Feds cram to meet ID deadlines

Reporting template for HSPD 12 plans

Federal officials who must prepare to issue secure credentials to employees and contractors face their first reporting deadline June 27, a date that experienced program officials say could arrive too soon for some agencies.

The new credentialing policy, Homeland Security Presidential Directive (HSPD) 12, applies to all executive and independent federal agencies, including the Defense Department and the Postal Service. Government corporations, such as the Federal Deposit Insurance Corp., are exempt from the directive, according to the Office of Management and Budget's compliance guidelines.

Academic institutions that conduct federal research are also exempt. But agency officials must decide whether to issue the new identity credentials to guest researchers and require them for researchers who need to gain access from a remote location to upload data to a secure federal Web site.

OMB's guidelines let agency officials decide which of their contractors need the new credentials, but the intent of the guidelines is clear, said Mary Dixon, deputy director of DOD's Defense Manpower Data Center, which is responsible for DOD's HSPD 12 credentialing program. "We're trying to get to the point where people who come inside our buildings or our campuses or our bases have been either adequately vetted or are properly supervised," she said.

OMB officials expect each agency to submit detailed plans for issuing identity credentials that conform to the HSPD 12 biometric smart card standard, known as Federal Information Processing Standard (FIPS) 201.

By Aug. 27, OMB will require federal officials to submit a list of ideas for expanding their use of the FIPS 201 standard beyond its basic purpose to provide secure access to federal buildings and computer systems. The standard could be used, for example, to replace user IDs and passwords now required to gain access to many federal databases and software applications.

Agencies that have never used smart cards as secure IDs lack a vision of how the technology will benefit them, said Randy Vanderhoof, executive director of the Smart Card Alliance, an industry group based in Princeton, N.J. "Once they have this platform in place, there will be many opportunities for them to utilize it to become more effective and more efficient," he said.

While agency officials focus on the upcoming deadlines, officials at the National Institute of Standards and Technology have a June 25 deadline for creating a working prototype, or reference implementation, of the new FIPS 201 standard.

"When you go to implement a standard for the first time, you find issues that need to be resolved," Dixon said, adding that a reference implementation helps resolve many of them.

Some agency officials may be surprised by the standard's strict requirements for background checks and OMB's strict deadlines for completing those checks before issuing new identity credentials. Similar investigations of federal employees have been on the books for more than 50 years. A 1950 executive order requires background checks to verify the identity of prospective employees and their "worthiness to hold a position of public trust."

OMB's latest guidelines state that background checks needed to comply with FIPS 201 are less extensive than those required for employees with security clearances to gain access to classified information. But before issuing FIPS 201 credentials, officials are required to investigate all federal employees by running a national agency check against FBI databases, for example.

Many federal agencies, even within DOD, have not always completed background checks on civilian employees before issuing them government IDs, Dixon said. Many civilian employees who do not require a clearance to do their work are hired and put to work before officials have completed the national agency check, she said. But with HSPD 12, that will change.

OMB's guidelines state that agencies cannot issue FIPS 201 credentials to an employee until the national check is completed. "That will require a little bit of a change in our business process for some of our workers," Dixon said.

Complying with the new building and systems access control standard could be challenging for everyone, security experts say, especially for federal agencies that share space with other agencies in a regional federal building. Glenn Schlarman, chief of OMB's Information Policy and Technology Branch, wrote in a May 19 memo that officials in charge of those agencies could collaborate on their HSPD 12 plans, but they have to first consult with General Services Administration officials.

Agencies with employees who work undercover could have difficulty complying with HSPD 12. OMB officials have acknowledged the issue by advising "agencies with employees who serve undercover shall implement this directive in a manner consistent with maintenance of the cover and to the extent consistent with applicable law."

Most agencies will have to make tough cryptographic choices in preparing to issue smart card IDs. Bill Schell, president of August Schell, a software consulting firm specializing in public-key infrastructure (PKI) engineering, offered questions that agency officials must answer. Does an agency introduce the RSA 1,024-bit encryption when it's going to expire in a couple of years? But if they opt for RSA 2048, will their software still work?

Officials also need to consider whether to use elliptic curve algorithms, especially if their agency relies mostly on SSL technology, which does not yet support elliptic curve, Schell said. His company helped Defense Information Systems Agency officials set up the PKI infrastructure for the Common Access Cards program, which Schell said has the largest PKI implementation.

DOD has an identity-credentialing program based on smart cards that will allow it to meet deadlines for complying with the new HSPD 12 standard, Dixon said. "We're probably 85 percent to 90 percent compliant with HSPD 12 already," she said.

The policy's intent is to create a secure credentialing process so that federal officials know that the right people are getting credentials and that every time someone presents those credentials, security officials can be sure that people are who they say they are.

"Maybe I can't keep anybody from stealing someone's identity, but I sure can keep them from using it," Dixon said. "That's what HSPD 12 is trying to do."