What is Required in an ATO Package?

What is Required in an ATO Package?

‍
Why is an ATO needed? An Authorization to Operate (ATO) is a formal declaration that a system meets the necessary government security and privacy standards for deployment as the Federal Information Security Modernization Act (FISMA) requires. Obtaining an ATO involves a structured, but flexible process defined by the Risk Management Framework (RMF). An ATO is critical for risk management, regulatory compliance, accountability, and transparency. It also establishes protocols for managing and mitigating security incidents. Unfortunately, while ATOs are required, obtaining a traditional ATO has several limitations: 

‍

• Time-Consuming: Traditional ATOs can delay the deployment of critical systems and major updates by months or even years.
  
• Static Assessments: Traditional ATOs are based on a point-in-time security check of controls which does not support near real-time changes to address changes to technology or emerging threats.. 
• Resource-Intensive: The process requires significant resources in terms of time, personnel, and documentation. Authorization is generally issued for a limited period —often three years—and expiration and major updates require reauthorization.

After receiving an initial ATO, there’s a more effective approach: continuous Authority to Operate (cATO) which allows for ongoing assessments, agile practices, and a focus on risk mitigation rather than just compliance. More on that later. Now, let’s get into the nuts and bolts of a traditional ATO package.

What Is an ATO in the DOD?

Like other federal agencies, the Department of Defense (DOD) requires ATOs to ensure a system can protect sensitive information and perform its intended functions without exposing the network to unacceptable levels of risk.  An Authorizing Official (AO) grants an ATO after evaluating and accepting the security risks associated with an information system. The ATO signifies that the system is secure enough to process, store, and transmit information. Understanding the DOD ATO Process

ATOs are granted during the seven-step RMF process following this Authorization to Operate checklist:

• Prepare: Identify key risk management roles, define an organizational risk strategy with tolerance levels, and establish a comprehensive risk assessment framework with tailored control baselines.

• Categorize: Assess the system's impact level based on confidentiality, integrity, and availability using NIST FIPS 199 guidelines.

• Select Security Controls: Based on system categorization, select a baseline set of security controls from NIST SP 800-53B, supplementing as needed to address specific risks.

• Implement Security Controls: Implement the selected security controls and document their deployment and integration within the system.

• Assess Security Controls: Verify effective risk mitigation with a comprehensive assessment of the implemented controls, including penetration testing and vulnerability scanning.

• Authorize the System: Compile an Authorization Package for the Authorizing Official's review and risk assessment to determine whether to grant the ATO based on the system’s security posture.

• Monitor Security Controls: After ATO approval, continuously monitor the system with regular assessments, updates, and reporting to maintain security and address emerging threats.
  

Note: This list is a high-level overview of the RMF process—multiple steps in each section must be completed. More information is available on NIST's website or when working with an experienced partner like Rise8. 

What Is Required for an ATO?

Obtaining an ATO involves a comprehensive evaluation of the system's security controls, adherence to regulatory requirements, and mitigation of potential risks. To achieve an ATO, you must:

1. Apply the RMF Steps: The Risk Management Framework provides a structured, but flexible approach to managing and mitigating security and privacy risks of information systems. Organizations may apply the essential RMF steps in nonsequential order to achieve an ATO.
   
   
2. Create Comprehensive Documentation: Detailed documentation demonstrating the system’s security measures, risk management strategies, and compliance with federal standards is required to achieve ATO. This includes the System Security Plan (SSP), Security Assessment Report (SAR), Risk Assessment Report (RAR), and Plan of Action and Milestones (POA&M).
   
   
3. Select Effective Security Controls: Based on risk assessments, the system must have robust baseline security controls implemented, tested, and validated with supplemental and compensating controls added to protect against threats as necessary.
   
   
4. Implement a Continuous Monitoring Plan: This involves real-time detecting, reporting, and responding to changes that may impact a system’s security posture; activities include configuration management and control, security impact analysis, and an assessment of security controls. 

What Is Required in an ATO Package?

This package compiles all necessary documentation for the Authorizing Official to make an informed decision about granting the ATO. It typically includes the SSP, RAR,  and POA&M, along with any other relevant documentation such as configuration management plans or incident response plans.

What Are the ATO Documents?

An ATO package compiles the documentation that enables the AO to make an informed authorization decision. It typically includes the SSP, RAR, POA&M, and other relevant documents such as configuration management and incident response plans.

ATO package documents examples include:

• System Security Plan (SSP): Details the system’s security requirements, control implementations, boundaries, data flows, and role assignments.
• Risk Assessment Report (RAR): Identifies potential risks, assesses their likelihood and impact, and documents mitigation strategies.
  Security Control Assessment (SCA) Report: Contains evaluation results for each control, including testing, validation, and security audit results.
• Plan of Action and Milestones (POA&M): Outlines plans to address vulnerabilities, with timelines for remediation and progress tracking.

There’s a Better Way With Rise8

Traditional ATOs, while essential, can be a barrier to rapid deployment. Continuous ATO (cATO) offers a modern alternative, integrating continuous monitoring and agile delivery with the RMF for real-time authorization and risk management, not just compliance. This approach aligns security with speed, reducing risk rather than increasing it.

At Rise8, we specialize in implementing cATO, ensuring systems are compliant, agile, and resilient in the face of evolving threats. Our approach doesn’t just check the compliance box—it enables meaningful operational impact, empowering teams to deliver secure software at the speed of need.

Ready to modernize your authorization process? Contact Rise8 today to learn how we can help you achieve continuous delivery.