Information Assurance: National Partnership Offers Benefits, but 
Faces Considerable Challenges (24-MAR-06, GAO-06-392).		 
                                                                 
In 1997, the National Security Agency and the National Institute 
of Standards and Technology formed the National Information	 
Assurance Partnership (NIAP) to boost federal agencies' and	 
consumers' confidence in information security products		 
manufactured by vendors. To facilitate this goal, NIAP developed 
a national program that requires accredited laboratories to	 
independently evaluate and validate the security of these	 
products for use in national security systems. These systems are 
those under control of the U.S. government that contain 	 
classified information or involve intelligence activities. GAO	 
was asked to identify (1) the governmentwide benefits and	 
challenges of the NIAP evaluation process on national security	 
systems, and (2) the potential benefits and challenges of	 
expanding the requirement of NIAP to non-national security	 
systems, including sensitive but unclassified systems.		 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-06-392 					        
    ACCNO:   A50017						        
  TITLE:     Information Assurance: National Partnership Offers       
Benefits, but Faces Considerable Challenges			 
     DATE:   03/24/2006 
  SUBJECT:   Cyber security					 
	     Evaluation criteria				 
	     Evaluation methods 				 
	     Information security				 
	     Information technology				 
	     Product evaluation 				 
	     Program evaluation 				 
	     Systems evaluation 				 
	     Information management				 
	     Joint ventures					 

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GAO-06-392

     

     * Report to the Honorable William Lacy Clay, House of Representatives
          * March 2006
     * INFORMATION ASSURANCE
          * National Partnership Offers Benefits, but Faces Considerable
            Challenges
     * Contents
          * Results in Brief
          * Background
               * Federal Partnership Formed to Promote the Use of Evaluated
                 IT Products
               * Federal Policy Requires Evaluated Products for National
                 Security Systems
               * NIAP Evaluation Process Contributes to System Security, but
                 Is Not a Complete Solution
          * NIAP Offers Benefits for Use in National Security Systems, but
            Process Faces Considerable Challenges
               * NIAP Evaluation Process Offers Benefits
                    * Independent Testing and Evaluation of Products and
                      Accreditation of Laboratories Can Increase Product
                      Assurance
                    * NIAP Membership in International Recognition
                      Arrangement Gives Agencies Broader Product Selection
                      and Reduces Vendor Burden
                    * Product Evaluations Can Uncover Flaws and Cause Vendors
                      to Fix Them
                    * Product Evaluations Can Result in Improvements to
                      Vendors' Development Processes
               * NIAP Evaluation Process Faces Challenges
                    * NIAP-Evaluated Products Do Not Always Meet Agencies'
                      Needs
                    * Lack of Vendors Awareness of NIAP Evaluation Process
                      Affects Efficiency of Evaluations
                    * Reduction in the Number of Validators May Affect
                      Timeliness of Certifications
                    * Lack of Performance Measures and Difficulty in
                      Documenting the Effectiveness of the NIAP Process
          * Expanding NIAP Requirement to Non- national Security Systems May
            Yield Many of the Same Benefits and Challenges and Could
            Exacerbate Resource Constraints
          * Conclusions
          * Recommendations for Executive Action
          * Agency Comments and Our Evaluation
     * Objectives, Scope, and Methodology
     * Common Criteria Evaluation Assurance Levels
     * Comments from the Department of Defense
     * GAO Contact and Staff Acknowledgments

Report to the Honorable William Lacy Clay, House of Representatives

March 2006

INFORMATION ASSURANCE

National Partnership Offers Benefits, but Faces Considerable Challenges

Contents

Table

Figures

March 24, 2006 Letter

The Honorable William Lacy Clay House of Representatives

Dear Mr. Clay:

The sophistication and effectiveness of cybersecurity attacks have
advanced steadily over the past few years and have drastically changed the
way we think about protecting our information and information systems,
including national security systems.1 Commercial-off-the-shelf information
assurance products and information assurance-enabled products or
technologies2 are readily available to agencies as well as consumers
providing needed security services. Acquiring such products for use on
national security systems that perform as claimed by the vendors who
manufacture these products is a governmentwide challenge.

In 1997, the National Information Assurance Partnership (NIAP) was formed
by the National Security Agency and the National Institute of Standards
and Technology (NIST) to boost federal agencies' and consumers' confidence
in commercial-off-the-shelf products. To facilitate this goal, NIAP
developed a national program that uses accredited laboratories to
independently evaluate and validate the security of vendor products using
standardized processes. The NIAP program allows the U.S. to meet federal
agency needs by participating in an international arrangement to validate
security products using standardized processes. In addition, the Committee
on National Security Systems established a federal policy which mandates,
among other things, the use of NIAP-evaluated products for national
security systems. Further, the policy allows but does not require users of
non-national security systems to acquire NIAP-evaluated products.

Our objectives were to identify (1) the governmentwide benefits and
challenges of the NIAP evaluation process for national security systems
and (2) the potential benefits and challenges of expanding the requirement
of using NIAP-evaluated products for non-national security systems,
including sensitive but unclassified systems. To address these objectives,
we obtained perspectives from selected industry groups and various NIAP
process participants, such as vendors, accredited laboratories, and
government officials. We also developed and submitted a survey
questionnaire to the 24 federal agencies-also process participants-cited
in the Chief Financial Officer's Act of 1990 (Public Law 101-576) to
determine their use of, and perspectives on, NIAP-evaluated products. In
addition, we analyzed documentation related to NIAP evaluation and
validation policies and processes, test and evaluation criteria, and
laboratory accreditation processes. We conducted our work in Washington,
D.C., from May 2005 through February 2006, in accordance with generally
accepted government auditing standards. See appendix I for more details
about our objectives, scope, and methodology.

