In the world of IT modernization and cybersecurity, the Commercial Solutions for Classified (CSfC) program is a game-changer. It creates a big opportunity for a diverse array of solution providers to better meet the needs of US Government customers who need top-notch technology for their missions. However, to properly support a customer as an NSA Certified Trusted Integrator demands a comprehensive array of skills, from development expertise to meticulous assessments, strategic partnerships, and ongoing guidance. Thus, as the CSfC program continues to shape the National Security Systems (NSS) cybersecurity landscape, it beckons stakeholders to navigate its complexities with precision and foresight.
As I reflect on my experience at the 2024 CSfC conference, I'm struck by the dynamic landscape of cybersecurity and the pivotal role of CSfC in bridging the gap between government requirements and commercial solutions. At the 2023 CSfC conference, I had the pleasure of taking a deep dive into the differences between a trusted integrator vs. a trusted advisor. This year, I returned eager for another enriching panel discussion, this time focusing on practical implementation strategies.
A Brief History of CSfC
Spearheaded by the National Security Agency (NSA), the CSfC Program was conceived to expedite the certification of products for classified use, offering a streamlined pathway for rapid deployment.
CSfC is nothing new and has evolved into a robust program, fostering collaboration through public-private partnerships. These partnerships empower security engineers, developers, vendors, and integrators to confront the ever-evolving threats in our digital landscape while helping government agencies adopt the latest technology solutions.
6 Ways to Put CSfC Into Practice
Implementing CSfC effectively requires more than just a surface-level understanding of its principles. To navigate the complexities of CSfC deployment with finesse, our job as trusted integrators is to serve as trusted advisors and ensure customers employ a strategic approach that encompasses various facets. Here are six key strategies to put CSfC into practice and ensure seamless compliance and success in this dynamic landscape.
1. Communication is Key: Effective communication lies at the heart of successful CSfC implementation. Trusted integrators, often acting as value-added resellers, must maintain clear lines of communication with partners and customers. It's imperative to work closely with the OEMs to keep track of where their products are on the components list and the lifecycles of their products. Equally important is working with the customer to educate them on what CSfC is, how to comply, and their roles and responsibilities in the registration process. The customer providing their artifacts in a timely manner is critical to keeping the registration timeline to a minimum. Things like a certificate policy, certificate practice statements, or acceptable use policies are compliance documents that a Trusted Integrator may be able to help with, but ultimately lies on the customer to provide.
2. Address Complexities Ahead of Time: Take caution if a Trusted Integrator says they can deliver a full CSfC registered capabilities package without a single deviation. Due to the fluidity of the components list alone, there may be several deviations in a successfully registered solution. It's important to understand what risks are being accepted in any deviation, have a plan to mitigate, and review them often to make sure the plan to mitigate is being executed in an acceptable timeline. Deviations from the plan should be accompanied by a well-thought-out mitigation strategy. Timelines must be closely monitored, and any deviations, such as the need to replace laptops to meet WPA2 and WPA3 requirements, should be addressed promptly.
3. Embrace the Objectives: Capability Package requirements are broken into two different categories. First, a Threshold (T) requirement specifies a feature or function that provides the minimally acceptable capability for the security of the solution. An Objective (O) requirement specifies a feature or function that provides the preferred capability for the security of the solution. In general, when separate Threshold and Objective versions of a requirement exist, the Objective requirement provides a higher degree of security for the solution than the corresponding Threshold requirement. Experience has shown us that when new versions of capability packages come out, the most common changes are what was previously an "O" has become a "T" in the update. Due to the requirement needing to become compliant with the new package updates within six months of release, having as many "O's" as possible already checked can future-proof you from scrambling to make updates to your solution(s) when these requirements get released.
4. Customize Deployment Strategies: Trusted integrator services are highly customizable to accommodate diverse mission requirements. The Trusted Integrator should not only know what the customer's requirements are, but what the customer's available skillsets are as well, and how they can fill those gaps. Offering post-deployment options like stay-behind subject matter experts, providing sustainment engineers to fulfill the staff augmentations required by CSfC, or even providing CSfC-as-a-service, are all ways to hand off to the incumbent staff that can provide a smoother transition, which in turn, can boost the speed of customer adoption and customer experience of the new solution.
5. Understand Local Policies: Navigating CSfC deployment entails more than just compliance with NSA’s requirements. Integrators must also consider local policies such as Risk Management Framework (RMF) and Authority to Operate (ATO) processes. Neglecting these additional policies risks overlooking critical aspects of customer needs and security. This is an opportunity for trusted integrators to lean more into the role of trusted advisors.
6. Do the Legwork Upfront to Expedite the Registration Process: Beyond minimizing deviations, several strategies can expedite the registration process. Understanding the customer’s needs, delving into the details of the "5 Ws" (who, what, where, when, why), educating the customer on their roles and responsibilities, and meticulous documentation are essential. Preparing submissions thoroughly and ensuring alignment between documentation and pre-registration requirements can streamline the process significantly.
The Future of CSfC
Looking ahead, the threat of post-quantum poses new challenges and opportunities. As CSfC continues to evolve, it's imperative to remain agile and adaptive in our approaches to become quantum-resistant.
Ultimately, the journey towards CSfC compliance is a collaborative endeavor, marked by communication, customization, and continuous learning. As a trusted advisor, Iron Bow is committed to guiding customers through this transformative process, empowering them to navigate the ever-changing landscape of cybersecurity and IT modernization with confidence.
Need help with implementing CSfC? Learn how Iron Bow can help you as a trusted advisor by reaching out to our team of experts here.
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