ATO /Risk Management Framework Lead

The ATO / Risk Management Framework Lead plans and drives the path to anAuthorization to Operate (ATO) and then keeps the system authorized. ACF won'tlet any production system, MIS, dashboard, portal, data repository, or externalfacing platform that processes Federal information operate until ACF confirmsthe authorization path, whether a full ATO, a provisional ATO, or a written ACFOCIO determination that no ATO is required. ACF expects the ATO process to takeabout six months, on a schedule the ACF OCIO approves no later than 30 daysafter award. The lead builds the authorization package, coordinates assessmentand testing, resolves findings, runs continuous monitoring, and owns theprivacy and security activities Task 9 requires, including incident reportingand the flow down of requirements to anyone CDIT brings onto the work. The leadworks most closely with the Cloud / Solution Architect, who designs theenvironment the package describes.

Responsibilities

·       Within30 days after award, lead the draft Privacy Threshold Analysis and PrivacyImpact Assessment support package and the Data Security Plan for the COR andthe ACF OCIO reviewers, describing data flows, system boundaries, user roles,encryption, access controls, audit logging, retention, destruction, incidentresponse, subcontractor access, and privacy protections (RFQ Task 9.4).

·       Workwith the COR and ACF to determine the type and sensitivity of the CUI involvedand whether an ATO is required, and recommend the most efficient authorizationpath among the ACF Tech ATO types, including inheritance from a FedRAMPauthorized environment and the ACF Authority to Use (ACF Tech Appendix D).

·       Proposethe ATO schedule for ACF OCIO approval no later than 30 days after award andmanage the authorization effort to it (RFQ Task 10).

·       Categorizethe system under FIPS 199 and FIPS 200 and select, tailor, and document theNIST SP 800-53 control baseline for a Moderate system, applying NIST SP 800-18,NIST SP 800-171, DISA STIG hardening guidance, OMB Memorandum M-05-22, and HHSand ACF policy.

·       Authorand maintain the authorization package deliverables listed below on theschedule ACF Tech approves, including the annual System Security Plan update,the annual assessment, the quarterly POA&M update, and the annualcontingency plan test.

·       Coordinatethe security assessment with the assessor, support testing, track everyfinding, and drive remediation or risk acceptance to closure.

·       Documentthe Zero Trust implementation approach and expected maturity level and managethe quarterly Zero Trust scorecard submissions for the system (ACF TechAppendix B and Appendix C).

·       Runcontinuous monitoring under FISMA and NIST SP 800-137: monthly vulnerabilityscans with an ACF Tech approved tool, patch management, log review, accountreview, configuration management, and POA&M updates on the schedule ACFOCIO approves. Report critical and high vulnerabilities to the COR andremediate them within ACF approved timeframes (RFQ Task 10).

·       Maintainthe authorization boundary and all security documentation throughout the periodof performance, and submit changes through ACF change control beforeimplementation.

·       Ownincident reporting: any suspected or confirmed breach, cyber incident,unauthorized disclosure, lost device, or exposure of information that isn'tpublic is reported immediately, within one hour at most, through CDIT andGuidehouse to the Contracting Officer, the COR, and the ACF Incident ResponseTeam, with logs and evidence preserved and full cooperation with ACF and HHSresponse (RFQ Task 9.5 and Section 4.0).

·       Assesswhether any data the program collects, stores, transmits, or analyzes isProtected Health Information and whether CDIT or any subcontractor is a HIPAAbusiness associate, and if so support the Business Associate Agreement and therequired safeguards (RFQ Task 9.6).

·       Supportthe Data Inventory and Data Minimization Plan before any data is collected,confirming that no Social Security numbers or other high risk identifiers arecollected without written COR approval (RFQ Task 6.3).

·       Completethe electronic authentication risk assessment with the system owner and ISSO toset the identity, authentication, and federated assurance levels (RFQ Section4.0).

·       Flowthe privacy, security, records, incident reporting, and training requirementsdown to any subcontractor, consultant, or vendor CDIT uses, track the requiredtraining certificates, and keep the records that show compliance (RFQ Tasks 9.2and 9.3).

·       Supportthe Sustainability and Transition strategy with the security documentation,data handling, and media sanitization under NIST SP 800-88 needed for acomplete and secure transfer at the end of the contract (RFQ Task 8).

Required qualifications

·       Bachelor'sdegree.

·       Atleast 7 years in federal information security, with hands on Risk ManagementFramework work under NIST SP 800-37 and NIST SP 800-53.

·       Has ledat least one federal system through assessment to a signed ATO, includingwriting the System Security Plan, supporting the assessment, and managing thePOA&M.

·       FedRAMPknowledge, including control inheritance from an authorized cloud environmentand the customer responsibility matrix.

·       Continuousmonitoring and vulnerability management with enterprise scanning tools,including reading results and driving remediation.

·       Workingknowledge of FISMA, the Privacy Act, HIPAA security requirements, and federalincident reporting obligations.

·       Cleartechnical writing and the ability to coordinate assessors, developers, andGovernment reviewers to a schedule.

·       PublicTrust Tier 2 clearance, held or obtainable.

Desired qualifications (CDITadditions, not conditions of the subcontract)

·       CISSP,CGRC (formerly CAP), CISM, or an equivalent security certification.

·       PriorATO work at HHS or an HHS operating division, and familiarity with the HHS andACF security program and templates.

·       Experiencewith a governance, risk, and compliance tool used for federal authorizationpackages.

·       Experienceproducing Zero Trust scorecards against the CISA Zero Trust Maturity Model.

·       Privacycredential such as CIPP/G, or experience preparing Privacy Threshold Analysesand Privacy Impact Assessments.