Results in Brief

While the NIAP process offers benefits to national security systems, its
effectiveness has not been measured or documented, and considerable
challenges to acquiring and using NIAP-evaluated products exist. Specific
benefits include

o independent testing and evaluation of products and accreditation of the
performing laboratories, which can increase agencies' confidence that
products will perform as claimed;

o the ability to participate in an international arrangement of recognized
products, which gives agencies broader product selection and reduces
vendor workload;

o the discovery and correction of product flaws, which help to give
agencies greater confidence that the product will perform as claimed; and

o improvements to vendor development processes, which can result in
quality improvements to current and future products.

However, the NIAP process also faces several challenges, including

o difficulty in matching agencies' needs with the availability of
NIAP-evaluated products;

o vendors' lack of awareness regarding the evaluation process;

o a reduction in the number of validators to certify products; and

o a lack of performance measures and difficulty in documenting the
effectiveness of the NIAP process.

Collectively, these challenges hinder the effective use of the NIAP
process by vendors and agencies.

Expanding the requirement of the NIAP evaluation process to non-national
security systems is likely to yield the same benefits and challenges as
those experienced by current process participants. While federal policy
allows agencies with non-national security systems to consider using the
NIAP process to acquire evaluated and validated products, requiring that
they do so may further exacerbate current resource constraints related to
the evaluation and validation of products. In the absence of such a
requirement, agencies seeking information assurance for their non-national
security systems have other federal guidance and standards available to
them.

We are making recommendations to assist NIAP officials in addressing
process challenges, including developing awareness training workshops for
program participants and establishing and documenting performance measures
on process effectiveness.

In providing written comments on a draft of this report, the Deputy
Assistant Secretary of Defense (Deputy Chief Information Officer)
partially agreed with one of our recommendations, agreed with the other,
and described ongoing and planned efforts to address them. The Deputy
Assistant Secretary's comments are reprinted in appendix III. The
Department of Defense and the Department of Homeland Security also
provided technical comments, which we considered and addressed in our
report, as appropriate.

Background

The growing sophistication and effectiveness of cyber attacks, and the
increase of information assurance and information assurance-enabled
information technology (IT) products available for use on national
security systems, have heightened federal attention to the need for
information assurance.3 As a result of these trends, acquiring commercial
IT products that perform as vendors claim on national security systems has
become a governmentwide challenge. While not a complete solution, an
important way to increase confidence in commercial IT products is through
independent testing and evaluation of their security features and
functions during design and development.

Federal Partnership Formed to Promote the Use of Evaluated IT Products

In 1997, NIST and the National Security Agency4 collaborated to form the
NIAP. The purpose of the partnership is to boost consumers' and federal
agencies' confidence in information security products and enhance the
ability of U.S. companies to gain international recognition and acceptance
for their products. The five main goals of NIAP are to:

o promote the development and use of evaluated IT products and systems;

o champion the development and use of national and international standards
for IT security;

o foster research and development in IT security requirements definition,
test methods, tools, techniques, and assurance metrics;

o support a framework for international recognition and acceptance of IT
security testing and evaluations; and

o facilitate development and growth of a commercial security testing
industry within the U.S.

To facilitate achievement of these goals, NIAP developed a national
program called the Common Criteria Evaluation and Validation Scheme. The
program is based on an international standard of general concepts and
principles of IT security evaluations5 for the international community.
The program evaluates, through various evaluation assurance levels (see
app. II),6 commercial-off-the-shelf information assurance and information
assurance-enabled products for the federal government. These products can
be items of hardware, software, or firmware.7

7Computer programs that are stored in read-only memory are called
firmware.

As part of the evaluation, agencies can specify a degree of confidence
desired in a product through protection profiles.8 While a protection
profile is not required in order to have a product evaluated, a vendor is
required to develop a security target.9

NIAP evaluations are performed by accredited Common Criteria testing
laboratories.10 While a product is undergoing evaluation, the NIAP
validation body-an activity currently managed by the National Security
Agency-approves participation of security testing laboratories in
accordance with accreditation policies and procedures.11 It also reviews
the results of the security evaluations performed by the laboratories and
issues a validation report, which summarizes and provides independent
validation of the results. A product is considered NIAP-certified only
after it is both evaluated by an accredited laboratory and validated by
the validation body. Upon successful completion of these requirements, the
validation body issues a Common Criteria certificate for the evaluated
product. All evaluated products that receive a NIAP Common Criteria
certificate appear on a validated products list available on NIAP's Web
site. According to the Committee on National Security Systems12-a forum
for the discussion of policy issues that sets federal policy and
promulgates direction, operational procedures, and guidance for the
security of national security systems-the fact that a product appears on
the validated products list does not by itself mean that it is secure. A
product's listing on any Common Criteria validated products list means
that the product was evaluated against its security claims and that it has
met those claims.13 Figure 1 outlines the NIAP evaluation process.

