United States Government Accountability Office Report to Congressional Requesters April 2016 CLOUD COMPUTING Agencies Need to Incorporate Key Practices to Ensure Effective Performance GAO-16-325 April 2016 CLOUD COMPUTING Agencies Need to Incorporate Key Practices to Ensure Effective Performance Highlights of GAO-16-325 a report to congressional requesters Why GAO Did This Study What GAO Found Cloud computing is a means for delivering computing services via IT networks When executed effectively cloud-based services can allow agencies to pay for only the IT services used thus paying less for more services An important element of acquiring cloud services is a service level agreement that specifies among other things what services a cloud provider is to perform and at what level Federal and private sector guidance highlights the importance of federal agencies using a service level agreement SLA in a contract when acquiring information technology IT services through a cloud computing services provider An SLA defines the level of service and performance expected from a provider how that performance will be measured and what enforcement mechanisms will be used to ensure the specified performance levels are achieved GAO identified ten key practices to be included in an SLA such as identifying the roles and responsibilities of major stakeholders defining performance objectives and specifying security metrics The key practices if properly implemented can help agencies ensure services are performed effectively efficiently and securely Under the direction of the Office of Management and Budget OMB guidance issued to agencies in February 2012 included seven of the ten key practices described in this report that could help agencies ensure the effectiveness of their cloud services contracts GAO was asked to examine federal agencies’ use of SLAs GAO’s objectives were to 1 identify key practices in cloud computing SLAs and 2 determine the extent to which federal agencies have incorporated such practices into their SLAs GAO analyzed research studies and guidance developed by federal and private entities to develop a list of key practices to be included in SLAs GAO validated its list with the entities including OMB and analyzed 21 cloud service contracts and related documentation of five agencies with the largest fiscal year 2015 IT budgets against the key practices to identify any variances their causes and impacts GAO determined that the five agencies and the 21 cloud service contracts it reviewed had included a majority of the ten key practices Specifically of the 21 cloud service contracts reviewed from the Departments of Defense Health and Human Services Homeland Security Treasury and Veterans Affairs 7 had fulfilled all 10 of the key practices as illustrated in the figure The remaining 13 contracts had incorporated 5 or more of the 10 key practices and 1 had not included any practices Figure 1 Number of Cloud Service Contracts That Met All 10 Key Practices What GAO Recommends GAO recommends that OMB include all ten key practices in future guidance to agencies and that Defense Health and Human Services Homeland Security Treasury and Veterans Affairs implement SLA guidance and incorporate applicable key practices into their SLAs In commenting on a draft of this report OMB and one agency had no comment the remaining four agencies concurred with GAO’s recommendations View GAO-16-325 For more information contact David A Powner at 202 512-9286 or pownerd@gao gov Agency officials gave several reasons for why they did not include all elements of the key practices into their cloud service contracts including that guidance directing the use of such practices had not been created when the cloud services were acquired Unless agencies fully implement SLA key practices into their SLAs they may not be able to adequately measure the performance of the services and therefore may not be able to effectively hold the contractors accountable when performance falls short United States Government Accountability Office Contents Letter 1 Background Key Practices for Cloud Computing Service Level Agreements Can Help Agencies Manage Services More Effectively Selected Agencies Incorporated Most of the Key Practices but Differed in Addressing Them Conclusions Recommendations for Executive Action Agency Comments and Our Evaluation 3 15 19 20 20 Appendix I Objectives Scope and Methodology 22 Appendix II Analysis of Agencies’ Cloud Service SLAs against Key Practices 25 Appendix III Comments from the Department of Defense 32 Appendix IV Comments from the Department of Homeland Security 34 Appendix V Comments from the Department of Health Human Services 36 Appendix VI Comments from the Department of Veterans Affairs 38 Appendix VII GAO Contact and Staff Acknowledgments 40 12 Tables Table 1 Key Practices for a Cloud Computing Service Level Agreement Table 2 Analysis of DOD’s Cloud Service SLAs against Key Practices Page i 12 25 GAO-16-325 Cloud Computing Table 3 Analysis of DHS’s Cloud Service SLAs against Key Practices Table 4 Analysis of HHS’s Cloud Service SLAs against Key Practices Table 5 Analysis of Treasury’s Cloud Service SLAs against Key Practices Table 6 Analysis of VA’s Cloud Service SLAs against Key Practices 27 28 30 31 Figures Figure 1 Cloud Service Provider and Consumer Responsibilities for the Three Service Models Figure 2 Number of Cloud Service Contracts That Met All 10 Key Practices at Selected Agencies Figure 3 Number of 10 Key Practices Met on 21 Cloud Service Contracts at Selected Agencies Page ii 5 16 17 GAO-16-325 Cloud Computing Abbreviations CIO DOD DHS FAR GSA HHS IT IRS NIST OMB SLA Treasury VA chief information officer Department of Defense Department of Homeland Security Federal Acquisition Regulation General Services Administration Department of Health and Human Services information technology Internal Revenue Service National Institute of Standards and Technology Office of Management and Budget