agencies are experiencing, which informs the types of investments they should make to defend against modern threats. Maximizing the effectiveness of this approach requires updating tools and models by which staff conduct operational security to detect and prevent intrusions. It also requires risk proportionate application of security practices and maintenance of situational awareness, particularly in scenarios in which Federal information resides in an off-premises environment, such as in commercially-provided clouds. Government-wide programs designed to deliver these tools and services must evolve, as must the operational culture by which agencies collect and analyze logs.

Ensure that policy, resource allocation, acquisition, and operational approaches to security enable use of new technology without sacrificing reliability or performance.

Information Technology policy, resource allocations, acquisition processes, and operational guidance must enable the achievement of security objectives while also allowing agencies to take advantage of newer approaches to technology, such as commercial cloud-based services and mobile devices. Agencies should prioritize the IT resources and technical personnel they need to implement necessary data protections and provide situational awareness in their daily operations. This must be done regardless of whether information is stored on premises or in a commercial cloud. While some successes have occurred in the Federal Government, many real or perceived impediments remain to accelerating network consolidation and optimization on a Government-wide scale. The recommendations in this report collectively address and seek to remedy impediments to modernizing Federal IT. Addressing these barriers will enable agencies to accelerate toward a new era of modernization without sacrificing security or performance.

Implementation Plan

This section outlines immediate next steps and long-term considerations related to the modernization of Federal networks. The focus areas below accelerate Federal efforts on three core concepts: (1) prioritizing high value assets; (2) adopting security frameworks that better protect systems at the data level; and (3) consolidating and standardizing network acquisitions and management wherever possible.

1. Prioritize the Modernization of High-Risk High Value Assets (HVAs)

The HVA Initiative, beginning in 2015, was a seminal step in helping the Federal Government recognize, categorize, and prioritize modernization and security improvements for the primary benefit of its “crown jewel” systems.5 The implementation plan outlined below goes a step further by recommending specific policy, resource allocation, and other interventions to provide near-term assistance to agencies as they strengthen their ability to protect these assets, which are susceptible to the greatest amount of cybersecurity risk. It leverages the current ATC supported efforts to improve the Authority to Operate (ATO) process, and it corresponds with the direction set forth in Section 1 of EO 13800, which mandates that all agencies perform a risk assessment and identify areas in which additional attention is needed. This is consistent with agency responsibilities under FISMA.

Simply applying the next set of patches to these systems and tacking on additional tools is no longer sufficient; rather, HVAs must be driven toward implementation of modern architectures that are based on data-level protections. Systems that are most important to the Federal Government, yet are also most vulnerable, should be addressed first.

Next steps to support this recommendation are as follows:

Immediate Action:

It is recommended that the President direct the implementation of the plan outlined below to improve the security of high-risk HVAs by migrating to a modernized architecture and employing security best practices.

Upon Approval of the President and within a Timeline of 30 Days:

Consistent with relevant portions of the enterprise risk management plan to be developed pursuant to Section 1(c)(iv) of EO 13800, Commerce’s National Institute of Standards and Technology (NIST) will provide OMB 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 simultaneously allowing for the deployment of low-impact systems in a less burdensome and less costly manner. This plan will include a process and timeline for revising Federal Information Processing Standard (FIPS) Publication 199, Standards for Security Categorization of Federal Information and Information Systems, and FIPS Publication 200, Minimum Security Requirements for Federal Information and Information Systems. The plan should also include proposed updates to any other relevant NIST Special Publications (SPs) to enable and support improvements in agency risk management processes that lead to the appropriate selection, implementation, and continuous monitoring of controls and capabilities commensurate with the risk to information, systems, agency missions, and individuals. These updates should include the use of the NIST Framework for Improving Critical Infrastructure Cybersecurity (Cybersecurity Framework), and, where appropriate, incorporate lessons from other control and compliance frameworks, such as ISO, SOC 2 Compliance Audits, and Payment Card Industry. These updates should review the security requirements for these other frameworks and system approval processes used, and assess the use of overlays of these frameworks as a viable approach and intended for inclusion into the proposed updates of the relevant Special Publications.