Figure 1: The NIAP Evaluation Process

In order to maintain the validity of an evaluation when a product upgrades
to its next version, a vendor can request either a re-evaluation of the
entire new product version or validation of only the changes in the
product. To request the latter, a vendor must participate in the NIAP
Assurance Maintenance Program. To participate in this program, a vendor
must submit a request that addresses how it plans to maintain the product
and a report of what will be maintained.

Vendors can select any one of the 10 accredited commercial testing
laboratories to perform product evaluations.14 The vendor and testing
laboratory negotiate evaluation costs, which can vary according to the
laboratory and the assurance level the product is tested against15 (see
fig. 2).

Figure 2: Range of Sample Cost of NIAP Evaluations to Vendors by
Evaluation Assurance Level

Other factors that influence the overall cost of NIAP product evaluations
include

o the scope of evaluation-the tendency of vendors to include elements in
their security target that agencies may not require introduces additional
costs; and

o the design of the product-if a product is designed so that its security
functions are performed by a small number of modules, it may be possible
to limit the portion of the product that must be examined.

Federal Policy Requires Evaluated Products for National Security Systems

In January 2000, as revised in June 2003, a federal policy was established
that required the use of evaluated products for national security systems.
Specifically, the Committee on National Security Systems established
National Security Telecommunications and Information Systems Security
Policy Number 11.16 The policy required, effective July 1, 2002, that all
commercial-off-the-shelf information assurance and information
assurance-enabled IT products acquired for use on national security
systems be evaluated and validated in accordance with one of the following
criteria:

1.The International Common Criteria for Information Security Technology
Evaluation Recognition Arrangement,17

2.The NIAP Common Criteria Evaluation and Validation Scheme,

3.The NIST Federal Information Processing Standards Cryptographic Module
Validation Program.18

The objective of the policy is to ensure that these products, which are
acquired by the federal government, undergo a standardized evaluation
validating that a product either performs as its claims or meets the
user's security requirements. The policy requires that the evaluation and
validation of such products be conducted by accredited commercial
laboratories or by the National Security Agency for government off-the
shelf products. It does not require mandatory compliance for information
assurance products acquired prior to July 1, 2002, and includes a
provision for deferred compliance, on a case-by-case basis, when
information assurance-evaluated products do not cover the full range of
potential user application, or do not incorporate the most current
technology.

Moreover, while not a requirement, the federal policy includes provisions
for departments and agencies who may wish to consider using the NIAP
process for the acquisition and appropriate implementation of evaluated
and validated products for non-national security systems.

NIAP Evaluation Process Contributes to System Security, but Is Not a
Complete Solution

The use of commercial products that have been independently tested and
evaluated is only a part of a security solution that contributes to the
overall information assurance of a product. Other complementary controls
are needed, including sound operating procedures, adequate information
security training, overall system certification and accreditation,19 sound
security policies, and well-designed system architectures. According to
the Committee on National Security Systems, the protection of systems
encompasses more than just acquiring the right product. The committee
notes that once acquired, these products must be integrated properly and
subjected to a system accreditation process, as discussed above, which
will help to ensure the integrity of the information and systems to be
protected.

For federal agencies, such an overall security solution is spelled out by
the Federal Information Security Management Act. The act requires federal
agencies to protect and maintain the confidentiality, integrity, and
availability of their information and information systems. Among other
things, the act requires each agency (including agencies with national
security systems) to develop, document, and implement agencywide
information security programs to provide information security for the
information and information systems that support the operations and assets
of the agency, including those provided or managed by another agency,
contractor, or other source.

More specifically, the Federal Information Security Management Act
stipulates that the head of each agency operating or exercising control of
a national security system is responsible for providing information
security protections commensurate with the risk and magnitude of harm that
could result should a security breach occur. The act also stipulates that
agency heads are responsible for implementing information security
policies and practices as required by standards and guidelines for
national security systems. The Department of Defense and the Director of
Central Intelligence have authority under the act to develop policies,
guidelines, and standards for national security systems.

The Federal Information Security Management Act also requires NIST, among
other things, to provide technical assistance to agencies; to evaluate
private sector security policies and practices; to evaluate commercially
available IT, as well as practices developed for national security
systems; and to assess the potential application by agencies to strengthen
information security for non-national systems.

NIAP Offers Benefits for Use in National Security Systems, but Process
Faces Considerable Challenges

While the NIAP evaluation process offers benefits to national security
systems, its effectiveness has not been measured or documented, and
considerable challenges to acquiring and using NIAP-evaluated products
exist.

NIAP Evaluation Process Offers Benefits

NIAP process participants-vendors, laboratories, federal agencies, and
NIAP officials-identified benefits to using the process for use in
national security systems, including

o independent testing and evaluation of IT products and accreditation of
the performing laboratories, which can give agencies confidence that the
products will perform as claimed;

o international recognition of evaluated products, which provides agencies
broader product selection and reduces vendor burden;

o discovery of software flaws in product security features and functions,
which can cause vendors to fix them; and

o improvements to vendor development processes, which help to improve the
overall quality of current and future products.

Independent Testing and Evaluation of Products and Accreditation of
Laboratories Can Increase Product Assurance

Independent testing and evaluation of commercial IT products and
accreditation of the laboratories that perform the test and evaluations
can give agencies increased assurance that the products will perform as
vendors claim. Independent testing is a best practice for assuring
conformance to functional, performance, reliability, and interoperability
specifications-especially for systems requiring elevated levels of
security or trust. As discussed previously, NIAP requires vendors to
obtain independent testing and evaluation of specific security features
and functions that are built into their products. Agencies are able to use
the results of validation reports to distinguish between competing
products and thus make better-informed IT procurement decisions. Further,
the Committee on National Security Systems encourages agencies to review
the security target of a product and determine its appropriateness for the
environment in which the product will operate.

