Defense Acquisitions: DOD Needs to Better Support Program	 
Managers' Implementation of Anti-Tamper Protection (31-MAR-04,	 
GAO-04-302).							 
                                                                 
The U.S. government has invested hundreds of billions of dollars 
in developing the most sophisticated weapon systems and 	 
technologies in the world. Yet, U.S. weapons and technologies are
vulnerable to exploitation, which can weaken U.S. military	 
advantage, shorten the expected combat life of a system, and	 
erode the U.S. industrial base's technological competitiveness.  
In an effort to protect U.S. technologies from exploitation, the 
Department of Defense (DOD) established in 1999 a policy	 
directing each military service to implement anti-tamper	 
techniques, which include software and hardware protective	 
devices. This report reviews DOD's implementation of the	 
anti-tamper policy as required by the Senate report accompanying 
the National Defense Authorization Act for Fiscal Year 2004.	 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-04-302 					        
    ACCNO:   A09594						        
  TITLE:     Defense Acquisitions: DOD Needs to Better Support Program
Managers' Implementation of Anti-Tamper Protection		 
     DATE:   03/31/2004 
  SUBJECT:   Internal controls					 
	     Strategic planning 				 
	     Weapons systems					 
	     Weapons research and development			 
	     Policy evaluation					 
	     Policies and procedures				 

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GAO-04-302

United States General Accounting Office

GAO

Report to the Committee on Armed

                             Services, U.S. Senate

March 2004

DEFENSE ACQUISITIONS

  DOD Needs to Better Support Program Managers' Implementation of Anti-Tamper
                                   Protection

GAO-04-302

Highlights of GAO-04-302, a report to the Senate Committee on Armed
Services

The U.S. government has invested hundreds of billions of dollars in
developing the most sophisticated weapon systems and technologies in the
world. Yet, U.S. weapons and technologies are vulnerable to exploitation,
which can weaken U.S. military advantage, shorten the expected combat life
of a system, and erode the U.S. industrial base's technological
competitiveness. In an effort to protect U.S. technologies from
exploitation, the Department of Defense (DOD) established in 1999 a policy
directing each military service to implement anti-tamper techniques, which
include software and hardware protective devices.

This report reviews DOD's implementation of the anti-tamper policy as
required by the Senate report accompanying the National Defense
Authorization Act for Fiscal Year 2004.

GAO is recommending that the Secretary of Defense direct the Under
Secretary of Acquisition, Technology, and Logistics and the anti-tamper
Executive Agent to take several actions to improve oversight and assist
program offices in implementing anti-tamper protection on weapon systems.

DOD concurred or partially concurred with the recommendations, but it
suggested alternative language for several, which GAO incorporated when
appropriate.

March 2004

DEFENSE ACQUISITIONS

DOD Needs to Better Support Program Managers' Implementation of Anti-Tamper
Protection

Program managers have encountered difficulties in implementing DOD's
anti-tamper policy on individual weapon systems. First, defining a
critical technology-a basis for determining the need for anti-tamper-is
subjective, which can result in different conclusions regarding what needs
anti-tamper protection. While different organizations can check on program
managers' assessments, no organization has complete information or
visibility across all programs. Some program managers said they needed
assistance in determining which technologies were critical, but resources
to help them were limited or unknown and therefore not requested. Second,
anti-tamper protection is treated as an added requirement and can affect a
program's cost and schedule objectives, particularly if the program is
further along in the acquisition process. Programs GAO contacted
experienced or estimated cost increases, and some encountered schedule
delays when applying antitamper protection. Officials from one program
stated that their existing budget was insufficient to cover the added cost
of applying anti-tamper protection and that they were waiting for separate
funding before attempting to apply such protection. Finally, anti-tamper
techniques can be technically difficult to incorporate in some weapon
systems- particularly when the techniques are not fully developed or when
the systems are already in design or production. One program that had
difficulty incorporating the techniques resorted to alternatives that
provided less security. While DOD is overseeing the development of generic
anti-tamper techniques and tools to help program managers, many of these
efforts are still in progress, and program managers ultimately have to
design and incorporate techniques needed for their unique systems.

www.gao.gov/cgi-bin/getrpt?GAO-04-302.

