Fast Facts

Federal agencies are increasingly using cloud computing services. Cloud computing offers benefits but also poses cybersecurity risks. OMB requires agencies to use the Federal Risk and Authorization Management Program to authorize their use of cloud services.

Although agencies increased their program use—authorizations were up 137% from 2017 to 2019—15 of the 24 agencies we surveyed reported that they didn’t always use the program. Our 4 case study agencies didn’t fully implement key elements of the authorization process. Also, OMB didn’t monitor use of the program.

We made 24 recommendations to 4 agencies, plus one to OMB to improve oversight.

Illustration of cloud computing

Illustration of cloud computing

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Highlights

What GAO Found

The 24 federal agencies GAO surveyed reported using the Federal Risk and Authorization Management Program (FedRAMP) for authorizing cloud services. From June 2017 to July 2019, the number of authorizations granted through FedRAMP by the 24 agencies increased from 390 to 926, a 137 percent increase. However, 15 agencies reported that they did not always use the program for authorizing cloud services. For example, one agency reported that it used 90 cloud services that were not authorized through FedRAMP and the other 14 agencies reported using a total of 157 cloud services that were not authorized through the program. In addition, 31 of 47 cloud service providers reported that during fiscal year 2017, agencies used providers' cloud services that had not been authorized through FedRAMP. Although the Office of Management and Budget (OMB) required agencies to use the program, it did not effectively monitor agencies' compliance with this requirement. Consequently, OMB may have less assurance that cloud services used by agencies meet federal security requirements.

Four selected agencies did not consistently address key elements of the FedRAMP authorization process (see table). Officials at the agencies attributed some of these shortcomings to a lack of clarity in the FedRAMP guidance.

Agency Implementation of Key Elements of the FedRAMP Authorization Process

 

HHS

GSA

EPA

USAID

Element

 

 

 

 

Control implementation summaries identified security control responsibilities

Security plans addressed required information on control implementation

Security assessment reports summarized results of control tests

Remedial action plans addressed required information

Cloud service authorizations prepared and provided to FedRAMP Program Office

Legend: ● fully addressed the element ◐ partially addressed the element

FedRAMP = Federal Risk and Authorization Management Program; HHS = Department of Health and Human Services; GSA = General Services Administration; EPA = Environmental Protection Agency; USAID = U.S. Agency for International Development

Source: GAO analysis of agency documentation| GAO-20-126

Program participants identified several benefits, but also noted challenges with implementing the FedRAMP. For example, almost half of the 24 agencies reported that the program had improved the security of their data. However, participants reported ongoing challenges with resources needed to comply with the program. GSA took steps to improve the program, but its FedRAMP guidance on requirements and responsibilities was not always clear and the program's process for monitoring the status of security controls over cloud services was limited. Until GSA addresses these challenges, agency implementation of the program's requirements will likely remain inconsistent.

Why GAO Did This Study

Federal agencies use internet-based (cloud) services to fulfill their missions. GSA manages FedRAMP, which provides a standardized approach to ensure that cloud services meet federal security requirements. OMB requires agencies to use FedRAMP to authorize the use of cloud services.

GAO was asked to review FedRAMP. The objectives were to determine the extent to which 1) federal agencies used FedRAMP to authorize cloud services, 2) selected agencies addressed key elements of the program's authorization process, and 3) program participants identified FedRAMP benefits and challenges. GAO analyzed survey responses from 24 federal agencies and 47 cloud service providers. GAO also reviewed policies, plans, procedures, and authorization packages for cloud services at four selected federal agencies and interviewed officials from federal agencies, the FedRAMP program office, and OMB.

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Recommendations

GAO is making one recommendation to OMB to enhance oversight, two to GSA to improve guidance and monitoring, and 22 to the selected agencies, including GSA. GSA and HHS agreed with the recommendations, USAID generally agreed, EPA generally disagreed, and OMB neither agreed nor disagreed. GAO revised four recommendations and withdrew one based on new information provided; it maintains that the remaining recommendations are warranted.

