Leveraging NIST OSCAL to Provide Compliance Automation: The Complete Guide

What is OSCAL?

OSCAL provides a traceable and machine-readable data format for capturing and sharing security information. A standardized, continuous representation of an organization’s security controls helps prove compliance with NIST’s risk management framework for mandated federal agencies.

FedRAMP joined with NIST to create the Open Security Controls Assessment Language (OSCAL), a standard that can be used to integrate existing security practices into a customized, code-based, continuous ATO (authority to operate) solution.

Today, security controls and control baselines are documented in various formats, requiring excessive manual efforts to prove and show their implementation. A key objective of OSCAL NIST is to transform these security controls and control baselines from a text-based and manual approach, using Word and Excel documents, to a set of standardized and machine-readable formats, using JSON, XML, and YAML file types. Data that is converted into OSCAL format can be easily presented to CIOs and CISOs to make risk-based decisions.

Leveraging NIST OSCAL to Provide Compliance Automation

What is an ATO?

Authorization to Operate (ATO) is the official decision given by a government authorizing an organization to operate an information system on behalf of a federal agency. With an ATO, the risks of organizational operations are accepted based on the implementation of an agreed-upon set of security controls.

Why was OSCAL created?

The Federal Information Security Modernization Act (FISMA) emphasized the significance of information security to the country’s economic and national security interests. It mandated that each federal agency develop, document, and implement a structured program to provide information security protections in line with the risk of unauthorized access to information. Agency leaders were required by FISMA to report on the suitability and efficacy of their company’s information security policies, procedures, and practices. Federal agencies diligently pursued the implementation of these principles for many years, but the Authority to Operate (ATO) procedures relied on complex paper-based processes and assessments that did not support data portability.

With time, as systems became more complex and more cloud-based solutions were adopted, the jobs of security practitioners and authorizing officials became increasingly difficult. Security teams need to reference multiple sets of documents while requiring an understanding of how the systems stack, relate to each other, and how the controls are addressing and identifying risks that need to be mitigated. The complexity of these tasks called for interoperable and portable security automation that starts with compliance documentation as code in a machine-readable format and integrates the data into relevant security assessments and monitoring procedures. 

Many proprietary solutions have been developed to ease the FedRAMP and NIST compliance processes, but many of the solutions are not interoperable. FedRAMP OSCAL was designed to be able to represent the necessary security information in a machine-readable format so digital tools can consume this information and facilitate automation of the assessment process, but it can also be used by different risk management regulatory frameworks without customizations. For example, OSCAL can be used to represent the SP 800-53 controls in XML, JSON, and YAML, but at the same time, OSCAL can be used to represent the ISO/IEC 27002 controls.

In addition, security automation with OSCAL tools supports a more agile and repeatable assessment of vendor security postures against multiple regulatory frameworks with less human subjectivity.

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How Can OSCAL Be Leveraged for Automated Compliance?

With OSCAL, security teams substantially reduce the time it takes to generate the needed information for an Authorization to Operate (ATO) decision. Furthermore, teams will be able to implement automated compliance with more rigor and with fewer resources. Official estimates indicate that months of assessment efforts can be reduced to weeks with additional benefits and enhanced security understanding of the systems assessed.

It is important to note that stakeholders do not need to understand the technical workings of OSCAL. OSCAL is a tool. What they will see are the pleasant, user-friendly dashboards or interfaces that the OSCAL-enabled products will provide, giving them access to all the information. Also, they will be able to concentrate on their areas of expertise, such as evaluating, auditing, or adjudicating. 

What is cATO?

The current implementation of the risk management framework mandated by the DoD establishes continuous management of system cybersecurity risk. It falls short, though, of implementing continuous monitoring of risk once authorization to operate (ATO) has been reached. Real-time data analytics of security events is essential to achieving the high level of security required in today’s risk-laden environment, especially in the DIB. Continuous authorization to operate (cATO) demonstrates that an organization can provide ongoing visibility of security activities inside the system boundary with robust monitoring of RMF controls and the ability to conduct active cyber defense and respond to threats in real-time. OSCAL helps achieve cATO by enabling you to integrate your existing security processes, tools, and documentation.

What are the Benefits of OSCAL?

An enormous advantage to OSCAL-enabled tools is that they could parse the data and recreate it while bringing it all together in front of the system owners, assessors, and approving officials. OSCAL can handle it. 

This is the return on investment for OSCAL that is easiest to reap. GRC tools can ingest the same security data from OSCAL and utilize it as the assessment’s seed data. A majority of the assessment can be automated with OSCAL.

OSCAL is not applicable or beneficial only to cloud-based solutions. Imagine an agency that has numerous internal systems that need to be periodically reassessed and continuously monitored to maintain their ATO. The SSP document might need to describe the implementation of the 159 controls and 102 control enhancements that are part of the NIST 800-53 moderate baseline. Then the assessors will have to assess all these controls and enhancements, summarize the assessment results, and create a POA&M when applicable. The findings are then shared with the authorizing official. The scanning results from the GRC tool need to be correlated and transformed from the proprietary format to a human-readable format to be summarized and the findings addressed.

Where Can You Learn More about NIST’s OSCAL?

NIST-generated documentation is available on NIST’s website: https://pages.nist.gov/OSCAL/documentation/.

Interested parties are encouraged to navigate the different pages of documentation NIST provides and review the concepts used in OSCAL, the logical layers aligned with the risk management approach, and the model for each layer. 

Start Getting Value With
Centraleyes for Free

See for yourself how the Centraleyes platform exceeds anything an old GRC
system does and eliminates the need for manual processes and spreadsheets
to give you immediate value and run a full risk assessment in less than 30 days

Does your company need to be compliant with NIST OSCAL?
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