To view the full product, including the scope and methodology, click on
the link above. For more information, contact Katherine V. Schinasi (202)
512-4841 or [email protected].

Contents

  Letter

Results in Brief
Background
Anti-Tamper Implementation Has Been Hampered by Several

Factors, and Support to Address Them Has Been Limited Conclusions
Recommendations for Executive Action Agency Comments and Our Evaluation
Scope and Methodology 1

1 2

5 12 13 14 15

Appendix Comments from the Department of Defense

  Figure

                   Figure 1: DOD Anti-Tamper Decision Process

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separately.

United States General Accounting Office Washington, DC 20548

  Results in Brief

March 31, 2004

The Honorable John W. Warner
Chairman
The Honorable Carl Levin
Ranking Minority Member
Committee on Armed Services
United States Senate

The U.S. government has invested hundreds of billions of dollars in
developing the most sophisticated weapon systems and technologies in
the world. Yet, U.S. weapons and technologies can be exposed to the risk
of compromise when they are exported, stolen, lost during combat, or
damaged during routine missions. When U.S. technologies are
compromised, it can weaken U.S. military advantage, shorten the expected
combat life of a system, and erode the U.S. industrial base's
technological
competitiveness in the international marketplace.

In an effort to protect U.S. technologies from exploitation, the Under
Secretary of Defense for Acquisition, Technology, and Logistics1 in 1999
directed each military service to implement anti-tamper techniques.2
Program managers are responsible for applying the techniques on
individual weapon systems. The Senate report accompanying the National
Defense Authorization Act for Fiscal Year 20043 required us to review the
Department of Defense's (DOD) implementation of the anti-tamper policy.
We conducted our work between February 2003 and August 2003 in
accordance with generally accepted government auditing standards.

Program managers have encountered difficulties in implementing DOD's
anti-tamper policy. First, defining a critical technology-a basis for
determining the need for anti-tamper protection-is subjective, which can
result in different conclusions regarding what needs protection. While
different organizations can check on program managers' critical

1Formerly this position was referred to as the Under Secretary of Defense
for Acquisition and Technology.

2Anti-tamper techniques are applied through a systems engineering
activity. Examples of techniques include software encryption and hardware
protective coatings.

3S. Rept. No. 108-46, at 345 (May 13, 2003).

technology assessments, no organization has complete information or
visibility across all programs. Some program managers said they needed
assistance in determining which technologies were critical, but resources
to help them were limited or unknown and therefore not requested. Second,
anti-tamper protection is treated as an added requirement and can affect a
program's cost and schedule objectives, particularly for those programs
that are further along in the acquisition process. Programs we contacted
experienced or estimated a cost increase, and some encountered schedule
delays when applying anti-tamper protection. Officials from one program
stated that their existing budget was insufficient to cover the added cost
of applying the protection. Finally, anti-tamper techniques can be
technically difficult to incorporate in some weapon systems-particularly
when the techniques are not fully developed or when the systems are
already in design or production. While DOD is overseeing the development
of generic anti-tamper techniques and tools to help program managers, many
of these efforts are still in progress, and program managers ultimately
have to design and incorporate unique techniques needed for their
individual systems.

We make five recommendations to DOD to better oversee and assist program
managers in implementing anti-tamper protection on weapon systems. In
written comments on a draft of this report, DOD partially concurred with
one recommendation and offered an alternative solution, which we did not
incorporate because it did not fully address the problem. DOD concurred
with our remaining four recommendations and provided alternative language
for two, which we incorporated as appropriate.