CIOs, Chief Information Security Officers (CISOs), and SAOPs will review their latest submission of HVAs to the DHS and OMB, and will make any necessary changes to reflect the latest information on system prioritization in tandem with the assessments made under their risk assessments as part of Section 1 of Executive Order 13800.

Upon Approval of the President and within a Timeline of 60 Days:

Consistent with Section 1(c)(iv)(B) of EO 13800, DHS, in consultation with OMB, will provide a report which identifies common areas of weakness in Government HVAs. The report will include recommendations for addressing these risks Government-wide, informed by agency risk assessments, as well as past and current Risk Vulnerability Assessments (RVAs), and Security Architecture Reviews (SARs) DHS has performed on various agency HVAs.

Upon Approval of the President and within a Timeline of 75 Days:

Consistent with Section 1(c)(iv)(B) of EO 13800 and in execution of independent statutory authorities, OMB, in consultation with DHS, will develop a strategy and framework for an approach that clearly describes the lines of authority and operating procedures necessary to optimally leverage resources across agencies in order to reduce the risk to the Federal enterprise in response to cybersecurity incidents. These efforts should align with the plan to adequately protect the executive branch enterprise in response to agency risk management reports, per Section 1.c.iv of EO 13800.

Pursuant to its statutory authorities and in execution thereof, OMB will update the annual FISMA metrics as well as the Cybersecurity Cross-Agency Priority (CAP) Goal metrics to focus on those critical capabilities that are most commonly lacking among agencies. OMB will focus oversight efforts, including CyberStat Reviews and President’s Management Council (PMC) Cybersecurity Assessments, on driving progress on these capabilities, with a specific focus on HVAs.

DHS, in consultation with OMB will direct Government-wide mitigation actions to address common areas of risk identified in the Report to the President on Risk Management in accordance with their authorities under FISMA and other relevant statutory authority.

Upon Approval of the President and within a Timeline of 80 Days:

Consistent with the current HVA Program that is administered by DHS and overseen by OMB, any agency that has an HVA that has been identified as having a major or critical weakness in either a risk assessment, RVA, SAR, or Inspector General (IG) report will identify a remediation plan, including a proposal for accelerating modernization within one year and identification of impediments in policy, resource allocation, workforce, or operations. This plan should maximize use of shared IT services, implement application and data-level protections, and emphasize appropriate use of commercial cloud-based architectures. Specific recommendations for modern security approaches are detailed in Appendix A. Agencies should prioritize existing financial and human resources and should identify other systems of concern that may suffer from similar issues, but that are not categorized as HVAs.

Upon Approval of the President and within a Timeline of 100 Days:

DHS, OMB, and the National Security Council (NSC) will review HVA lists submitted to DHS by Federal agencies and will produce a prioritized list of systems for Government-wide intervention. Six HVAs will be selected to receive centralized interventions in staffing and technical support, and the broader, prioritized list will be vetted by the PMC. Additionally, agencies will work with OMB to reallocate their IT resources appropriately in order to alight and appropriately resource the modernization of HVAs.

Where possible and subject to funding, OMB, through the U.S. Digital Service (USDS), and GSA will support DHS in providing hands-on technical assistance to agencies in bolstering protections for systems identified through this process as having the greatest need for modernization.

Additionally, DHS will work to expand the availability of RVAs and SARs for agency HVAs. OMB will also work with DHS to refocus these assessments to concentrate on hands-on technical engineering interventions, de-emphasizing the review of system documentation and policies. In addition, OMB and DHS will work with GSA to expand the visibility, offerings, and agency use of the Highly Adaptive Cybersecurity Services Special Item Numbers (HACS SINs) on IT Schedule 70.