In our survey, 15 of 18 federal agencies20 reported that they have derived
benefits from acquiring and using products evaluated by the NIAP process.
Of these 15 agencies,

o 11 reported that the availability of evaluated products helped the
agency make IT procurement decisions;

o 9 reported that the process provided their agency with thorough and
accurate product documentation; and

o 1 reported that evaluated products provided a common method of
performing a particular security service that is implemented in different
types of security or security-enabled devices, potentially resulting in a
greater degree of standardization of elements (such as audit entries).

Moreover, the NIST-administered National Voluntary Laboratory
Accreditation Program (NVLAP) reviews laboratories annually to ensure
competence and compliance with standards. Accreditation is granted to
laboratories following their successful completion of a process that
includes an application submission and fee payment by the laboratory, an
on-site assessment, participation in proficiency testing, resolution of
any deficiencies identified during the process, and a technical
evaluation. The issuance of a certificate formally signifies that a
laboratory has demonstrated that it meets all NVLAP requirements and
operates in accordance with management and the technical requirements of
the relevant standards. However, the accreditation does not imply any
guarantee of laboratory performance or test and calibration data; it is
solely a finding of laboratory competence and compliance with standards.
Figure 3 shows the laboratory accreditation process.

Figure 3: Laboratory Accreditation Process

NIAP Membership in International Recognition Arrangement Gives Agencies
Broader Product Selection and Reduces Vendor Burden

Another benefit of the NIAP evaluation process is NIAP's membership in the
Arrangement on the Recognition of Common Criteria Certificates in the
Field of IT Security. As part of the goals of the arrangement, members can
increase the availability of evaluated IT products and protection profiles
for national use and eliminate duplicate evaluations of IT products and
protection profiles, thus giving agencies a broader selection of evaluated
products from which to choose. Agencies have the ability to acquire
products that have been evaluated at evaluation assurance levels 1 through
4 from any of the countries that have an evaluation scheme. As of February
2006, there were 22 global signatories21 to the recognition arrangement,
and 247 evaluated products available.

The recognition arrangement also reduces the burden on vendors by limiting
the number of criteria to which their products must conform and the number
of evaluations that a vendor needs to complete in order to sell a product
internationally. Because NIAP evaluations (evaluation assurance levels
1-4) are accepted by the arrangement, vendors that go through the NIAP
process can sell their evaluated products in any of the 22 member
countries. Vendors are able to save time and money since they do not need
to complete multiple evaluations to sell their product in different
countries.

Product Evaluations Can Uncover Flaws and Cause Vendors to Fix Them

Another benefit of the NIAP process is that it uncovers flaws during
product evaluations and can cause vendors to fix them. NIAP, vendor, and
laboratory officials stated that the NIAP evaluation process has uncovered
flaws and vulnerabilities in evaluated products. According to NIAP
officials, software flaws are found in nearly all evaluated products, with
an evaluation resulting in an average of two to three fixes. According to
the four vendors included in our review, the NIAP evaluation process
discovered flaws or vulnerabilities in their products or their product
documentation. Also, officials from one of the laboratories included in
our review stated that out of the 90 products they have evaluated, all of
them had documentation flaws. Although vendors have the option of removing
from the evaluation security features or functions in which flaws have
been identified, any flaws in the remaining security features or functions
must be fixed in order to successfully complete the product evaluation.
Nonetheless, agencies procuring NIAP-evaluated products have a higher
level of assurance that the product's security features and functions will
perform as claimed in the validation report.

Product Evaluations Can Result in Improvements to Vendors' Development
Processes

Product evaluations can influence vendors to make improvements to their
development processes that raise the overall quality of their current and
future products. To complete a successful evaluation, vendors submit to
laboratories their development documentation, which describes various
processes related to security, such as software configuration controls.
Officials at six of the seven vendors we visited stated that product
evaluations had a positive influence on their development process.
According to one of the six vendors, completed product evaluations that
result in improvements to their development process would likely transfer
to the development process of other products and help improve the overall
quality of their products. Laboratory officials also stated that NIAP
evaluations often result in vendors improving their software development
process because vendors adopt some of the methodologies used to pass
evaluation, such as test methods and documentation, for their own quality
assurance processes. Additionally, we previously reported that vendors who
are proactive and adopt effective development processes and practices can
drastically reduce the number of flaws in their products.22

NIAP Evaluation Process Faces Challenges

NIAP process participants-NIAP officials and selected vendors,
laboratories, and federal agencies-identified challenges to acquiring and
using NIAP-evaluated products.

o NIAP-evaluated products do not always meet agencies' needs, which limit
agencies' acquisition and use of these products.

o A lack of vendor awareness of the NIAP evaluation process impacts the
timely completion of the evaluation and validation of products.

o A reduction in the number of validators available to certify products
could contribute to delays in validating products for agency use; and

o A lack of performance measures and difficulty in documenting the
effectiveness of the NIAP process makes it difficult to demonstrate the
program's usefulness or improvements made to products' security features
and functions or improvements to vendors' development processes.

Collectively, these challenges hinder the effective use of the NIAP
evaluation process by vendors and agencies.