                                   Background

DOD increasingly relies on advanced technology in its weapons for
effectiveness on the battlefield and actively seeks to include foreign
partners in weapon system development and acquisition. DOD's policy also
encourages the sale of certain weapons to foreign governments through the
Foreign Military Sales Program and direct commercial sales made by
companies. While these efforts have the potential to enhance coalition
operations and reduce weapons' unit costs, DOD has acknowledged that the
efforts also risk making U.S. technologies potentially vulnerable to
exploitation. DOD reported that an increasing number of countries have
reverse engineering capability and actively seek to obtain U.S. technology
through various means.

As a method to protect critical technologies, the Under Secretary of
Defense for Acquisition, Technology, and Logistics directed the military
services in 1999 to implement anti-tamper techniques. While the

techniques will not prevent exploitation, they are intended to delay or
discourage attempts to reverse engineer critical technologies in a weapon
system or develop countermeasures to a system or subsystem.

In 2001, the Under Secretary of Defense for Acquisition, Technology, and
Logistics designated the Air Force as the Executive Agent responsible for
implementing DOD's anti-tamper policy. The Executive Agent oversees an
annual budget of about $8 million per year to implement policy and manage
anti-tamper technology projects through the Air Force Research Laboratory.
DOD, in conjunction with the Air Force Research Laboratory and the
Department of Energy's Sandia National Laboratories, also holds periodic
information sessions to educate the acquisition community about
anti-tamper policy, guidance, and technology developments. In addition,
military services and defense agencies, such as the Missile Defense
Agency, have an anti-tamper focal point to coordinate activities.

Program managers are responsible for considering anti-tamper measures on
any weapon system with critical technologies.4 Since it is not feasible to
protect every technology, program managers are to conduct an assessment to
determine if anti-tamper protection is needed. The first step of the
decision process is to determine if the system has critical technologies.
If program managers determine the system has no critical technologies,
they are to document that decision according to draft guidance.5 Program
managers of systems that contain critical technologies complete the
remaining steps of the process. Based on draft guidance, program managers
are to conceptually address how they will implement antitamper measures at
system development, otherwise known as milestone B. DOD's anti-tamper
decision process is illustrated in figure 1.6

4According to the implementation guidelines of 2000, anti-tamper measures
should be included in requirements development for all new and upgraded
programs and be considered for systems that are developed with allied
partners or exported. Anti-tamper protection is not required for programs
beyond the design phase or those in full production, unless the
responsible decision authority determines otherwise.

5Mandatory Procedures for Research and Technology Protection within the
DOD (5200.39-R), draft, March 2002.

6Variations of DOD's anti-tamper decision process can be found in
different DOD documents.

Figure 1: DOD Anti-Tamper Decision Process

Program managers can obtain assistance on their assessments from
government laboratories, contractors, and the intelligence community. They
are required to document the decision to use or not to use antitamper
techniques in a classified annex of the program protection plan,7

7The program protection plan documents the program's approach for
protecting critical program information and should include a prioritized
list of critical information and an assessment of the threats and
vulnerabilities to that information.

which is subject to approval from the program's milestone decision
authority.8

Anti-tamper techniques vary depending on the type of protection the system
requires.9 An example of an anti-tamper technique is software encryption,
which scrambles software instructions to make them unintelligible without
first being reprocessed through a deciphering technique. Another example
is a thin opaque coating placed on microelectronic components, which makes
it difficult to extract or dissect the components without great damage.
Programs can apply multiple antitamper techniques to a critical
technology. For example, a program could encrypt critical data on a
microelectronic chip that is also covered with a protective coating. Each
layer of protection could act as an obstacle to reverse engineering.

Implementation of the anti-tamper policy has been hampered by several
factors. First, identification of critical technology is subject to
interpretation and program managers and DOD officials can and have arrived
at different conclusions about what needs to be protected. Second,
applying anti-tamper protection can take time and money, which may compete
with a program manager's cost and schedule objectives. Finally, some
programs found it difficult to apply anti-tamper techniques when the
techniques were not fully developed, and others were unsure which
techniques were available to them. In general, the later anti-tamper
techniques are applied, the more difficult and costly it can be to
implement. Thus far, support to help program managers address some of
these factors has been limited.

