As regulatory frameworks like FedRAMP evolve, organizations face increasing pressure to meet compliance requirements efficiently and effectively. The drive towards automation using Open Security Controls Assessment Language (OSCAL) compliance has highlighted a significant challenge: many organizations lack the tools and expertise to create, manage, submit, and review OSCAL authorization packages, resulting in an expenditure of more time and resources.
The team behind Xacta®, however, has anticipated this need by developing the platform to integrate OSCAL.
The Challenge
OSCAL is a machine-readable format designed to standardize the creation and management of SSPs and other compliance artifacts. Machine-readable, though, does not always mean human-comprehensible. Implementing OSCAL can be a significant lift, requiring both expertise and experience. Organizations without subject matter (SME) expertise may find creating OSCAL documents particularly daunting and still a very manual process.
Validating the quality of the OSCAL package produced can have its own set of challenges. The process of reviewing the validation results, understanding the errors, identifying the root cause for each finding, and addressing the finding in the data is a challenge for anyone not familiar with reading code.
Cloud Service Providers (CSPs) also face significant challenges due to varying OSCAL submission requirements across agencies. While FedRAMP has a defined baseline of controls, other agencies have not yet established OSCAL standards or rely on different submission processes. This lack of alignment will force CSPs to produce multiple OSCAL packages tailored to each agency, increasing complexity and operational overhead.
Without a flexible system to accommodate the challenge of providing a human-readable interface with an automated and flexible machine-readable ready package generator, organizations may risk submitting invalid or incomplete System Security Plans (SSPs). This can lead to delays or even rejection of their Authority to Operate (ATO), potentially resulting in significant costs or lost revenue opportunities.
Xacta has been designed to remove barriers to OSCAL compliance. Xacta 360™ allows CSP stakeholders to manage their data within an easy-to-understand user interface. Xacta Bridge™ (a proprietary OSCAL translation module) provides a flexible means of meeting complex and changing requirements without code changes. The Xacta suite is designed to bridge the gap to OSCAL by automating the generation of an organization’s submission package and artifacts in OSCAL. This means that Xacta empowers organizations to focus on what is important, proactively managing their risk and compliance —not the underlying code or structure.
With Xacta, organizations can:
1) Simplify requirements management: Xacta allows organizations to design their requirements using intuitive templates rather than code. Organizations can define controls, artifacts, and supplemental guidance—all within Xacta—to generate an OSCAL baseline profile and begin their OSCAL journey.
In the case of federal agencies, this baseline profile can then be shared with cloud service providers so they can meet the agency’s security standards.
In the case of cloud service providers seeking FedRAMP authorization, the team behind Xacta has designed a custom template to meet FedRAMP’s OSCAL requirements. CSPs leveraging this template can generate their packages in OSCAL, simplifying the process and typically saving significant amounts of time.
2) Automate OSCAL exports: Xacta Bridge translates the Xacta data into the OSCAL structure, bridging the gap between human-readable data in the interface and the machine-readable structure required by OSCAL. Additionally, during the translation process, Xacta Bridge thoroughly reviews and identifies gaps in the package. Using the OSCAL-CLI tool developed by NIST and FedRAMP, we validate the package and report any constraints after processing. This proactive approach helps CSPs refine their packages before submission, ensuring that your OSCAL files consistently meet agency standards.
3) Comply with multiple frameworks: Xacta’s powerful overlay functionality allows organizations to manage multiple frameworks simultaneously. For example, a CSP can seamlessly switch or stack FedRAMP and DoD requirements within the same project, generating tailored SSPs in OSCAL format for each agency.
Different requirements are no longer a roadblock to compliance. Xacta experts can work with you to create OSCAL data models that support multiple organization requirements.
4) Maintain compliance moving forward: Unique functionality built into Xacta ensures that, as regulatory requirements evolve, new controls or updates can be mapped and integrated into your existing system with minimal effort.
Additionally, the version control functionality standard in Xacta allows organizations to save and manage multiple versions of their SSPs. This enables compliance teams to maintain a record of previous documentation and refer to it whenever necessary.
The Path Forward: A Call to Action for Agencies
While FedRAMP has taken the lead in defining OSCAL requirements, other agencies will also need to define their requirements to ensure reciprocity. As new baselines are released by other federal agencies, CSPs may struggle to expand their packages to meet multiple agency expectations. Platforms like Xacta can bridge this gap and support agencies in defining and creating their requirements and driving adoption.
Conclusion
As the deadlines set by the OMB approach, the need for efficient, reliable solutions to define requirements and create SSPs becomes more critical than ever.
The team behind Xacta has developed the platform to empower organizations to accelerate compliance by automatically generating required documentation. For CSPs looking to remove the complexities from their compliance journey—or for agencies aiming to establish their OSCAL baselines—Xacta is designed to not only simplify the process of creating required documentation in OSCAL but also streamline the process of complying with future regulations.