NIAP-Evaluated Products Do Not Always Meet Agencies' Needs

Meeting agency needs for NIAP-evaluated products for use in national
security systems can be a challenge. According to agency responses to our
survey, 10 of 18 agencies23 that purchased NIAP-evaluated products
reported experiencing challenges in acquiring those products.
Specifically,

o 10 agencies noted that products on the NIAP-evaluated product list were
not the most current versions; and

o 7 agencies noted that products needed by their agency were not included
on the NIAP-evaluated product list.

Agencies also reported additional challenges for acquiring NIAP--
evaluated products. Specifically,

o choices for evaluated products are somewhat limited compared to the
general product marketplace; and

o the length of time required for a product to complete the evaluation
process can delay availability of the most up-to-date technology.

However, opportunities exist to better match agency needs with the
availability of NIAP-evaluated products:

o Agencies can write protection profiles to define the exact security
parameter specifications that they need. For example, two of the vendors
we visited stated that they had their products evaluated against the
Controlled Access Protection Profile, which provides agencies with a set
of security functional and assurance requirements for their IT products
and also provides a level of protection against threats of inadvertent or
casual attempts to breach the system security.

o Vendors can enter the evaluation process before their products are
publicly released, which can allow consumers to acquire the most
up-to-date technology. One vendor we visited had taken such a proactive
approach.

o Agencies can use the NIAP-validated products list to identify products
that meet their needs. Because the number of available NIAP-evaluated
products is increasing, agencies now have a variety of products from which
to choose. In January 2002, there were about 20 evaluated products. As of
February 2006, there were 127 evaluated products and 142 products in
evaluation. These evaluated products span across 26 categories of
information assurance products and information assurance-enabled products
from which to choose, including operating systems and firewalls. As
products continue to enter evaluation, agencies' needs may be better met.

o Vendors can, by participating in the NIAP Assurance Maintenance Program,
maintain the validity of an evaluation when a product upgrades to its next
version by either requesting a re-evaluation of the entire new product
version or validation of only the changes in the product. Vendors'
participation in this program may allow agencies to have the most recent
products available to them.

o Agencies can increase their selection of products through the Common
Criteria Recognition Arrangement-available on the Common Criteria portal
Web site-which currently has 247 evaluated products available. The
products listed on the Web site give agencies more choices of products
evaluated at evaluation assurance levels 4 and below.

Lack of Vendors Awareness of NIAP Evaluation Process Affects Efficiency of
Evaluations

Another challenge faced by the NIAP process is the lack of vendor
awareness regarding the requirements of the evaluation process. For
example, vendors who are new to the evaluation process are not aware of
the extensive documentation requirements. Creating documentation to meet
evaluation requirements can be an expensive and time-consuming process.
According to laboratory officials, about six months is the average time
for vendors to complete the required documentation before test and
evaluation can begin. However, if vendors consistently maintain their
documentation, subsequent evaluations can be faster and less expensive
since the vendor has previously produced the documentation and is already
familiar with the process.

Also, some vendors are not as active as others in the evaluation process,
which can cause varying lengths of time for completing the evaluation.
Vendors who are actively involved in the process are usually able to
complete the process more quickly, including fixing flaws, than those who
are not actively involved. According to one laboratory, the more active a
vendor is in the evaluation process, the faster and less expensive it will
be for the vendor. As such, the amount of involvement by the vendor during
the process and the timeliness with which it fixes discovered flaws
affects the length of time the product is in evaluation.

Furthermore, some vendors and laboratories do not have the same perception
of the length of time required to perform the evaluation. According to
laboratory officials, the length of time needed for conducting product
evaluations varies depending on the type of product being evaluated and
the evaluation assurance level (see fig. 4). Vendors are often not aware
of these requirements and tend to underestimate the length of time
required for evaluations.

Figure 4: Range of Time Required for Completing Product Evaluations at
Various Evaluation Assurance Levels

Vendors and laboratories also perceive the length of evaluations
differently because they punctuate start and end dates differently.
Vendors measure the length of an evaluation from the day they decide to go
into evaluation to the day they receive their product certificate. Their
measurement includes selecting and negotiating with a laboratory,
preparing required documentation, and testing the security features and
functions. Laboratories, on the other hand, consider the length of an
evaluation to be from the day they sign a contract with the vendor to the
day they complete testing.

While Common Criteria user forums for program participants have been held,
which NIAP participated in, NIAP itself has not developed education and
training workshops that focus on educating participants on specific
requirements-such as the documentation requirements. These workshops could
help ensure that vendors and laboratories are aware of the NIAP process
and could contribute to the efficiency of product evaluations. NIAP
officials acknowledge that such educational offerings could be beneficial.

Reduction in the Number of Validators May Affect Timeliness of
Certifications

Over the last year, NIAP has seen a reduction in the number of qualified
validators. NIAP officials stated that one of the most significant
challenges the NIAP process faces is hiring and maintaining qualified
personnel to validate products. In fiscal year 2005, the NIAP program lost
approximately four government validators and six contractor validators.
According to the NIAP Director, maintaining qualified personnel to perform
validation tasks is difficult largely because many validators are nearing
retirement age and the job is not an attractive position for recent
college graduates. Validators have a complex job with tasks that span the
entire evaluation process; they incrementally review the results of the
various tests of functional and assurance requirements as they are
completed by the laboratory. As a result, once validators are hired, it
typically takes 12 to 24 months to train new validators to become
proficient in performing validation tasks.