  Anti-Tamper Implementation Has Been Hampered by Several Factors, and Support
  to Address Them Has Been Limited

Different Interpretations of DOD officials acknowledged that the
identification of critical
Critical Technologies May technologies-a basis for determining if
anti-tamper protection is
Increase the Risk of Some needed-is subjective, which can result in
different conclusions regarding

what needs protection. DOD's Program Managers Anti-Tamper HandbookGoing
Unprotected defines technology as critical if compromise results in
degrading combat

8The milestone decision authority is the individual designated to approve
entry of an acquisition program to the next phase.

9Information regarding the specific anti-tamper techniques used on an
individual system is typically classified because disclosure could aid
exploitation. In some cases, anti-tamper information is restricted at the
special access level.

effectiveness, shortening the expected combat life of the system, or
significantly altering program direction. While a broad definition allows
for flexibility to determine what is critical on individual systems, it
may increase the risk that the same technology is protected on some
systems but not on others or that different conclusions can be reached on
whether programs have critical technologies. For example:

o  	An official from an intelligence agency described a case where two
services used the same critical technology, but only one identified the
technology as critical and provided protection. The intelligence agency
official speculated that if exploited, knowledge gained from the
unprotected system could have exposed the technology on both systems to
compromise. While both systems were ultimately protected, the intelligence
agency official stated that the situation could occur again.

o  Officials from the Executive Committee10 told us that two program

managers stated that their systems had no critical technologies and

therefore were not subject to the anti-tamper policy. Both managers were
directed by the Executive Committee to reconsider their determination and
apply anti-tamper protection. As a result, one

program is in the process of determining which technologies are critical,
and the other program is applying anti-tamper protection as a condition to
export the system.

While different conclusions can be reached regarding what is critical,
various organizations can serve as a check on a program manager's
assessment. However, no organization has complete information or
visibility of all programs across the services and agencies. For example,
the anti-tamper Executive Agent and the military service focal points do
not have full knowledge about which program offices have or have not
identified critical technologies or applied anti-tamper protection.11 In
2001, DOD attempted to collect such information,12 but not all programs

10 The Low Observable/Counter Low Observable Executive Committee
establishes security guidelines to protect stealth technology and ensures
exports are consistent with DOD policy.

11The Counterintelligence Field Activity and the Defense Intelligence
Agency are developing a database that will contain information regarding
critical program information for programs across the services.

12This effort was in response to the Under Secretary of Defense's
direction in 1999 that the acquisition executives determine the extent to
which anti-tamper protection was incorporated in weapon systems.

provided data and DOD did not corroborate what was provided to ensure that
program officials were consistently assessing critical technologies. The
Executive Agent stated that there are no plans to update this data.
Conducting oversight over program managers' assessments may be difficult
because of limited resources. Specifically, the Executive Agent has two
full-time staff and the military service focal points perform duties other
than anti-tamper management. Furthermore, according to a military
official, program offices that determine they have no critical
technologies are not required to obtain the focal points' concurrence.
While other organizations can review a program manager's critical
technology assessment as part of various acquisition and export processes,
they may not have a full perspective of the assessments made by all
programs across the services and the agencies. For example, different
milestone decision authorities only review an individual program manager's
critical technology decisions for programs coming under their
responsibility. Also, the Executive Committee may weigh in on the
determinations, but it only reviews exports involving stealth technology.

While it was apparent that the systems had critical technologies, some
program managers needed assistance to determine which specific
technologies were critical. For example, a program office tasked the
contractor to identify critical technologies, and it has worked for months
with the contractor to agree upon and finalize a list of critical
technologies on the system. Also, an intelligence official, who is
available to assist program managers in assessing their systems'
criticality, found that some program managers identified too many
technologies as critical and that others did not identify all of the
systems' critical elements. In one instance, a program manager indicated
that a system had 400 critical technologies, but an intelligence agency
narrowed down the list to about 50 that it considered critical. In another
case, a program manager concluded that an entire system was one critical
technology, but the intelligence agency recommended that the system's
technologies be broken down and identified approximately 15 as critical.