Recommendations for Executive Action

Agency Affected Recommendation Status
Office of the Director
Priority Rec.
This is a priority recommendation.
The Director of OMB should establish a process for monitoring and holding agencies accountable for authorizing cloud services through FedRAMP. (Recommendation 1)
Open
In April 2021, OMB stated that it was coordinating with federal agencies and the General Services Administration's FedRAMP to improve administrative processes. Additionally, OMB stated it worked with GSA to establish a program designed to collaborate with federal agencies. Further, OMB stated it plans to require agencies to report which cloud services have been authorized for use at their agency, including FedRAMP's Authorization log. However, to fully implement this recommendation, OMB needs to collect data on the extent to which federal agencies are using cloud services authorized outside of FedRAMP and oversee agencies' compliance with using the program. We will update the status of this recommendation when OMB provides information on its corrective actions.
Office of the Administrator The Administrator of GSA should direct the Director of FedRAMP to clarify guidance to agencies and cloud service providers on program requirements and responsibilities. (Recommendation 2)
Closed - Implemented
In fiscal year 2021, we verified that the Director of FedRAMP, in response to our recommendation took actions to clarify guidance to agencies and cloud service providers on program requirements and responsibilities. Specifically, the FedRAMP Program Management Office (PMO) updated the Customer Implementation Summary and Customer Responsibility Matrix templates for high, moderate, and low systems to include clear guidance for agencies and cloud service providers' responsibilities. Additionally, the FedRAMP PMO continued to host training opportunities for agencies and cloud service providers to help clarify guidance on the program's requirements and responsibilities. The PMO also streamlined the FedRAMP website to make it easier to access guidance and templates, among other things. These actions help ensure that responsibilities for implementing the program are clear and help agencies to better implement security controls over the cloud services they authorized.
Office of the Administrator The Administrator of GSA should direct the Director of FedRAMP to improve the program's continuous monitoring process by allowing more automated capabilities, including for agencies to review documentation. (Recommendation 3)
Open
In July 2021, GSA provided evidence to close this recommendation. We will update the recommendation's status when we confirm GSA's corrective actions.
Office of the Administrator The Administrator of GSA should update security plans for selected systems to include the description of security controls and reviews and approvals plan. (Recommendation 4)
Closed - Implemented
In fiscal year 2021, we verified that GSA, in response to our recommendation, updated security plans for selected systems to include the description of security controls and reviews and approvals of the plans. By taking this action GSA has an increased assurance that security controls are in place and operating as intended.
Office of the Administrator The Administrator of GSA should update the security assessment report for the selected system to identify the summarized results of control effectiveness tests. (Recommendation 5)
Open
In July 2021, GSA provided evidence to close this recommendation. We will update the recommendation's status when we confirm GSA's corrective actions.
Office of the Administrator The Administrator of GSA should update the list of corrective actions for selected systems to identify the responsible office and estimated funding required and anticipated source of funding. (Recommendation 6)
Open
In July 2021, GSA provided evidence to close this recommendation. We will update the recommendation's status when we confirm GSA's corrective actions.
Office of the Administrator The Administrator of GSA should develop guidance requiring that cloud service authorization letters be provided to the FedRAMP program management office. (Recommendation 7)
Closed - Implemented
In fiscal year 2021, we verified that GSA, in response to our recommendation, updated its guidance to require that cloud service authorization letters be provided to the FedRAMP Program Management Office (PMO). This action may reduce the risk that the FedRAMP PMO will not have accurate information on GSA's usage of approved cloud services.
Office of the Secretary The Secretary of HHS should direct the Director of CDC to update the security plan for the selected system to identify the authorization boundary, the system operational environment and connections, a description of security controls, and the individual reviewing and approving the plan and date of approval. (Recommendation 8)
Open
In June 2020, CDC reported that it had developed a Plan of Action & Milestones to address the deficiencies described in this recommendation and was updating its automated security control assessment and documentation of systems. However, as of September 2021, the agency has not provided supporting documentation to close this recommendation. Once we receive supporting documentation, we will provide updated information.
Office of the Secretary The Secretary of HHS should direct the Director of CDC to update the security assessment report for the selected system to identify the summarized results of control effectiveness tests. (Recommendation 9)
Open
In June 2020, CDC reported that it had developed a Plan of Action & Milestones to address the deficiencies described in this recommendation and was updating its automated security control assessment and documentation of systems. However, as of September 2021, the agency has not provided supporting documentation to close this recommendation. Once we receive supporting documentation, we will provide updated information.
Office of the Secretary The Secretary of HHS should direct the Director of CDC to update the list of corrective actions for the selected system to identify the specific weaknesses, funding source, changes to milestones and completion dates, identified source of weaknesses, and status of corrective actions. (Recommendation 10)
Open
In June 2020, CDC reported that it had developed a Plan of Action & Milestones to address the deficiencies described in this recommendation and was updating its automated security control assessment and documentation of systems. However, as of September 2021, the agency has not provided supporting documentation to close this recommendation. Once we receive supporting documentation, we will provide updated information.
Office of the Secretary The Secretary of HHS should direct the Administrator of CMS to update the system security plans for selected systems to identify a description of security controls. (Recommendation 11)
Open
In January 2021, CMS provided evidence to close this recommendation. However, the evidence was not sufficient to close the recommendation. We will follow-up with the agency to obtain additional documentation and continue to monitor the agency's efforts to implement this recommendation.