Upon Approval of the President and within a Timeline of 365 Days:

Pursuant to its statutory authorities and in execution thereof, OMB, will work with DHS, GSA, and other stakeholders to capture standard operating procedures for the protection of HVAs and will develop a playbook that agencies can leverage to expand this approach to other systems in a prioritized, risk-based fashion in accordance with FISMA.

2. Modernize the Trusted Internet Connections (TIC) and National Cybersecurity Protection System (NCPS) to Improve Protections, Remove Barriers, and Enable Commercial Cloud Migration.

The perimeter-based security model employed by Federal agencies today, formalized in OMB Memorandum M-08-05, Implementation of Trusted Internet Connections (TIC), focuses on standardizing security at the network boundary by consolidating external access points. Under this model, agencies are required to reduce external connections to a target of 50 and route their traffic through this limited number of secure gateways. These gateways apply common security protections, as well as common intrusion detection, information sharing, and prevention capabilities under DHS’s NCPS. NCPS consists of three sensor capabilities, collectively referred to as EINSTEIN, as well as a set of analytic tools used by cyber analysts to find, identify and categorize cyber threat activity.6

The NCPS sensor suite is deployed in three iterations: EINSTEIN 1, which captures and analyzes network flow information; EINSTEIN 2, which incorporates intrusion detection technology that scans the content of network communications to identify and alert to known indications of malicious activity; and EINSTEIN 3-Accelerated (E3A), which detects and blocks malicious activity through domain name systems (DNS) sinkholing and email filtering. The TIC policy, and subsequently the Federal Cybersecurity Enhancement Act of 2015, requires agencies to utilize these capabilities, which are currently provided through NCPS, to protect all information traveling between an agency information system and any external information system.7 This perimeter-based model sought to provide a means to aggregate all Federal Executive Branch traffic so that the Government can apply common methods, such as classified indicators, to protect against information security threats, and maintain consistent situational awareness.

This approach of perimeter-based network security has created several challenges for agencies wishing to take advantage of commercial cloud services.8 DHS recognizes these challenges, and has articulated initial steps toward addressing these specific challenges in Appendix C of this report. DHS will provide recommendations on how the NCPS and Continuous Diagnostics and Mitigation (CDM) programs can be updated to enable a layered security architecture that facilitates transition to modern computing in the commercial cloud.

Next steps to support this recommendation are as follows:

Immediate Action:

It is recommended that the President direct the implementation of the plan outlined below to accelerate secure use of commercial cloud through the modernization of the NCPS Program and TIC capabilities, policies, reference architectures, and associated cloud security authorization baselines. This effort will support the prioritization of security resources from lower-value assets to higher-value assets, enabling agencies to build out data-level protections in furtherance of a layered security architecture, and directly accelerating commercial cloud adoption. This effort will be driven by agency use cases, which will also be used to inform rapid updates to policy. This modernization effort will prioritize work to focus on cloud-ready projects and target agencies struggling to comply with the TIC policy and cloud adoption efforts to provide more immediate relief. The goal is to accelerate migration on three cloud-ready systems within the next year. OMB will codify this plan in an initial update to TIC policy, to provide agencies clear direction on the path forward. The entire process described below will be overseen directly by the ATC, including weekly status updates to the Director of the ATC regarding progress.

Upon Approval of the President and within a Timeline of 30 Days:

Pursuant to its statutory authorities and in execution thereof, OMB will submit a data call to agencies requesting submission of both in-progress and pending projects for cloud migration. Agencies should focus submissions on projects that have experienced delays due to constraints in current TIC policy and NCPS program implementation, and should propose a migration plan that, highlights needed changes to requisite policies and capabilities to facilitate faster migration.