Although there are various resources to help program managers identify
critical technologies, they may have limited utility, or may not be known,
and therefore not requested. For example, the Militarily Critical
Technologies List-cited in guidance as a primary reference for program
managers-may not be up to date and may not include all technologies,
according to some DOD officials. Another resource-the Program

Managers Anti-Tamper Handbook-contains information regarding critical
technology determinations, but program managers are not always aware that
the handbook exists, in part because it is not widely distributed.13 In
addition, the Defense Intelligence Agency can conduct an independent
assessment of a system's critical elements and technologies, if requested
by the program manager. However, many officials we interviewed were
unaware that the agency provides this assistance. According to a military
official, the focal points are available to review a program manager's
assessment if requested.

In some instances, program managers may have differing perceptions of what
constitutes a critical technology. According to DOD's guidance, critical
technologies can be either classified or unclassified. However, an
anti-tamper focal point stated that there is a perception that the
antitamper policy only applies to classified programs. We found in one
instance that the manager for a weapon program stated that the program did
not require anti-tamper protection because it had no critical technologies
that were classified.14

    Applying Anti-Tamper Protection Can Affect Cost and Schedule Objectives

Applying anti-tamper protection takes money and time, which can affect a
program manager's cost and schedule objectives. Generally, anti-tamper
implementation is treated as an added requirement that is not separately
funded for most programs.15 Program officials acknowledged that antitamper
costs can be difficult to estimate and isolate because they are
intertwined with other costs, such as research and development or
production costs. As we have found in prior work, the later a requirement
is identified, the more costly it is to achieve.16

13According to DOD officials, the handbook contains classified information
and they need to verify that a program office can accept and store
classified information before they distribute it.

14This program office estimated that 30 systems had been lost during
military operations. In addition, DOD reported that this technology has
been targeted for reverse engineering.

15One program we contacted was authorized separate congressional funding
for antitamper costs.

16Best Practices: Setting Requirements Differently Could Reduce Weapon
Systems' Total Ownership Costs, GAO-03-57 (Washington, D.C.: Feb. 11,
2003).

Most programs we visited experienced or estimated cost increases, and some
encountered schedule delays as they attempted to apply anti-tamper
techniques. For example:

o  	A program official told us the anti-tamper protection for a program
upgrade increased both design and production costs for the receiver unit.
The program official stated that the anti-tamper protection increased
total unit cost by an estimated $31 million, or 10 percent. Program
officials expressed concern that unit cost increases may affect
procurement decisions, particularly for one service, which is the largest
acquirer of units and may be unable to purchase the proposed number.

o  	A program office estimated that it needs a budget increase of $56
million, or 10 percent, to fund the desired anti-tamper protections.
Officials from that program told us that the existing program budget was
inadequate to fund the added anti-tamper requirements. As a result, the
program manager requested, and is waiting for, separate funding before
attempting to apply anti-tamper protection to the system.

o  	One program office awarded a contract modification for the design,
implementation, and testing of anti-tamper techniques valued at $12.5
million. Initially, the contractor had estimated the anti-tamper costs to
be $35 million, but the program office did not approve all techniques
suggested by the contractor. In addition, the contractor estimated that
the recurring unit price for anti-tamper protection on future production
lots may be $3,372 per unit. The U.S. government and the contractor have
not completed unit price negotiations. Program officials told us that
anti-tamper implementation contributed to a 6-month schedule delay.

o  	Another program office estimated that $87 million is needed to protect
two critical technologies with multiple anti-tamper techniques. The
program office expects that half of the anti-tamper budget will be used to
test the techniques. The anti-tamper protection will only be applied if
the system is approved for export. At that time, program officials will
reexamine the anti-tamper cost estimates. In addition, it may take 5 years
to adequately apply the techniques.

o  	Officials from an international program stated that, thus far, they
have experienced a 60-day schedule delay while they wait for the
contractor to estimate the system's anti-tamper cost. Program officials
stated that the potential for increased costs and additional schedule
delays is high.