service level agreement Department of the Treasury Department of Veterans Affairs This is a work of the U S government and is not subject to copyright protection in the United States The published product may be reproduced and distributed in its entirety without further permission from GAO However because this work may contain copyrighted images or other material permission from the copyright holder may be necessary if you wish to reproduce this material separately Page iii GAO-16-325 Cloud Computing Letter 441 G St N W Washington DC 20548 April 7 2016 The Honorable Ron Johnson Chairman The Honorable Thomas R Carper Ranking Member Committee on Homeland Security and Governmental Affairs United States Senate The Honorable Jason Chaffetz Chairman Committee on Oversight and Government Reform House of Representatives Cloud computing is a process for acquiring and delivering computing services via internal or external information technology IT networks According to the National Institute of Standards and Technology NIST cloud computing is “a means for enabling on-demand access to shared and scalable pools of computing resources with the goal of minimizing management effort or service provider interaction ” More specifically purchasing IT services through a provider enables agencies to avoid paying for all the assets e g hardware software networks that would typically be needed to provide such services This approach offers federal agencies a means to buy the services faster and possibly cheaper than through the traditional methods they have used such as keeping it all inhouse To take advantage of these potential benefits agencies have reported that they plan to spend more than $2 billion on cloud computing services in fiscal year 2016 1 An important part of acquiring IT cloud computing services is incorporating a service level agreement SLA into the contract An SLA defines levels of service and performance that the agency expects the contractor to meet and the agency uses the information to measure the effectiveness of its cloud services To encourage the use of SLAs the Office of Management and Budget OMB directed subject matter experts to issue guidance that highlighted SLAs as a key factor to be addressed 1 https www itdashboard gov Page 1 GAO-16-325 Cloud Computing in developing cloud computing contracts 2 You asked us to examine federal agencies’ use of SLAs Specifically our objectives were to 1 identify key practices used in cloud computing service level agreements to ensure service is performed at specified levels and 2 determine the extent to which federal agencies have incorporated such practices into their cloud computing service level agreements To identify key practices we analyzed SLA research studies and guidance developed and used by federal agencies and private entities and performed a comparative analysis of the practices to identify the most effective ones Specifically we analyzed information from publications and related documentation issued by the following ten public and private organizations to determine key SLA practices • • • • • • • • • • Federal Chief Information Officers Council Chief Acquisitions Officers Council National Institute of Standards and Technology European Commission Directorate General for Communications Networks Content and Technology OMB Gartner MITRE Corporation Cloud Standards Customer Council International Organization for Standardization International Electrotechnical Commission We then validated our analysis through interviews with experts from these organizations We also had officials from OMB review and validate that the practices we identified are those the office expects federal agencies to follow To determine the extent to which federal agencies have incorporated key practices into their cloud computing contracts we selected five agencies to review based in part on the size of their largest fiscal year 2015 IT budgets and planned spending on cloud computing services The agencies selected were the Departments of 2 Chief Information Officer’s Council and Chief Acquisition Officers Council Creating Effective Cloud Computing Contracts for the Federal Government Best Practices for Acquiring IT as a Service Feb 24 2012 The guidance was written in coordination with the Federal Cloud Compliance Committee Page 2 GAO-16-325 Cloud Computing • • • • • Defense Health and Human Services Homeland Security Treasury and Veterans Affairs To select and review the cloud services used by the agencies we obtained a list of each agency’s cloud services We listed the cloud services for each agency and selected two for each of three major cloud service models infrastructure platform or software 3 In certain cases the agency did not have two cloud services for a service model so the number chosen for that service model was less than two For each of the selected cloud services we compared its contract if one existed any supporting SLA and other documentation to our list of key practices to determine the extent to which the agency had adhered to the key practices or if there were variances 4 We also interviewed agency officials to corroborate our analysis and identify the causes and impacts of any variances from the practices Further details of our scope and methodology are in app I We conducted this performance audit from January 2015 to April 2016 in accordance to generally accepted government auditing standards Those standards require that we plan and perform the audit to obtain sufficient appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives Background The federal government spends more than $80 billion dollars on IT annually with more than $2 billion of that amount spent on acquiring cloud-based services This amount is expected to rise in coming fiscal years according to OMB A goal of these investments is to improve 3 An expanded description of each of these types of service is included in the following section 4 Types of documentation included contract