Upon Approval of the President and within a Timeline of 60 Days:

The ATC, supported by GSA, will include the FedRAMP PMO and the Technology Transformation Service (TTS), DHS, OMB to include USDS, NSC, and other relevant parties will review these submissions and bucket them into three categories:

  1. Systems that are sufficiently low risk to migrate to cloud immediately. These systems will be migrated to the cloud, and lessons learned will be captured and used to pilot further changes to existing policy. These systems will also be the focus of additional updates to the FedRAMP baselines to explore further tailoring of controls for low-risk systems.9

  2. Systems that are high-priority cloud migration candidates but present a level of risk significant enough that external assistance is necessary to ensure secure migration. This will represent a small number of “implementation validation case studies” that will receive technical assistance in support of their migrations. Lessons learned from these case studies will be used to inform new approaches to TIC and NCPS policy and operations.

  3. Systems that are such high risk that they should not be migrated until further policy direction is given or capability enhancements are made. These systems will be assessed to evaluate whether there are common features or capabilities that could be provided efficiently, effectively, and securely by cloud service providers (CSPs). This analysis will serve as an input to the FedRAMP Joint Authorization Board (JAB) prioritization of high-baseline CSP offerings available to agencies wanting to migrate high impact data to the cloud.

To codify this approach, OMB will provide a preliminary update to the TIC policy that introduces a 90 day sprint during which projects approved by OMB will pilot proposed changes in TIC requirements and formalizes the approach outlined above and in the subsequent two sections.

Upon Approval of the President and within a Timeline of 90 Days:

  1. For Category 1 of projects above, agencies will be given approval to begin cloud migration by following their proposed migration plans. GSA, DHS, OMB, and NSC will require collection of metrics, which will be used to ensure that the proposed changes to policy, that do not introduce an unacceptable level of cybersecurity risk. Agency project teams would capture these metrics and lessons learned from these migrations and submit initial findings to GSA, DHS, and OMB. These inputs will inform changes to the TIC policy, Reference Architecture (RA), and NCPS operational model and outcomes and to further tailoring of the FedRAMP baselines. These activities will be undertaken within the understanding that agency heads still own the risk for the system authorizations and control decisions they are making.

  2. For category 2 projects above, GSA, DHS, OMB, NSC, USDS, and other relevant parties will kick off a 90-day sprint to validate particular case studies. The exact number of engagements will be driven by staffing considerations from these organizations, but will consist of at minimum three test cases. These case studies will be operational in nature, and will validate a subset of implementation plans for improving the TIC policy, RA, and NCPS operational model and outcomes in commercial cloud.

  3. For category 3 projects above, GSA, DHS, and OMB will work with agencies to evaluate whether there are common features or capabilities that could be provided efficiently, effectively, and securely by CSPs. This analysis will serve as an input to the FedRAMP JAB’s prioritization of high-baseline CSP offerings available to agencies wanting to migrate high-impact data to the cloud.

Upon Approval of the President and within a Timeline of 180 Days:

DHS, GSA, and OMB will use the information gathered from the activities listed in the section immediately preceding to inform rapid updates to the TIC policy, reference architectures (RA), and NCPS operational models to facilitate outcomes in commercial cloud. The updates will codify the findings from these case studies, as well as holistically address incentives and barriers for agencies in securely migrating to commercial cloud solutions. This update would at a minimum address the following issue areas:

3. Consolidate Network Acquisitions and Management

The current model of IT acquisition wherein each agency, and often multiple components within a single agency, purchase goods and services independently has contributed to a fractured IT landscape. This creates an inconsistent security posture and fails to maximize the buying power of the Federal Government. To alleviate this problem, the Federal Government is implementing category management principles to consolidate and standardize network and security service acquisitions to take full advantage of economies of scale, reduce burden, and dramatically improve technical development and operations.

Currently, GSA is transitioning agencies from the legacy Networx contract, under which agencies purchased $1.79 billion in network and telecommunications services in fiscal year (FY) 2016, to a comprehensive solution-based contract vehicle called Enterprise Infrastructure Solutions (EIS).10 The purpose of EIS is to address all aspects of agency telecommunications and network infrastructure requirements while also leveraging the bulk purchasing power of the Federal Government. EIS can be leveraged to help address some of the unique challenges faced by small agencies, a community that typically lags behind the large agencies in terms of cybersecurity capabilities.11 Smaller and non-CFO Act agencies struggle to attract and retain top information security personnel and often lack the expertise to fully manage their information security programs. This impedes the Federal Government’s ability to gain a full understanding of the risk to Federal networks. EIS can be leveraged to consolidate acquisition activities and other security services for small agency networks by focusing on the objectives below.