Program officials and representatives from the Executive Committee stated
that the cost of anti-tamper protection can be significantly higher for an
international program for various reasons, including that the U.S. version
and the international version of the system may require different
anti-tamper techniques.

Cost and schedule impacts may also be more significant if the programs are
further along in the acquisition process when program offices first
attempt to apply anti-tamper protection. Several programs that have
experienced significant cost increases or delays were in or beyond the
program development phase when they attempted to apply anti-tamper
techniques. For example, when the anti-tamper policy was issued, one
program had just obtained approval to begin system development and program
officials believed it was too late to implement anti-tamper protection. As
a result, the program received an interim waiver17 of the anti-tamper
policy, and it only plans to apply anti-tamper techniques if the system is
approved for export. While DOD has not systematically collected cost data
for anti-tamper application across programs, DOD officials have stated
that it is more cost-effective for programs to consider anti-tamper
requirements at program inception, rather than later in the acquisition
process. An official from a program that applied anti-tamper techniques in
the production phase stated that ideally a program should identify its
antitamper needs, including cost and technology, as early as possible.
Recent Army anti-tamper guidance indicates that programs should receive
approval for their preliminary anti-tamper plans at the concept stage.

    Needs Outpace Availability of Techniques and Tools

Anti-tamper techniques can be technically difficult to incorporate on a
weapon system, such as when the technology is immature. DOD is working to
oversee the development of generic anti-tamper techniques and tools to
help program managers identify potential techniques, but many of these
efforts are still in progress and it is uncertain how they will help
program managers. While program managers want knowledge about generic
techniques, they ultimately have to design and incorporate techniques
needed for their unique systems to ensure protection of critical
technologies and to meet performance objectives.

17According to representatives from the Executive Committee, DOD can waive
the antitamper requirement when a program can make a compelling reason for
forgoing the policy.

Problems in applying anti-tamper techniques typically arose when the
programs were already in design or production or when the techniques were
not fully developed or specifically designed for the system. For example:

o  	Officials from a program told us that they experienced problems when
applying an anti-tamper protective coating. Because the team applying the
coating did not coordinate with teams working on other aspects of the
system, the problems with the coating were not discovered until just
before production. Prior to an initial development test, the program
office received a temporary waiver to test the system without the
anti-tamper technique because the coating caused malfunctioning. The
program office and its contractor are working to resolve issues with the
anti-tamper technique.

o  	A program office was not able to copy anti-tamper techniques used by a
similar program and, therefore, attempted to apply a generically developed
anti-tamper coating, which resulted in problems. Specifically, the coating
caused the system to malfunction, so the program office requested
assistance from a national laboratory, but the laboratory's solution
melted key components of the system. Therefore, the program office
requested that the contractor develop a new coating and other methods of
protection for the system. The contractor's antitamper techniques were
successfully applied to the system.

o  	One program required advanced anti-tamper techniques to protect
miniaturized internal components, but the technology was still in
development and not available for immediate application. According to
program officials, research and development of the anti-tamper technique
was originally expected to be completed in 2002 and is now estimated to be
available in 2006. Currently, officials are uncertain that the technique
will meet their needs because the technique is being generically
developed. In the absence of being able to apply the antitamper technique,
the program received approval from DOD to use procedural protections,
whereby U.S. military personnel provide physical security of the system
when it is used in foreign countries, which includes locking the unit in a
protected room to restrict access by foreign nationals. DOD officials
stated that physical security can be less reliable than actual anti-tamper
protection.

Some program managers told us that they need more help in deciding what
anti-tamper techniques they should apply to their individual systems. To
provide information, DOD has a classified database that describes current
anti-tamper techniques. An Air Force Research Laboratory official

stated that they are in the process of updating this database, developing
a rating system on the value of various techniques to be included in the
database, and creating a classified technology road map that will
prioritize the needs for various anti-tamper techniques. These tools are
currently unavailable.18 DOD and Sandia National Laboratories also have
provided information on anti-tamper techniques and tools to program
managers at periodic workshops where attendance is voluntary.

