This is an updated secition. It includes information from the Cybersecurity Reciprocity Playbook and A DoD Enterprise DevSecOps Reference Design. These documents were generated by Gemini 3 Pro. I am using it to create the materials for this CONOP. The concept was initially my own, but it now includes input from a variety of people who have agreed to lend their assistance to this idea.
Generative AI isn't intended to do the job, it is intended to massively expand a person's capabilities and productivity.
Date: December 02, 2025
Subject: Proposal for an Inter-Agency eMASS Data Clearing House to Accelerate RMF Authorization
To: Defense Counterintelligence and Security Agency (DCSA) / Defense Information Systems Agency (DISA)
From:
The National Industrial Security Program (NISP), established by Executive Order 12829, mandates rigorous security standards for industrial contractors and government agencies. While the Enterprise Mission Assurance Support Service (eMASS) has successfully digitized the Risk Management Framework (RMF), the current operational environment is characterized by significant data silos. Thousands of identical systems are independently assessed and authorized, creating redundant workflows that delay "Speed to Capability."
This Concept of Operations (CONOPS) proposes the development of the Unified RMF Gateway (URG). This clearing house will act as a central API gateway connecting disparate eMASS installations across the Government and Military. URG will aggregate security control values and configuration data while strictly stripping source-attribution data. This ensures Operational Security (OPSEC) by anonymizing agency identities while allowing Authorizing Officials (AOs) to leverage pre-validated data to accelerate Authorization to Operate (ATO) decisions.
Currently, the DCSA and DISA manage the RMF process via eMASS. The workflow is linear and isolated, despite the availability of standardized infrastructure tools.
Standardization without Reciprocity: Recent initiatives, such as the DoD Enterprise DevSecOps Reference Design, have introduced DoD Cloud Infrastructure as Code (IaC). This allows agencies to deploy mathematically identical, pre-configured environments (e.g., IL5 DevSecOps enclaves).
Limited Inheritance: While DoD Cloud IaC allows for approximately 40% control inheritance from the underlying PaaS/IaaS providers, the remaining 60% of controls are often identical across installations but are re-assessed manually for every new package.
Redundancy: An Information System Security Officer (ISSO) deploying a standard "DoD Cloud IaC" web server must manually populate control implementations, even though 5,000 other instances of that exact template are already authorized.
Inefficiency: Evaluation teams re-test validated configurations, and AOs review packages as if they are novel, ignoring the statistical probability of security based on identical, previously authorized baselines.
The lack of horizontal communication between eMASS instances results in:
Wasted Man-Hours: Duplicate data entry and testing for standard DoD Cloud IaC configurations.
Delayed Deployment: Critical capabilities sit in "ATO pending" status for months.
Inconsistent Standards: One AO may accept a configuration that another rejects, despite identical technical baselines derived from the same source code.
The URG is a "Middleware Clearing House"—a secure API Gateway that sits between the user (ISSO/Assessor) and the global ecosystem of eMASS installations. It does not replace local eMASS instances but indexes the values within them to enable "Blind Reciprocity."
The system operates on a Query-Response model with a strict Anonymization Layer.
4.2.1. Standardized Input Ingestion (The "Trusted Baseline")
The URG is optimized to ingest data from known, immutable sources such as DoD Cloud IaC templates.
When an agency deploys a system using a verified DoD Cloud IaC template, the URG recognizes the unique signature (hash) of that deployment.
Because the infrastructure is deployed as code, the Clearing House treats it as a "High Confidence" match, instantly linking the new system to the history of all other systems deployed using that specific version of the code.
4.2.2. The API Gateway
The Gateway ingests connection requests from local eMASS installations. It allows an ISSO to upload a "candidate file" (e.g., a STIG Checklist, ACAS scan result, or IaC Template Hash) and query the Clearing House.
4.2.3. The Anonymization Engine (The "Black Box")
This is the core innovation of the URG.
Input: The engine receives data from all connected eMASS nodes (Agency A, Base B, Contractor C).
Sanitization: It systematically strips all metadata that could identify the source.
Removed: IP Addresses, Unit Names, FQDNs, Location Data, POCs, Agency Headers.
Retained: CCI (Control Correlation Identifier) statuses, Hash values of configuration files, Patch levels, Mitigation narratives (sanitized), and residual risk scores.
Output: The engine presents a "Confidence Score" based on aggregate data.
Scenario: A Receiving Organization (e.g., a defense contractor) needs an ATO for a Red Hat Enterprise Linux 9 web server deployed via a Granting Organization's (e.g., DISA HaCC) DoD Cloud IaC template.
Initiation: The Receiving Organization deploys the server using the approved DoD Cloud IaC template.
Query: In eMASS, the ISSO selects "Search URG" and provides the Template ID/Hash of the deployment.
Matching: The Clearing House recognizes the DoD Cloud IaC signature from the Granting Organization.
The Return: The system returns a comprehensive report:
"Template Match: DoD Cloud IaC - Azure Web App v2.1."
"Identical configuration values found in 4,200 active ATO packages."
"Compliance Rate for this specific template: 99.9%."
"Inheritable Narratives Available: 115 controls (covering the 60% usually left to the user)."
Reciprocity: The Receiving Organization imports the sanitized control values and narratives.
Validation: The AO sees that this configuration is derived from a Standardized Baseline and validated across the enterprise, allowing for an expedited "Fast Track" authorization.