modifications subscription agreement terms of use terms of condition performance work statement support agreement service level compliance report application management services technical proposal and customer agreements Page 3 GAO-16-325 Cloud Computing federal IT systems by replacing aging and duplicative infrastructure and systems that are costly and difficult to maintain Cloud computing helps do this by giving agencies the ability to purchase a broad range of IT services in a utility-based model that allows an agency to pay for only the IT services it uses 5 According to NIST an application should possess five essential characteristics to be considered cloud computing on-demand selfservice broad network access resource pooling rapid elasticity and measured service 6 Essentially cloud computing applications are network-based and scalable on demand According to OMB cloud computing is economical flexible and fast • Economical cloud computing can be a pay-as-you-go approach in which a low initial investment is required to begin and additional investment is needed only as system use increases • Flexible IT departments that anticipate fluctuations in user demand no longer need to scramble for hardware and software to meet increasing need With cloud computing capacity can be added or subtracted quickly • Fast cloud computing eliminates long procurement and certification processes while providing a wide selection of services In addition according to NIST cloud computing offers three service models • Infrastructure as a service—the agency has the capability to provision processing storage networks and other fundamental computing 5 Chief Information Officer’s Council and the Chief Acquisition Officers Council Creating Effective Cloud Computing Contracts for the Federal Government Feb 24 2012 6 NIST defines these characteristics further On-demand self-service allows consumers to acquire computing capabilities automatically and as needed Broad network access provides capabilities over a network which is accessed through standard mechanisms e g a mobile phone tablet laptop and workstation Resource pooling means the vendor’s combined computing resources serve multiple consumers Rapid elasticity refers to the ability to vary resources commensurate with demand Measured services are incrementally valued typically on a pay-per-use or charge-per-use basis Page 4 GAO-16-325 Cloud Computing resources and run its own software including operating systems and applications The agency does not manage or control the underlying infrastructure but controls and configures operating systems storage deployed applications and possibly selected networking components e g host firewalls • Platform as a service—the agency deploys its own or acquired applications created using programming languages and tools supported by the provider The agency does not manage or control the underlying infrastructure but controls and configures the deployed applications • Software as a service—the agency uses the service provider’s applications which are accessible from various client devices through an interface such as a Web browser e g Web-based e-mail system The agency does not manage or control the underlying infrastructure or the individual application capabilities As can be seen in figure 1 each service model offers unique functionality with consumer control of the environment decreasing from infrastructure to platform to software Figure 1 Cloud Service Provider and Consumer Responsibilities for the Three Service Models Page 5 GAO-16-325 Cloud Computing NIST has also defined four deployment models for providing cloud services private community public and hybrid • In a private cloud the service is set up specifically for one organization although there may be multiple customers within that organization and the cloud may exist on or off the customer’s premises • In a community cloud the service is shared by organizations with similar requirements The cloud may be managed by the organizations or a third party and may exist on or off an organization’s premises • A public cloud is available to the general public and is owned and operated by the service provider • A hybrid cloud is a composite of two or more other deployment models private community or public that are bound together by standardized or proprietary technology According to federal guidance these deployment models determine the number of consumers and the nature of other consumers’ data that may be present in a cloud environment A public cloud should not allow a consumer to know or control other consumers of a cloud service provider’s environment However a private cloud can allow for ultimate control in selecting who has access to a cloud environment Community clouds and hybrid clouds allow for a mixed degree of control and knowledge of other consumers OMB Has Undertaken Initiatives and Issued Guidance to Increase Agency Adoption of Cloud Computing Services According to OMB the federal government needs to shift from building custom computer systems to adopting cloud technologies and shared services which will improve the government’s operational efficiencies and result in substantial cost savings To help agencies achieve these benefits OMB required agencies in 2010 to immediately shift to a “Cloud First” policy and increase their use of available cloud and shared services whenever a secure reliable and cost-effective cloud service exists 7 7 OMB 25 Point Implementation Plan to Reform Federal Information Technology Management Washington D C Dec 9 2010 Page 6 GAO-16-325 Cloud Computing In February 2011 OMB issued the Federal Cloud Computing Strategy 8 as called for in its 25-Point Plan The strategy provided definitions of cloud computing services benefits of cloud services such as accelerating data center consolidations a decision framework for migrating services to a cloud environment 9 case studies to support agencies’ migration to cloud computing services and roles