To further assist program managers, DOD is in the process of overseeing
the development of generic anti-tamper techniques, but it is uncertain to
what extent such techniques address a program's specific needs. In 2001,
DOD issued several contracts to encourage anti-tamper technology
development. To date, several defense contractors have provided antitamper
technology concepts, but according to the Executive Agent, programs need
to further develop the technology before it can be applied to and function
on a particular system. According to Air Force Research Laboratory and
Sandia National Laboratories officials, generic anti-tamper techniques can
be considered, but program managers have to design and incorporate the
techniques needed for their unique systems. Program managers ultimately
have to ensure that the techniques protect critical technologies and do
not adversely affect performance objectives for the system.

Anti-tamper protection is one of the key ways DOD can preserve U.S.
investment in critical technologies, while operating in an environment of
coalition warfare and a globalized defense industry. However,
implementation of the anti-tamper policy, thus far, has been difficult-in
part because DOD has not developed an implementation strategy to ensure
success. For program managers expected to implement anti-tamper
protection, the policy can compete with their goals of meeting cost and
schedule objectives, particularly when the anti-tamper requirement is
identified late in the system development process. Without providing more
oversight and guidance about what needs to be protected and how to do so,
DOD is at risk of program managers making decisions on individual programs
that can result in unprotected technologies and have negative consequences
for maintaining the military's overall technological advantage.

18According to a laboratory official, an initial prototype of an updated
database is estimated to be available in 2004.

  Conclusions

  Recommendations for Executive Action

We are recommending that the Secretary of Defense direct the Under
Secretary of Acquisition, Technology, and Logistics and the anti-tamper
Executive Agent to take the following five actions to improve oversight
and assist program offices in implementing anti-tamper protection on
weapon systems.

To better oversee identification of critical technologies for all programs
subject to the anti-tamper policy, we recommend that the Secretary of
Defense direct the Under Secretary for Acquisition, Technology, and
Logistics, in coordination with the Executive Agent and the focal points,
to (1) collect from program managers information they are to develop on
critical technology identification and (2) appoint appropriate technical
experts to centrally review the technologies identified for consistency
across programs and services.

To better support program managers in the identification of critical
technologies, the Secretary of Defense should direct the Under Secretary
for Acquisition, Technology, and Logistics, in coordination with the
Executive Agent and the focal points, to (1) continue to identify
available anti-tamper technical resources, (2) issue updated policy
identifying roles and responsibilities of the technical support
organizations, and (3) work with training organizations to ensure training
includes practical information on how to identify critical technologies.

To help minimize the impact to program cost and schedule objectives, the
Secretary of Defense should direct the Under Secretary for Acquisition,
Technology, and Logistics to work with program managers to ensure that the
cost and techniques needed to implement anti-tamper protection are
identified early in a system's life cycle and to reflect that practice in
guidance and decisions.

To maximize the return on investment of DOD's anti-tamper technology
efforts, the Secretary of Defense should direct the Executive Agent to
monitor the value of developing generic anti-tamper techniques and
evaluate the effectiveness of the tools, once deployed, in assisting
program managers to identify and apply techniques on individual programs.

To ensure successful implementation of the anti-tamper policy, the
Secretary of Defense should direct the Under Secretary for Acquisition,
Technology, and Logistics to develop a business case that determines
whether the current organizational structure and resources are adequate to
implement anti-tamper protection and if not, what other actions are needed
to mitigate the risk of compromise of critical technologies.

  Agency Comments
  and Our Evaluation

In written comments on a draft of this report, DOD partially concurred
with one recommendation and offered an alternative solution, which we did
not incorporate. DOD concurred with our remaining four recommendations and
provided alternative language for two, which we incorporated as
appropriate. DOD's letter is reprinted in the appendix.