Reduce Wasteful Spending on Duplicative Security Capabilities. Under the current Networx contract, agencies who do not have their own TIC capabilities must procure TIC services by purchasing the full suite of Managed Trusted Internet Protocol Services (MTIPS) services,12 the bundling of which prohibits agencies from procuring only those tools they need, thereby increasing cost. EIS will allow agencies the flexibility to choose a la carte the managed security services tools they need to comply with MTIPS requirements, while still being protected by the intrusion detection and prevention capabilities DHS provides.13 Though a positive and cost-saving step for many agencies, some small agencies may still struggle to procure TIC-like capabilities in this manner due to the complexity of managing the procurement and integration of multiple vendors; however, when paired with the proposed revisions to the existing TIC policy and RA, agencies will be able to make cost-effective acquisition decisions based on their existing tools and overall risk tolerance.

Decrease Risk by Improving Situational Awareness of Managed External Network Connections to the Internet. Approximately 40 of the 102 small agencies supported by the Networx contract currently receive MTIPS services. The result of this gap in MTIPS capabilities is a lack of shared situational awareness regarding the network traffic traversing Federal network boundaries. This lack of awareness makes it difficult to conduct enhanced monitoring of network traffic and ultimately makes it harder to perform incident response activities. Increasing this visibility is critical to the defense of the .gov environment, and the additional flexibilities noted above will enable the remaining agencies to provide the requisite information.

Next steps to support the objectives outlined above are as follows:

Immediate Action:

It is recommended that the President direct implementation of the plan outlined below. This plan will leverage the consolidated buying power of the Federal Government to procure more cost effective and secure network services.

Upon Approval of the President and within a Timeline of 60 Days:

DHS to provide GSA and agencies with baseline configuration guidance for Managed Security Services (MSS) capabilities offered under EIS in order to maximize the return on investment for the security capabilities procured by agencies and to ensure compliance with current TIC policy.

Upon Approval of the President and within a Timeline of 90 Days:

GSA, in coordination with DHS, shall develop a comprehensive acquisition strategy that provides a feasibility assessment and roadmap to accomplish the following tasks:

Other High-Level Actions:

Increase Economies of Scale through Consolidation of Contracts for Small Agencies. Currently, 102 Federal small agencies are supported by the legacy Networx contract, each on separate task orders. GSA will support these small agencies in the transition to EIS by consolidating requirements for small agencies and is considering the best approach to leverage a limited number of task orders to purchase the majority of services these agencies need. Through the consolidation of common requirements across small agencies, GSA can leverage one or a small number of task orders under EIS to purchase the majority of services needed for all small agencies, with an option to provide additional specific language focused on agency-specific requirements, in order to realize economies of scale.

Improve Acquisitions Support for Small Agencies to Maximize the Use of MTIPS and other Cybersecurity Services. For small agencies, there are often barriers to acquiring and maximizing the benefits of MTIPS. In addition to high costs, many small agencies lack the appropriate expertise to draft effective task orders and the resources to manage their MTIPS contract and hold vendors accountable for accomplishing the work specified in Service Level Agreements (SLAs). As such, GSA will provide guidance to small agencies on how best to leverage its cross-agency acquisition in order to optimize their IT investments and management throughout the procurement process.

  1. E-Government Act of 2002 (Pub. L. No. 107-347); Information Technology Management Reform Act of 1996, “Clinger-Cohen Act (CCA),” (Pub. L. 104-106, Division E); and Paperwork Reduction Act of 1995 (Pub. L. No. 96-511). 