and responsibilities for federal agencies For example the strategy stated that NIST’s role is to lead and collaborate with federal state and local government agency chief information officers private sector experts and international bodies to identify standards and guidance and prioritize the adoption of cloud computing services In addition the strategy stated that agency cloud service contracts should include SLAs designed to meet agency requirements In a December 2011 memo OMB established the Federal Risk and Authorization Management Program FedRAMP 10 a government-wide program intended to provide a standardized approach to security assessment authorization 11 and continuous monitoring for cloud computing products and services 12 All federal agencies must meet FedRAMP requirements when using cloud services and the cloud service providers must implement the FedRAMP security requirements in their cloud environment To become authorized cloud service providers provide a security assessment package to be reviewed by the FedRAMP 8 OMB Federal Cloud Computing Strategy Washington D C Feb 8 2011 9 The decision framework among other things identifies several key areas for determining the readiness for moving to a cloud environment including the ability of the cloud service provider to address government security requirements 10 OMB Security Authorization of Information Systems in Cloud Computing Environments Washington D C Dec 8 2011 11 Security authorization is the official management decision given by a senior official of an organization to authorize operation of an information system and to explicitly accept the risk to organizational operations and assets individuals other organizations and the nation based on the implementation of an agreed-on set of security controls 12 FedRAMP’s security assessment framework encompasses four process areas document assess authorize and monitor that are based on the six steps within the framework described in NIST’s Guide for Applying the Risk Management Framework to Federal Information Systems A Security Life Cycle Approach SP 800-37 Revision 1 Gaithersburg MD February 2010 Page 7 GAO-16-325 Cloud Computing Joint Authorization Board 13 which may grant a provisional authorization Federal agencies can leverage cloud service provider authorization packages for review when granting an agency authority to operate where this reuse is intended to save time and money Further at the direction of OMB the Chief Information Officers Council and the Chief Acquisition Officers Council issued in February 2012 guidance to help agencies acquire cloud services 14 In particular the guidance highlights that SLAs are a key factor for ensuring the success of cloud based services and that federal agencies should include an SLA when creating a cloud computing contract or as a reference The guidance provides important areas of an SLA to be addressed for example it states that an SLA should define performance with clear terms and definitions demonstrate how performance is being measured and identify what enforcement mechanisms are in place to ensure the conditions are being met In addition NIST in its role designated by OMB in the Federal Cloud Computing Strategy collaborated with private sector organizations to release cloud computing guidance 15 which affirms the importance of using an SLA when acquiring cloud computing services Moreover a number of other public and private sector organizations have issued research on the incorporation of an SLA in a cloud computing 13 The Joint Authorization Board is composed of the chief information officers from DOD DHS and the General Services Administration and establishes the baseline controls for FedRAMP and criteria for accrediting third-party independent assessment organizations 14 Chief Information Officer’s Council and Chief Acquisition Officers Council Creating Effective Cloud Computing Contracts for the Federal Government Best Practices for Acquiring IT as a Service 15 See for example NIST US Government Cloud Computing Technology Roadmap Volume 1 High-Priority Requirements to Further USG Agency Cloud Computing Adoption NIST SP 500-293 Gaithersburg MD October 2014 and NIST Cloud Computing Synopsis and Recommendations NIST SP 800-146 Gaithersburg MD May 2012 Page 8 GAO-16-325 Cloud Computing contract 16 According to these studies an SLA is important because it ensures that services are being performed at the levels specified in the cloud computing contract can significantly contribute to avoiding conflict and can facilitate the resolution of an issue before it escalates into a dispute The studies also highlight that a typical SLA describes levels of service using various attributes such as availability serviceability or performance and specifies thresholds and financial penalties associated with a failure to comply with these thresholds Agencies Are Taking Steps to Implement Prior GAOIdentified Improvements for Cloud-based Computing Services We have previously reported on federal agencies’ efforts to implement cloud computing services and on progress oversight that agencies have made to help federal agencies in those efforts These include • In May 2010 we reported on the efforts of multiple agencies to ensure the security of government-wide cloud computing services 17 We noted that while OMB the General Services Administration GSA and NIST had initiated efforts to ensure secure cloud computing services OMB had not yet finished a cloud computing strategy GSA had begun a procurement for expanding cloud computing services for its website that served as a central location for federal agencies to purchase cloud services but had not yet developed specific plans for establishing a shared information security assessment and authorization process and NIST had not yet issued cloud-specific security guidance We recommended that OMB establish milestones to complete a strategy for federal cloud computing and ensure it addressed information