DOD partially concurred with our recommendation to collect and centrally
review the program's critical technology identifications and proposed,
instead, that it develop a standardized process to minimize subjectivity,
incorporate that process into anti-tamper policy, and monitor subsequent
implementation. As part of its rationale, DOD stated that technical
representatives in the services currently work with program managers to
implement the anti-tamper policy and that quarterly conferences and
seminars are ways to disseminate important information to program
managers. We believe DOD's proposal is an improvement over the current
process given that program managers need more technical support and
guidance to identify critical technologies. However, we do not believe
DOD's proposal is sufficient because a central review mechanism is needed
to ensure consistent critical technology identification across the
services and the agencies. Without central visibility over program
managers' critical technology identifications, the risk exists that the
same technology is protected on some systems but not on others. Knowledge
gained from unprotected systems can expose critical technology to
compromise, which minimizes the impact of anti-tamper protection. In
addition, DOD's dissemination of information at conferences may be limited
because conference attendance is voluntary and all program managers may
not attend and receive the information. Given the need for consistency and
a central review, we did not revise our recommendation.

DOD concurred with our remaining recommendations, but offered alternative
language for two, which we incorporated. Specifically, for our
recommendation aimed at better supporting program managers in identifying
critical technologies, DOD proposed adding language that underscored the
need for identifying technical resources and maintaining up-to-date
policies on technical support organizations' roles and responsibilities.
While DOD has identified some resources and listed them in several
documents, it has not developed a comprehensive list of resources to
assist program managers. Therefore, we added to our recommendation that
DOD continue to identify available anti-tamper technical resources. For
our recommendation that DOD evaluate generic anti-tamper techniques, DOD
proposed language that offered greater flexibility, which seemed
reasonable and we incorporated.

  Scope and Methodology

To determine how DOD implemented the anti-tamper policy, we collected data
and interviewed officials from 17 programs, which were identified by DOD
as having experience with implementing the policy or by us through our
review. Twelve of the 17 programs reported that their systems had critical
technologies, and most were in various stages of implementing the
anti-tamper policy. From those programs we selected six for an in-depth
review. We conducted structured interviews with the six programs that had
identified critical technologies on their systems to understand their
experiences with applying anti-tamper techniques. We selected systems that
represented a cross-section of acquisition programs and various types of
systems in different phases of development. To the extent possible, when
selecting the programs for an in-depth review, we considered factors that
may increase a system's vulnerability and exposure to exploitation. We
also considered whether the system was approved for export by examining
the Defense Security Cooperation Agency's data on foreign military sales.
In addition, we analyzed available program information from the
anti-tamper Executive Agent and the military focal points to determine
programs reporting critical technologies and anti-tamper plans. DOD
acknowledged that the information was incomplete, and we did not
independently verify the reliability of the data.

We supplemented the program information by interviewing the Executive
Agent, the military focal points, representatives from the intelligence
community, DOD's Executive Committee, the Department of Energy's Sandia
National Laboratories, the Air Force Research Laboratory, defense
contractors, and an electronic security specialist. We also discussed
DOD's anti-tamper policy with current and former officials from the Office
of the Secretary of Defense. To observe DOD's training of program
managers, we attended a DOD anti-tamper information workshop and a
quarterly review. We analyzed pertinent DOD policies, directives,
instructions, and guidance governing anti-tamper protection on systems. We
also conducted a literature search to obtain information on program
protection and industry practices related to anti-tamper measures.

We are sending copies of this report to interested congressional
committees; the Secretary of Defense; and the Director, Office of
Management and Budget. We will make copies available to others upon
request. In addition, this report will be available at no charge on the
GAO Web site at http://www.gao.gov.

If you or your staff have any questions concerning this report, please
call
me at (202) 512-4841. Others making key contributions to this report were
Anne-Marie Lasowski, Yelena T. Harden, Gregory K. Harmon, and Holly
Ciampi.

Katherine V. Schinasi
Managing Director
Acquisition and Sourcing Management

Appendix: Comments from the Department of Defense

 Appendix: Comments from the Department of Defense Appendix: Comments from the
    Department of Defense Appendix: Comments from the Department of Defense

Appendix: Comments from the Department of Defense

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