  2. State of Federal IT Report, Public Release Version 1.0. 

  3. Federal IT Acquisition Reform Act (included in the National Defense Authorization Act for Fiscal Year 2015 – Pub. L. 113-291). 

  4. The TIC and NCPS initiatives are further described in the Comprehensive National Cyber Security Initiative (CNCI), established by Joint Presidential Directive NSPD-54/HSPD-23; OMB Memorandum M-08-16, Guidance for TIC Statement of Capability Form (SOC); OMB Memorandum M-08-26, Transition from FTS 2001 to Networx; OMB Memorandum M-08-27, Guidance for TIC Compliance; OMB Memorandum M-09-32, Update on the TIC Initiative; and DHS’s TIC Reference Architecture. These documents provide further details on agency, OMB, and DHS responsibilities and reporting requirements, acquisition vehicles, and technical capabilities under the TIC initiative. The Homeland Security Act, as amended by section 223 of the Federal Cybersecurity Enhancement Act of 2015, [Consolidated Appropriations Act of 2016][APPROPS2016] (Pub. L. No. 114-113, 129 Stat. 2242, Division N, Title II, Subtitle B), requires DHS to “deploy, operate, and maintain” and “make available for use by any agency” capabilities to detect cybersecurity risks in agency network traffic and take actions to mitigate those risks (6 U.S.C. § 151(b)(1)). DHS currently provides these capabilities through its NCPS program and, as required by law, ensures all retention, use, and disclosure of information obtained through NCPS occurs only for protecting information and information systems from cybersecurity risks (See id. § 151(c)(3)). The Federal Cybersecurity Enhancement Act of 2015 also requires agencies to apply these capabilities to “all information traveling between an agency information system and any information system other than an agency information system.” Id. § 151, note. Notably, these statutory provisions have flexibility regarding the technological means through which DHS offers these intrusion detection and prevention capabilities and is not tied to the current NCPS implementation. Indeed, the Homeland Security Act encourages development of these capabilities by requiring DHS to “regularly assess through operational test and evaluation in real world or simulated environments available advanced protective technologies to improve detection and prevention capabilities, including commercial and noncommercial technologies and detection technologies beyond signature-based detection, and acquire, test, and deploy such technologies when appropriate.” Id. § 151(c)(4). 

  5. OMB Memorandum M-17-09, Management of Federal High Value Assets

  6. See Footnote 9. 

  7. Federal Cybersecurity Enhancement Act of 2015, Consolidated Appropriations Act of 2016 (Pub. L. No. 114-113, 129 Stat. 2242, Division N, Title II, Subtitle B). 

  8. DHS Office of the Inspector General. Implementation Status of EINSTEIN 3 Accelerated. March 2014. U.S. Government Accountability Office (GAO) Report 16-294, DHS Needs to Enhance Capabilities, Improve Planning, and Support Greater Adoption of its NCPS. January 2016. 

  9. This approach was originally piloted by the FedRAMP Tailored baseline, which was designed to increase FedRAMP’s flexibility to rapidly authorize and use low-risk applications. The deadline for public comment on this initial tailored baseline was in July 2017. 

  10. The recently rescinded OMB Memorandum M-08-26, Transition from FTS 2001 to Networx stated that all agencies should use Networx to acquire telecommunications connectivity, including the option to purchase Trusted Internet Connections solutions from vendors as a managed service, called Managed Trusted Internet Protocol Services (MTIPS). As of July 2017, an OMB Memorandum mandating a similar use under the EIS contract does not exist. 

  11. In this report, “large” agencies refer to the 24 agencies required to appoint agency Chief Financial Officers (CFOs) (i.e., “CFO Act agencies”) under the Chief Financial Officers Act of 1990 (31 U.S.C. §901). All other agencies aside from these 24 are referred to as “small” agencies. 

  12. MTIPS providers supply small agencies with a vendor-managed solution that ensures compliance with OMB’s Trusted Internet Connection policy. 

  13. Pursuant to 6 U.S.C. § 151.