Improvements Are Needed in the Cloud Security Assessment, Approval, and Monitoring Processes

The Chief Information Officer should ensure that separation of duty controls reflect NIST guidance and require that all cloud systems have a unique System Owner and AO or AO Designated Representative.

The Chief Information Officer should ensure that the cloud system immediately completes its pilot program and that an ATO memorandum is approved for the system to remain in production.

The Chief Information Officer should ensure that summary reports are timely created for all cloud systems as required with sufficient oversight by the AOs.

The Chief Information Officer should ensure that the Cloud Continuous Monitoring SOP reflect that all summary reports are required to have a unique POA&M identification number when identifying weaknesses.

The Chief Information Officer should ensure that management approvals are consistent and documented per the requirements for cloud systems.