Office of the Secretary The Secretary of HHS should direct the Administrator of CMS to update the security assessment report for selected system to identify the summarized results of control effectiveness tests. (Recommendation 12)
Open
In January 2021, CMS provided evidence to close this recommendation. However, the evidence was not sufficient to close the recommendation. We will follow-up with the agency to obtain additional documentation and continue to monitor the agency's efforts to implement this recommendation.
Office of the Secretary The Secretary of HHS should direct the Administrator of CMS to update and document the CMS remedial action plan for the selected system to identify the anticipated source of funding. (Recommendation 13)
Open
In January 2021, CMS provided evidence to close this recommendation. However, the evidence was not sufficient to close the recommendation. We will follow-up with the agency to obtain additional documentation and continue to monitor the agency's efforts to implement this recommendation.
Office of the Secretary The Secretary of HHS should direct the Administrator of CMS to prepare letters authorizing the use of cloud services for the selected systems and submit the letters to the FedRAMP program management office. (Recommendation 14)
Open
In January 2021, CMS provided evidence to close this recommendation. However, the evidence was not sufficient to close the recommendation. We will follow-up with the agency to obtain additional documentation and continue to monitor the agency's efforts to implement this recommendation.
Office of the Secretary The Secretary of HHS should direct the Director of NIH to update security plans for selected systems to identify the authorization boundary, system operation in terms of mission and business processes, operational environment and connections, and a description of security controls. (Recommendation 15)
Open
In September 2021, NIH state that it plans to decommission one of the selected systems in March 2022. Once we receive supporting documentation on the system's decommission, we will provide updated information.
Office of the Secretary The Secretary of HHS should direct the Director of NIH to update the security assessment report for selected systems to identify summarized results of control effectiveness tests. (Recommendation 16)
Open
In September 2021, NIH stated that it plans to decommission one of the selected systems in March 2022. Once NIH provides the supporting documentation on the system's decommission, we will provide updated information.
Office of the Secretary The Secretary of HHS should direct the Director of NIH to update the NIH list of corrective actions for selected systems to identify estimated funding and anticipated source of funding, key milestones with completion dates, and changes to milestones and completion dates. (Recommendation 17)
Open
In September 2021, NIH stated that it plans to decommission one of the selected systems in March 2022. Once NIH provides the supporting documentation on the system's decommission, we will provide updated information.
Office of the Secretary The Secretary of HHS should direct the Director of NIH to submit the division's letters authorizing the use of cloud services for the selected systems to the FedRAMP program management office. (Recommendation 18)
Open
In September 2021, NIH stated that it plans to decommission one of the selected systems in March 2022. Once NIH provides the supporting documentation on the system's decommission, we will provide updated information.
Environmental Protection Agency The Administrator of EPA should update security plan for the selected operational system to identify a description of security controls, and the individual reviewing and approving the plan and date of approval. (Recommendation 19)
Open
As of September 2021, the EPA has not provided supporting documentation to close this recommendation. Once EPA provides the supporting documentation, we will provide updated information.
Environmental Protection Agency The Administrator of EPA should update the security assessment report for the selected operational system to identify the summarized results of control effectiveness tests. (Recommendation 20)
Open
In May 2021, EPA provided evidence of its corrective actions. However, the evidence was not sufficient to close the recommendation. We will follow-up with the agency to obtain additional documentation and continue to monitor the agency's efforts to implement this recommendation.
Environmental Protection Agency The Administrator of EPA should update the list of corrective actions for the selected operational system to identify the specific weakness, estimated funding and anticipated source of funding, key remediation milestones with completion dates, changes to milestones and completion dates, and source of the weaknesses. (Recommendation 21)
Open
As of September 2021, the EPA has not provided supporting documentation to close this recommendation. Once EPA provides the supporting documentation, we will provide updated information.
Environmental Protection Agency The Administrator of EPA should prepare the letter authorizing the use of cloud service for the selected operational system and submit the letter to the FedRAMP program management office. (Recommendation 22)
Open
In May 2021, EPA provided evidence of its corrective actions. However, the evidence was not sufficient to close the recommendation. We will follow-up with the agency to obtain additional documentation and continue to monitor the agency's efforts to implement this recommendation.
Environmental Protection Agency The Administrator of EPA should develop guidance requiring that cloud service authorization letter be provided to the FedRAMP program management office. (Recommendation 23)
Open
In May 2021, EPA provided evidence of its corrective action. However, the evidence was not sufficient to close the recommendation. We will follow-up with the agency to obtain additional documentation and continue to monitor the agency's efforts to implement this recommendation.
United States Agency for International Development The Administrator of USAID should update the list of corrective actions for the selected system to include the party responsible for addressing the weakness, and source of the weakness. (Recommendation 24)
Closed - Implemented
In fiscal year 2020, we verified that USAID, in response to our recommendation, updated the list of corrective actions for the selected system to include the party responsible for addressing the weakness, and identified the source of the weakness. By taking this action, USAID has an increased assurance it is effectively assessing, prioritizing, and monitoring efforts to resolve weaknesses in the agency's system.
United States Agency for International Development The Administrator of USAID should prepare the letter authorizing the use of cloud service for the selected system and submit the letter to the FedRAMP program management office. (Recommendation 25)
Closed - Implemented
In fiscal year 2020, we verified that USAID, in response to our recommendation, prepared the letter authorizing the use of cloud service for the selected system and submitted the letter to the FedRAMP program management office. This action reduces the risk that the office will not have accurate information on USAID's usage of approved cloud services.

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