If the NIAP program continues to see a reduction in validators, there
could be an increased risk that a backlog of products needing to obtain
NIAP certifications will develop, which could also impact the already
lengthy evaluation process. The number of products entering evaluation is
steadily increasing (in fiscal year 2002 there were approximately 20
products in evaluation and as of February 2006, there were 142 products in
evaluation). Additionally, approximately five to seven products enter into
evaluation each month. To address the widening gap between the number of
products entering the process and the number of validators available to
review products, NIAP intends to pursue legislation allowing it to recoup
the costs of validations and hire additional staff.

Lack of Performance Measures and Difficulty in Documenting the
Effectiveness of the NIAP Process

A best practice in public and private organizations is the use of
performance measurements to gain insight into-and make adjustments to-the
effectiveness and efficiency of programs, processes, and people.  24
Performance measurement is a process of assessing progress toward
achieving predetermined goals, and includes gathering information on the
efficiency with which resources are transformed into goods and services,
the quality of those outputs, and the effectiveness of government
operations in terms of their specific contributions to program objectives.
Establishing, updating, and collecting performance metrics to measure and
track progress can assist organizations in determining whether they are
fulfilling their vision and meeting their customer-focused strategic
goals.

The NIAP program lacks performance metrics to measure process
effectiveness and thus faces difficulty in documenting its effectiveness.
The program has not collected and analyzed data on the findings, flaws,
and fixes resulting from product tests and evaluations. NIAP officials
pointed out that nondisclosure agreements between laboratories and vendors
make it difficult to collect and document such data. According to NIAP
officials, there is existing laboratory information on findings, flaws,
and fixes, but it has not been collected because of nondisclosure
agreements. Nondisclosure agreements are important for protecting vendors'
proprietary data from being released to the public and competitors.
However, releasing summary laboratory information on findings, flaws and
fixes, while at the same time considering the requirements of
nondisclosure agreements, could be beneficial to determining the
effectiveness of the NIAP program. Without this type of information, NIAP
will have difficulty demonstrating its effectiveness and will be
challenged to know and to demonstrate whether the process is meeting its
goals.

Expanding NIAP Requirement to Non-national Security Systems May Yield Many
of the Same Benefits and Challenges and Could Exacerbate Resource
Constraints

While the National Security Telecommunications and Information Systems
Security Policy Number 11 already allows agencies with non-national
security systems to acquire NIAP-evaluated products, expanding the policy
to mandate that such systems acquire NIAP-evaluated products may yield
many of the same benefits and challenges experienced by current process
participants, and could further exacerbate resources. For example, one
identified benefit for national security systems-independent testing and
evaluation of IT products-gives agencies confidence that validated
features of a product, whether acquired for national or non-national
security systems, will perform as claimed by the vendor. Similarly, one
challenge-a reduction in the number of validators for certifying
products-could contribute to delays in validating products, whether for
national or non-nation security systems. Further, expanding the
requirement to mandate the policy for non-national security systems may
further exacerbate current resource constraints, related to hiring and
maintaining qualified personnel to validate products.

Nevertheless, agencies with non-national security systems have in fact
acquired NIAP-evaluated products. Specifically, ten of the federal
agencies we surveyed indicated that they have used the NIAP process to
acquire evaluated products for non-national security systems, even though
they are not required to do so. One agency is considering the use of
NIAP-evaluated products during its product reviews, and is also
considering including NIAP-evaluated products as part of its procurement
strategy.

Moreover, agencies seeking information assurance for their non-national
security systems, but who do not acquire NIAP-evaluated products, have
guidance and standards available to them. Specifically, as required by the
Federal Information Security Management Act, NIST has developed and issued
standards and guidelines, including minimum information security
requirements, for the acquisition and use of security-related IT products
for non-national security systems.25 These standards and guidelines are to
be complementary with those established for the protection of national
security systems and information contained in such systems. Further, NIST
issued additional guidance to agencies for incorporating security into all
phases of the system development life cycle process26 as a framework for
selecting and acquiring cost-effective security controls. In August 2000,
NIST also issued guidance on security assurance for non-national security
systems in NIST Special Publication 800-23: Guideline to Federal
Organizations on Security Assurance and Acquisition/Use of
Tested/Evaluated Products.

Conclusions

While a range of controls are needed to protect national security systems
against increasingly sophisticated cyber attacks, establishing effective
policies and processes for acquiring products that have been validated by
an independent party is important to the federal government's ability to
procure and deploy the right technologies. Acquiring NIAP-evaluated
products can increase the federal government's confidence that its IT
products and systems will perform security features and functions as
claimed. Despite the benefits of acquiring and using IT products that have
gone through the rigorous tests and evaluations of NIAP, the program faces
considerable challenges that hinder its effective use by vendors and
agencies. These challenges include the difficulty in matching agencies'
needs with the availability of NIAP-evaluated products, vendors' lack of
awareness regarding the evaluation process, a reduction in the number of
validators to certify products, and difficulty in measuring and
documenting the effectiveness of the NIAP process. Until these challenges
are addressed, they will continue to undermine the efficacy of NIAP.
Regarding expanding the NIAP requirement to non-national security systems,
pursing this approach may further exacerbate current resource constraints.

