A September 22 report from the Government Accountability Office (GAO) says it is unclear who is ultimately responsible for coordinating implementation of the National Cyber Strategy, and holding federal agencies accountable once activities are implemented.
Increasingly sophisticated cyber threats have underscored the need to manage and bolster the cybersecurity of key government systems and the nation’s cybersecurity. The risks to these systems are increasing as security threats evolve and become more sophisticated. GAO first designated information security as a government-wide high-risk area in 1997. This was expanded to include protecting cyber critical infrastructure in 2003 and protecting the privacy of personally identifiable information in 2015. In 2018, GAO noted that the need to establish a national cybersecurity strategy with effective oversight was a major challenge facing the federal government. The White House’s National Cyber Strategy was subsequently created in September 2018.
GAO’s review found that federal entities have a variety of roles and responsibilities for supporting efforts to enhance the cybersecurity of the nation. Among other things, 23 federal entities have roles and responsibilities for developing policies, monitoring critical infrastructure protection efforts, sharing information to enhance cybersecurity across the nation, responding to cyber incidents, investigating cyberattacks, and conducting cybersecurity-related research.
To fulfill their roles and responsibilities, federal entities identified activities undertaken in support of the nation’s cybersecurity. For example, National Security Council (NSC) staff, on behalf of the President, and the National Institute of Standards and Technology, have developed policies, strategies, standards, and plans to guide cybersecurity efforts. The Department of Homeland Security has helped secure the nation’s critical infrastructure through developing security policy and coordinating security initiatives, among other efforts. Other agencies have established initiatives to gather intelligence and share actual or possible cyberattack information. Multiple agencies have mechanisms in place to assist in responding to cyberattacks, and law enforcement components, including the Federal Bureau of Investigation, are responsible for investigating them.
The White House’s September 2018 National Cyber Strategy and the NSC’s accompanying June 2019 Implementation Plan detail the executive branch’s approach to managing the nation’s cybersecurity. GAO says that when evaluated together, these documents address several of the desirable characteristics of national strategies, but lack certain key elements for addressing others. For example, the Implementation Plan details 191 activities that federal entities are to undertake to execute the priority actions outlined in the National Cyber Strategy. These activities are assigned a level, or tier, based on the coordination efforts required to execute the activity and the extent to which NSC staff is expected to be involved. Thirty-five of these activities are designated as the highest level (tier 1), and are coordinated by a functional entity within the NSC. Ten entities are assigned to lead or co-lead these critical activities while also tasked to lead or co-lead lower tier activities.
GAO reports that although the Implementation Plan defined the entities responsible for leading each of the activities; it did not include goals and timelines for 46 of the activities or identify the resources needed to execute 160 activities. Additionally, discussion of risk in the National Cyber Strategy and Implementation Plan was not based on an analysis of threats and vulnerabilities. Further, GAO found the documents did not specify a process for monitoring agency progress in executing Implementation Plan activities. Instead, NSC staff stated that they performed periodic check-ins with responsible entities, but did not provide an explanation or definition of specific level of NSC staff involvement for each of the three tier designations.
GAO and others have reported on the urgency and necessity of clearly defining a central leadership role in order to coordinate the government’s efforts to overcome the nation’s cyber-related threats and challenges. The White House identified the NSC staff as responsible for coordinating the implementation of the National Cyber Strategy. However, in light of the elimination of the White House Cybersecurity Coordinator position in May 2018, it remains unclear which official ultimately maintains responsibility for not only coordinating execution of the Implementation Plan, but also holding federal agencies accountable once activities are implemented. NSC staff told GAO that responsibility for duties previously attributed to the White House Cyber Coordinator were passed to the senior director of NSC’s Cyber directorate; however, the staff did not provide a description of what those responsibilities include. NSC staff also stated that federal entities are ultimately responsible for determining the status of the activities that they lead or support and for communicating implementation status to relevant NSC staff. GAO says that without a clear central leader to coordinate activities, as well as a process for monitoring performance of the Implementation Plan activities, the White House cannot ensure that entities are effectively executing their assigned activities intended to support the nation’s cybersecurity strategy and ultimately overcome this urgent challenge.
GAO is therefore asking Congress to consider legislation to designate a leadership position in the White House with the commensurate authority to implement and encourage action in support of the nation’s cybersecurity.
GAO is also recommending that the National Security Council work with relevant federal entities to update cybersecurity strategy documents to include goals, performance measures, and resource information, among other things.