OMB Starts Clock on Agencies Implementing Policies to Welcome Public Security Research

Federal agencies now have 180 days to publish and operationalize coordinated vulnerability disclosure policies aimed at encouraging ethical hackers to submit reports of weaknesses they find in government systems.

“VDPs empower agencies to crowdsource vulnerability discovery and thereby realize extraordinary return on investment,” Acting Deputy Director for Management Michael Rigas said in a press release announcing a new policy memorandum Wednesday. “This is part of an ongoing effort to improve our cyber defenses and to improve government transparency, while adopting industry-tested and cost effective measure[s] to improve federal information security programs.”

The VDP initiative represents a big cultural change for the government. It is meant to open communication channels between agencies and security researchers who might otherwise be reluctant to share vulnerabilities they find due to fear of prosecution under the Computer Fraud and Abuse Act or are demoralized by a lack of responsiveness when they do. 

The OMB memo lays out a time table for actions federal agencies and the Cybersecurity and Infrastructure Security Agency need to take over the next year to fully implement policies that would promise researchers agencies won’t pursue legal action if they act within certain parameters, and establish when researchers can expect their reports to be resolved. 

Within 60 days, CISA must “publish actions that agencies shall take to incorporate VDP into agency information security programs,” according to the memo.

As anticipated, CISA also released its final version of a related binding operational directive for agencies, shortly after OMB’s release. The directive echoes the OMB memo, and notes that CISA will start checking whether agencies have published policies at the 180-day mark.

“OMB, in coordination with the Department of Homeland Security Cybersecurity and Infrastructure Security Agency, encourages federal agencies to establish VDPs and begin welcoming vulnerability findings from the general public,” reads the OMB release. “Since the public comment period, the policy has evolved to promote remediation and provide a clear definition of good-faith security research.”

Public comments submitted to CISA in response to the draft binding operational directive reflected angst on the part of some federal agencies who fear a lack of resources necessary to appropriately implement the policies. But the effort has champions in Congress, such as Rep. Jim Langevin, D-R.I., who encouraged agencies to voice their concerns there in order to have them addressed.  

Under the memo, within 240 days, agencies must “provide timelines and milestones for VDP to cover all federal information systems.” Within that time, CISA must also work with federal agencies to “coordinate the tracking of submitted vulnerabilities across the federal enterprise,” and DHS must “report to OMB on the demand for centrally-managed bug bounty solution, and collect business requirements accordingly.”

CISA has already issued a solicitation for a platform to track the disclosure and remediation of vulnerabilities and according to a blog post issued along with the directive, will offer a service starting next spring that the agency expects “will ease operations at agencies, diminish their reporting burden under this directive, and enhance discoverability for vulnerability reporters.”   

OMB has tasked the agency with publishing a report on emergent challenges implementing the new policy within 360 days. 

“This BOD is part of CISA’s agency-wide priority to make 2020 the ‘year of vulnerability management,’ with a particular focus on making vulnerability disclosure to the civilian executive branch easier for the public,” CISA said in its release.

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