Recommendations for Executive Action

To assist the NIAP in documenting the effectiveness of the NIAP evaluation
process, we recommend that the Secretary of Defense direct the Director of
the National Security Agency, in coordination with NIST under the
provisions of the NIAP partnership, to take the following two actions:

1.Coordinate with vendors, laboratories, and various industry associations
that have knowledge of the evaluation process to develop awareness
training workshops for program participants.

2.Consider collecting, analyzing, and reporting metrics on the
effectiveness of NIAP tests and evaluations. Such metrics could include
summary information on the number of findings, flaws, and associated
fixes.

Agency Comments and Our Evaluation

In providing written comments on a draft of this report (reprinted in app.
III), the Deputy Assistant Secretary of Defense (Deputy Chief Information
Officer), partially agreed with one of our recommendations, agreed with
the other, and described ongoing and planned efforts to address them.
While the Deputy Assistant Secretary agreed with our recommendation to
develop awareness training workshops for NIAP program participants, she
stated that the NIAP must also live with the realities of the challenges
that we identified in our report. The Deputy Assistant Secretary noted
that, as our report highlights, the NIAP program is facing considerable
challenges with resources and funding to sustain the current day-to-day
running of the program and that it is not feasible for the NIAP office to
increase its current efforts in developing and hosting the recommended
training and education. Nonetheless, she also noted that the Secretary of
Defense should direct the Director of the National Security Agency, in
coordination with the NIST under the provisions of the NIAP, to coordinate
with the vendors, laboratories, and various industry associations that
have knowledge of the evaluation process to develop awareness training
workshops for program participants within the current constraints and to
work with the commercial laboratories, vendors, and others to identify
ways that organizations outside of NIAP can further this initiative. We
agree that NIAP should continue its efforts in awareness and education
training, and endorse increasing such efforts as resources permit.

The Deputy Assistant Secretary agreed with our recommendation to collect,
analyze, and report metrics on the effectiveness of NIAP tests and
evaluations, and stated that the NIAP has already started researching ways
to institute metrics to help determine the effectiveness of the evaluation
program. She noted that the goal of collecting metrics is to demonstrate
to the NIAP constituency that NIAP evaluations do provide value by
improving the security of the evaluated products and by providing the end
customer with assurance that these products perform their security
functions as intended even when faced with adverse conditions.

The Department of Defense and the Department of Homeland Security also
provided technical comments, which we considered and addressed in our
report, as appropriate.

We are sending copies of this report to the Departments of Commerce
(National Institute of Standards and Technology), Defense, and Homeland
Security; the Office of Management and Budget; the General Services
Administration, and to other interested parties. In addition, the 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 about this report, please contact
me at (202) 512-6244 or [email protected] . Contact points for our
Offices of Congressional Relations and Public Affairs may be found on the
last page of this report. GAO staff who made major contributions to this
report are listed in appendix IV.

Sincerely yours,

Gregory C. Wilshusen Director, Information Security Issues

Objectives, Scope, and Methodology Appendix I

Our objectives were to identify (1) the governmentwide benefits and
challenges of the National Information Assurance Partnership (NIAP)
evaluation process; and (2) the potential benefits and challenges of
expanding the requirement of NIAP to non-national security systems,
including sensitive but unclassified systems.

To determine the benefits and challenges for both objectives, we analyzed
and reviewed a number of policy documents and reports from both industry
and government. We also reviewed relevant federal policies relating to
information security issues. To gain insight into the NIAP evaluation
process, we met with software vendors and certification laboratories to
discuss their experiences with NIAP, their applicable processes, and
reviewed their relevant documentation. We selected vendors based on broad
or distinguishing product capabilities demonstrating a range of features,
brand recognition based on high ratings received in reviews conducted by
information security magazines, and vendors mentioned more frequently in
various discussions with industry experts and in information security
literature. Vendors selected represented different information technology
(IT) market sectors, are considered leaders in their field, and varied in
size.

To determine the industrywide perspective on NIAP, we met with two IT
industry groups: The Information Technology Association of America and
Cyber Security Industry Alliance. We selected these industry groups
because they represent a cross-section of the IT industry as a whole. To
gain insight into the program's functions and usefulness to agencies, we
spoke with government officials from the Department of Commerce
(specifically the National Institute of Standards and Technology),
Department of Defense, Department of Homeland Security, General Services
Administration, and the Office of Management and Budget. We also surveyed
officials from the 24 federal agencies designated under the Chief
Financial Officers Act of 1990 to determine their current use of
NIAP-evaluated products, the perceived usefulness of the program, and the
benefits and challenges associated with acquiring and using NIAP-evaluated
products.

For each agency survey, we identified the office of the chief information
officer, notified them of our work, and distributed the survey instrument
to each via an e-mail attachment. In addition, we discussed the purpose
and content of the survey instrument with agency officials when requested.
All 24 agencies responded to our survey. We did not verify the accuracy of
the agencies' responses; however, we reviewed supporting documentation
that agencies provided to validate their responses. We contacted agency
officials when necessary for follow-up information. We then analyzed the
agencies' responses.

Although this was not a sample survey, and, therefore, there were no
sampling errors, conducting any survey may introduce other kinds of
errors. For example, difficulties in how a particular question is
interpreted, in the sources of information that are available to
respondents, or in how the data are entered into a database (or were
analyzed) can introduce unwanted variability into the survey results.

