OMB Finalizes Long-Awaited Update to Internet Connection Policy

Almost seven years to the day after the last major revision, the Trump administration Thursday released the third iteration of the Trusted Internet Connection policy, a roadmap for how agencies can ensure secure system access at a time when the notion of networks is changing rapidly.

Federal employees, networks and data are prime targets for hackers and other bad actors looking to steal sensitive information on agencies, Americans and anyone who interacts with government systems. To ensure those data and networks are secure, federal employees must know they are accessing agency systems through secure connections. Were a federal employee to access an agency system through a compromised connection, bad actors could intercept sensitive data and potentially leverage the user’s credential to gain more access.

The original 2007 TIC policy—as well as TIC 2.0 released in September 2012—focused on offering agencies a set list of specific connectivity options designed to exclude potentially dangerous connections. However, those policies were incredibly proscriptive, and have not translated well in the cloud-based networks the administration is pushing agencies to adopt.

The previous policies “required agency traffic to flow through a physical TIC access point, which has proven to be an obstacle to the adoption of cloud-based infrastructure,” according to the policy memo released Thursday.

“We’ve seen a lot of things change with a stagnant program,” Mark Bunn, program manager for the Homeland Security Department’s TIC initiative, said in September 2018 as work on TIC 3 was in progress. “We have the whole concept of boundaries, and now we have technologies that don’t have boundaries. How do you apply a boundary program to try to leverage data and use data when there’s no such thing as a boundary anymore?”

The solution, as devised by DHS and the Office of Management and Budget, was to create a set of use cases that outline the different ways agencies set up networks and how employees should connect to those networks.

“It still requires agencies to meet all the strict security requirements that have always been a priority and are even more of a priority now,” Federal Chief Information Officer Suzette Kent said during a keynote Thursday at the Dell Technologies Forum. “But it includes new pathways to take advantage of new technologies and capabilities of software that wasn’t even imagined when that original policy was written.”

The use cases, once finalized, will center on four types of user access and network structures:

• Traditional: Connecting through approved, established connections. This also represents the default use case agencies should abide if a situation does not fall into one of the other three buckets.
• Cloud: The use cases will include infrastructure-as-a-service, software-as-a-service, email-as-a-service and platform-as-a-service, or what OMB considers to be the “most prevalent cloud models used by agencies today.”
• Agency Branch Office: In cases where satellite offices connect to agency headquarters networks “for the majority of their services—including generic web traffic.” This will also be used for agencies deploying software-defined wide area networks, or SD-WAN.
• Remote Users: For teleworkers or those operating in the field, the final use cases will describe how best to connect to an agency’s cloud, from a government-issued device, but through a third-party connection. The memo notes this work will be “an evolution” of the TIC Overlay framework developed by the Federal Risk and Authorization Management Program, or FedRAMP.

Per Thursday’s memo, DHS—in cooperation with OMB, the General Services Administration and Federal Chief Information Security Officer Council—has 60 days to begin and complete pilots with various agencies to test policy frameworks for each use case. By the end of the two-month timeline, DHS should have finalized use cases and reference architecture documentation available for each.

As the work on each use case wraps up, DHS, GSA and the National Institute of Standards and Technology will have 90 days to create a verification process to ensure agencies are in compliance with the new policy.

Federal agencies will have one year—until Sept. 12, 2020—to determine the right use cases for their situations and implement the new policy. The administration will continue to ensure compliance with TIC 3 through the annual Federal Information Security Management Act, or FISMA, reports.

Kent noted TIC 3 is part of a suite of policy updates the administration has been working on for the last year and a half.

“Our work of the last 18 months to update, not only the internet connectivity policy but Cloud Smart, recognizing what goes on in a hybrid environment; how we treat high-value assets; improvements to how we manage identity, which is incredibly critical as we move into a data-centric world; and the first-ever data strategy,” she said. “These reflect how we actually are using policy to break down barriers and enable the federal government and the agencies to use market-leading capabilities. … How do we take advantage of those for the specific reason for achieving mission and better serving citizens?”