The primary concern for a centralized repository is the potential for an adversary to map the government's entire network topology. URG addresses this via Data Decoupling.
Value-Only Storage: The Clearing House does not store the "who" or "where." It only stores the "what."
Example: The database knows that a system exists with "Setting A=1," but it does not know if that system belongs to the Navy or a NISP Contractor.
One-Way Hashing: Source Agency IDs are hashed upon ingestion. The system can verify a match without revealing the identity of the match.
Need-to-Know: Participating agencies cannot browse the database. They can only query against a specific technical artifact they already possess (i.e., "Do you have a match for this file?").
Benefit Category
Description
Speed
Reduces package creation time from months to days by importing pre-validated narratives and values.
Cost Savings
Massive reduction in labor hours for ISSOs and Security Control Assessors (SCAs).
Standardization
Incentivizes the use of DoD Cloud IaC and other approved baselines to achieve faster authorization times.
Blind Reciprocity
Allows agencies to trust the data without needing to establish formal MOUs with every other agency, as the trust is brokered by the Clearing House logic.
The URG architecture is explicitly designed to operationalize the directives found in the DoD Cybersecurity Reciprocity Playbook (March 2024). It serves as the technical enabler for the following policy mandates:
The Playbook endorses the creation of an "AO Consortium" to handle complex, multi-stakeholder authorizations (e.g., Enterprise Clouds, DevSecOps).
URG Alignment: URG acts as the data-sharing engine that powers this consortium. By providing a transparent, anonymized view of a system’s risk posture across the enterprise, URG allows all stakeholders in the committee to participate in the assessment with high confidence, fulfilling the Playbook’s goal of "increased confidence and trust between Authorization stakeholders."
The Playbook highlights the "Reciprocity Search" function within eMASS and the "Interagency Partner" role.
URG Alignment: URG evolves this capability from a manual, user-dependent search into an automated, API-driven process. Instead of relying on a human to find "similar systems," URG uses cryptographic hashing of IaC templates to instantly identify and retrieve exact matches, ensuring the "re-use of artifacts" mandated by policy.
The Playbook defines the roles of the "Granting Organization" (artifact owner) and the "Receiving Organization" (deployer).
URG Alignment: URG automates the exchange of the Body of Evidence (BoE) between these two parties. It ensures that when a Receiving Organization deploys a standard capability, they instantly inherit the BoE from the Granting Organization without requiring manual file transfers or complex MOAs, streamlining the responsibilities outlined in Section 4.4.1 and 4.4.2.
The Playbook notes that Receiving AOs may refuse reciprocity if there is "insufficient content demonstrating an informed understanding of the security posture."
URG Alignment: URG directly mitigates the risk of refusal. By providing a "High Confidence Match" report that proves the Receiving Organization's configuration is mathematically identical to thousands of previously authorized systems, URG provides the "compelling operational... reasons" required to justify risk acceptance, reducing the likelihood of the 10-day refusal scenario described in Section 9.
Phase 1: Pilot Program (DCSA Only) – Connect NISP eMASS instances to normalize contractor data and integrate DoD Cloud IaC template hashes.
Phase 2: The Gateway Build – Develop the API structure and the Anonymization/Sanitization algorithms.
Phase 3: Joint Integration – Connect DISA and Service-level eMASS instances.
Phase 4: Full Operational Capability (FOC) – Automated recommendations and AI-driven risk scoring based on aggregate data.
The current RMF process is bottlenecked by the inability to leverage the collective work of the DoD and Industrial Base. The URG concept transforms the authorization process from a manual, linear effort into a data-driven, automated ecosystem. By leveraging standardized inputs like DoD Cloud IaC and aligning directly with the DoD Cybersecurity Reciprocity Playbook, DCSA and DISA can achieve the speed of operations required by modern warfare while maintaining the highest levels of information security.
In the DoD Cloud IaC model (referenced in the uploaded PDF), you do not "build" a server by hand. You run a script (the IaC template).
Expectation: If you need a Windows Server 2019 instance to host your software, you use the DoD-Cloud-IaC-Windows2019 template.
URG's Role: The URG sees that you used that specific, pre-authorized template. It knows that the OS hardening, logging connections, and network settings are already 100% compliant because they were born from the trusted code.
Standard software packages (like an SQL Server, an IIS Web Server, or a specific COTS application) are deployed onto that IaC-created server.
Expectation: The software is deployed via a pipeline (CI/CD) using a configuration script (like Ansible, Chef, or a Kubernetes Manifest).
URG's Role: The URG would hash the configuration file used to deploy the software.
Example: If you deploy "Standard SQL Server Config v1.2" onto "Standard Windows Server IaC v2.0", the URG matches both hashes. It sees that this exact combination (Software + OS) has been authorized 500 times before.
Virtual Desktops (VDI): Yes, these would be created via IaC in the cloud (e.g., Azure Virtual Desktop), and URG would apply perfectly here.
Physical Workstations: These are generally outside the scope of "DoD Cloud IaC" (which is for cloud environments). However, if the physical workstations are managed by a configuration tool (like Microsoft Endpoint Configuration Manager) that enforces a "Gold Image," the URG could technically ingest the hash of that Gold Image policy to grant reciprocity, provided the scanning data confirms the match.
In summary: The "IaC" covers the container/server the software lives in. For the software itself, the "IaC" equivalent is the deployment script/configuration file. The URG validates the "stack" of both.