DOD's cautious path to the cloud

Since December 2012, a total of 10 cloud service providers (CSPs) and 13 solutions have achieved compliance under the Federal Risk and Authorization Management Program (FedRAMP), the government's baseline mandatory requirements for agency cloud deployments at low- and moderate-risk impact levels.

That number is expected to grow quickly as the June 5, 2014, deadline to meet FedRAMP standards approaches, said FedRAMP director Maria Roat at a December event in Washington.

By June, FedRAMP will touch or affect the vast majority of CSPs that performed cloud computing-related contracts from civilian agencies totaling $16.5 billion between October 2012 and September 2013, according to Alex Rossino, principal research analyst at Deltek.

The numbers show that civilian agencies are beginning to embrace the administration's Federal Cloud Computing Strategy, which details how the government can use cloud computing to rid itself of billions annually in duplicative IT spending.

Tellingly, however, defense agencies spent a paltry $65 million on cloud contracts during the same period, signaling a much slower and more cautious approach at the Department of Defense.

Indeed, only Autonomic Resources has achieved provisional authorization under the additional security controls currently required by the DOD, making it the first addition to the Defense Information Systems Agency's Enterprise Cloud Service Broker (ECSB) catalog. That provisional authorization grants Autonomic DOD-wide acceptance at DOD Impact Levels 1 and 2. Two other companies, Amazon Web Services and CGI Federal, are close to achieving provisional authorization.

Impact levels are assigned by DISA to data depending on its type and confidentiality, integrity and availability in categorizations of low-, moderate-, or high-risk under the Federal Information Process Standard Publication (FIPS) 199.

Thus far, Impact Levels 1 and 2 total approximately two dozen additional controls and enhancements that come from the third revision of the National Institute of Standards and Technology Special Publication 800-53 on top of FedRAMP's 298 security controls. Impact Levels 1 and 2 deal only with low-risk unclassified public information and unclassified private information, which is essentially low-risk front-facing data. According to multiple sources, DISA plans to release its first cloud services contract at Impact Levels 1-2 within the next month for infrastructure-as-a-service and platform-as-a-service. The multi-award contract is expected to be valued at up to $150 million, and competing companies would have to be able to achieve provisional authorization at Impact Levels 1 and 2.

However, CSPs recognize the bulk of the true savings cloud computing offers in defense and military operations lies at Impact Levels 3-5 -- higher-risk unclassified data. Impact level 6 is designated for classified information only. The market value for cloud computing services at Impact Levels 3-5 is likely 10 times more than exists at Levels 1-2, according to sources. As they are currently drafted, Impact Levels 3-5 require a private cloud, meaning a single-tenant environment with dedicated hardware. As a cloud service provider ascends up the impact level ladder, it would be mandated to meet additional controls and requirements.

Yet according to multiple sources, while impact levels 1-2 are essentially set, impact levels 3-5 remain in draft status and await approval from the Defense Information Systems Network (DISN) Flag Panel, meaning that CSPs cannot yet officially meet them. Many contend that progress has been too slow, and critics believe DOD's approach to cloud computing adoption is overly bureaucratic and stifling to innovation. FedRAMP accreditation -- essentially the entry fee for provisional authority for DISA at Impact Levels 1 and 2, takes CSPs an average of three to six months. Attaining provisional authority at each impact level adds months (and more dollars) to the effort.

DISA published its first interim guidance on cloud computing in December 2011, stating the "use of third-party, off-premises cloud services will require a waiver from the (Government Information Grid) Waiver Panel in order to preserve the security of DOD data and mission assurance in the face of persistent cyber threats from capable adversaries."

A June 2012 memo from the DOD CIO further designated DISA to perform cloud brokerage functions to ensure security and IT efficiencies in cloud adoption, and mandated that DOD components must acquire cloud services through DISA's ECSB or obtain a waiver from the DOD CIO designated review authority.

One year later, in June 2013, the DISN GIG Flag Panel authorized DISA as the ECSB with the responsibility of issuing DOD provisional authorizations for DOD-wide use of commercial cloud services for low-impact data and missions.

Yet according to a recent DOD CIO memo obtained by FCW, the DISN GIG Flag Panel "decided the use of commercial cloud services for moderate-risk data or missions, which include Controlled Unclassified Information, require DISN GIG Flag Panel approval, coordinated via the Broker."

"As such," the memo states, "the Broker developed a DISN GIG Flag Panel approval process for issuing DOD provisional authorizations for commercial cloud services, based on input and review of DISA's cyber security assessment by the Defense Information Assurance Security Accreditation Working Group."

Basically, DISA can issue authorizations for CSPs for its least sensitive data, but anything above Impact Level 2 -- where most of the potential savings exist -- requires additional approvals.

DOD CIO Teresa Takai did not comment on the memo, which her office distributed to DOD and military branches as supplemental guidance. Sources tell FCW the memo is not yet official policy but is likely to be introduced as such in the spring, though it could be altered depending on received feedback.

To critics and personnel from some CSPs waiting to make the jump to DOD, the memo adds another hurdle for CSPs to clear.

"We're headed into 2014 with more barriers to cloud adoption being raised, and the impact of the mission is suffering, cost savings are being lost and innovation is all but shut down," said one executive at a large CSP with government offerings.

"It's now been two years since the Interim Guidance. We're seeing more of a pent-up demand in DOD than I think the DOD CIO thought would happen, and now here's a policy that will put on the brakes," the source said. "To me, it violates the cloud-first policy. This is just another speed bump and layer of bureaucracy. This is the DOD CIO saying 'get in line and let us control the movement.'"

The memo also calls for a suspension of cloud services that do not have a DOD provisional authorization, signaling an emphasis on security.

"I am committed to achieving Information Technology (IT) efficiencies while ensuring our Department's cybersecurity posture and other IT requirements are met," states the memo, which is signed by Takai. "DOD Components are requested to collaborate with the Broker to help accelerate the availability of secure and less expensive commercial cloud services for the Department."

John Keese, CEO of Autonomic Resources, said he believes DOD -- by far the largest federal agency -- is being mindful of its security posture as it transitions to disruptive cloud computing technology.

"I think DOD is trying to get a handle on the disparate departments and agencies that have gone out to different cloud service providers to get their needs met," Keese said. "To aggregate those accredited CSPs through DISA helps [rein] in people who've gone off the reservation. They're looking at security posture because they don't want something bad to happen.

"If everyone gets to a common standard of security controls, it says a lot for the marketplace," Keese said. "If people want to go buy cars without seatbelts, you'd say that'd be foolish, right? DOD is a customer, and they're being prudent in being able to aggregate demand."