We took steps in the development of the survey instrument, the data
collection, and the data analysis to minimize these survey-related errors.
For example, we developed the questionnaire in two stages. First, we had a
survey specialist design the survey instrument in collaboration with
subject-matter experts. Then, we pretested the instrument at two federal
departments and internally at GAO to ensure that questions were relevant,
clearly stated, and easy to answer.

We conducted our work in Washington, D.C., from May 2005 through February
2006, in accordance with generally accepted government auditing standards.

Common Criteria Evaluation Assurance Levels

Table 1: Summary of the Common Criteria Evaluation Assurance Levels

Evaluation       What is tested      Description                           
assurance level                      
1                Functionality       Evaluation provides independent       
                                        testing against a specification and   
                                        an examination of the guidance        
                                        documentation. Used when confidence   
                                        in correct operation is required but  
                                        the threats to security are not       
                                        viewed as serious.                    
2                Structure           Evaluation provides a low to moderate 
                                        level of independently assured        
                                        security as required by vendors or    
                                        users.                                
3                Methodology         Evaluation provides an analysis       
                                        supported by testing, selective       
                                        independent confirmation of the       
                                        vendor test results, and evidence of  
                                        a vendor search for obvious           
                                        vulnerabilities.                      
4                Methodology and     Evaluation provides a moderate to     
                    Design              high level of independently assured   
                                        security in conventional commodity    
                                        products. Testing is supported by an  
                                        independent search for obvious        
                                        vulnerabilities.                      
5                Semiformal Design   Evaluation provides a high level of   
                                        independently assured security in a   
                                        planned development, with a rigorous  
                                        development approach. The search for  
                                        vulnerabilities must ensure           
                                        resistance to penetration attackers   
                                        with a moderate attack potential.     
6                Semiformal Verified Used for the development of           
                    Design              specialized security products, for    
                                        application in high risk situations.  
                                        The independent search for            
                                        vulnerabilities must ensure           
                                        resistance to penetration attackers   
                                        with a high attack potential.         
7                Formal Design       Used in the development of security   
                                        products for application in extremely 
                                        high risk situations. Evidence of     
                                        vendor testing and complete           
                                        independent confirmation of vendor    
                                        test results are required.            

Source: GAO analysis of Common Criteria data.

Comments from the Department of Defense Appendix III

GAO Contact and Staff Acknowledgments Appendix IV

Gregory C. Wilshusen, Director, Information Security Issues, (202)
512-6244

In addition to the individual named above, Jenniffer Wilson (Assistant
Director), Neil Doherty, Jennifer Franks, Joel Grossman, Matthew Grote,
Min Hyun, Anjalique Lawrence, J. Paul Nicholas, Karen Talley, and Amos
Tevelow were key contributors to this report.

(310551)

www.gao.gov/cgi-bin/getrpt? GAO-06-392 .

To view the full product, including the scope

and methodology, click on the link above.

For more information, contact Gregory C. Wilshusen at (202) 512-6244 or
[email protected].

Highlights of GAO-06-392 , a report to the Honorable William Lacy Clay,
House of Representatives

March 2006

INFORMATION ASSURANCE

National Partnership Offers Benefits, but Faces Considerable Challenges

In 1997, the National Security Agency and the National Institute of
Standards and Technology formed the National Information Assurance
Partnership (NIAP) to boost federal agencies' and consumers' confidence in
information security products manufactured by vendors. To facilitate this
goal, NIAP developed a national program that requires accredited
laboratories to independently evaluate and validate the security of these
products for use in national security systems. These systems are those
under control of the U.S. government that contain classified information
or involve intelligence activities.

GAO was asked to identify (1) the governmentwide benefits and challenges
of the NIAP evaluation process on national security systems, and (2) the
potential benefits and challenges of expanding the requirement of NIAP to
non-national security systems, including sensitive but unclassified
systems.

What GAO Recommends

GAO is making two recommendations to address challenges with the NIAP
evaluation process, including establishing and documenting performance
measures on process effectiveness. The Department of Defense concurred
with one of our recommendations and partially concurred with the other.

While NIAP process participants-vendors, laboratories, and federal
agencies-indicated that the process (see figure below) offers benefits for
use in national security systems, its effectiveness has not been measured
or documented, and considerable challenges to acquiring and using
NIAP-evaluated products exist. Specific benefits included independent
testing and evaluation of products and accreditation of the performing
laboratories, the discovery and correction of product flaws, and
improvements to vendor development processes. However, process
participants also face several challenges, including difficulty in
matching agencies' needs with the availability of NIAP-evaluated products,
vendors' lack of awareness regarding the evaluation process, and a lack of
performance measures and difficulty in documenting the effectiveness of
the NIAP evaluation process. Collectively, these challenges hinder the
effective use of the NIAP evaluation process by vendors and agencies.

Simplified Overview of NIAP Evaluation Process

Expanding the requirement of the NIAP evaluation process to non-national
security systems is likely to yield similar benefits and challenges as
those experienced by current process participants. For example, a current
benefit-independent testing and evaluation of IT products-gives agencies
confidence that validated features of a product will perform as claimed by
the vendor. However, federal policy already allows agencies with
non-national security systems to consider acquiring NIAP-evaluated
products for those systems, and requiring that they do so may further
exacerbate current resource constraints related to the evaluation and
validation of products. In the absence of such a requirement, agencies
seeking information assurance (measures that defend and protect
information and information systems by ensuring their confidentiality,
integrity, authenticity, availability, and utility) for their non-national
security systems have other federal guidance and standards available to
them.
*** End of document. ***