security challenges These include having a process to assess vendor compliance with government information security requirements and division of information security responsibilities between the customer and vendor 16 See for example European Commission Directorate General for Communications Networks Content and Technology Cloud Service Level Agreement Standardization Guidelines Brussels Belgium June 2014 MITRE Cloud SLA Considerations for the Government Consumer September 2012 Cloud Standards Customer Council Practical Guide to Cloud Service Agreements Version 2 0 April 2015 and Gartner Best Practices for Service Level Agreements for Software as a Service Stamford CT November 2010 17 GAO Information Security Federal Guidance Needed to Address Control Issues with Implementing Cloud Computing GAO-10-513 Washington D C May 27 2010 Page 9 GAO-16-325 Cloud Computing OMB agreed with our recommendations and subsequently published a strategy in February 2011 that addressed the importance of information security when using cloud computing but it did not fully address several key challenges confronting agencies such as the appropriate use of attestation standards for control assessments of cloud computing service providers and division of information security-related responsibilities between customer and provider We also recommended that GSA consider security in its procurement for cloud services including consideration of a shared assessment and authorization process GSA generally agreed with our recommendations and has since developed the FedRAMP program Finally we recommended that NIST issue guidance specific to cloud computing security NIST agreed with our recommendations and has since issued multiple publications that address such guidance • In April 2012 we reported that more needed to be done to implement OMB’s 25-Point Plan and measure its results 18 Among other things we reported that of the 10 key action items that we reviewed 3 had been completed and 7 had been partially completed by December 2011 In particular OMB and agencies’ cloud-related efforts only partially addressed requirements Specifically agencies’ plans were missing key practices such as a discussion of needed resources a migration schedule and plans for retiring legacy systems As a result we recommended among other things that the Secretaries of Homeland Security and Veterans Affairs and the Attorney General direct their respective CIOs to complete practices missing from the agencies’ plans for migrating services to a cloud computing environment Officials from each of the agencies generally agreed with our recommendations and have taken steps to implement them • In July 2012 we reported on the efforts of seven agencies to implement three services by June 2012 including the challenges associated with doing so 19 Specifically we reported that selected federal agencies had made progress in implementing OMB’s “Cloud First” policy Seven agencies had implemented 21 cloud computing solutions and had spent a total of $307 million for cloud computing in 18 GAO Information Technology Reform Progress Made More Needs to Be Done to Complete Actions and Measure Results GAO-12-461 Washington D C Apr 26 2012 19 GAO Information Technology Reform Progress Made but Future Cloud Computing Efforts Should Be Better Planned GAO-12-756 Washington D C July 11 2012 Page 10 GAO-16-325 Cloud Computing fiscal year 2012 about 1 percent of their total IT budgets While each of the seven agencies had submitted plans to OMB for implementing their cloud services a majority of the plans were missing required elements Agencies also identified opportunities for future cloud service implementations such as moving storage and help desk services to a cloud environment Agencies also shared seven common challenges that they experienced in moving services to cloud computing We made recommendations to the agencies to develop planning information such as estimated costs and legacy IT systems’ retirement plans for existing and planned services The agencies generally agreed with our recommendations and have taken actions to implement them • In September 2014 we reported on the aforementioned seven agencies’ efforts to implement additional cloud computing services any reported cost savings as a result of implementing those cloud services and challenges associated with the implementation 20 All of the seven federal agencies we reviewed had added more cloud computing services the number of cloud services implemented by them had increased from 21 to 101 between fiscal years 2012 and 2014 In addition agencies had collectively doubled the percentage of their IT budgets from 1 to 2 percent during the fiscal year 2012–14 period Further the agencies reported a collective cost savings of about $96 million through fiscal year 2013 We made recommendations to the agencies to assess their IT investments that had yet to be evaluated for suitability for cloud computing services For the most part the agencies generally agreed with our recommendations and have taken actions to implement them 20 GAO Cloud Computing Additional Opportunities and Savings Need to Be Pursued GAO-14-753 Washington D C Sept 25 2014 Page 11 GAO-16-325 Cloud Computing Key Practices for Cloud Computing Service Level Agreements Can Help Agencies Manage Services More Effectively Based on our analysis of practices recommended by the ten organizations with expertise in the area of SLAs and OMB we compiled the following list of ten practices that are key for federal agencies to incorporate into a contract to help ensure services are performed effectively efficiently and securely for cloud computing services The key practices are organized by the following management areas—roles and responsibilities performance measures security and consequences 21 Table 1 Key Practices for a Cloud Computing Service Level Agreement Roles and responsibilities 1 Specify roles and responsibilities of all parties with respect to the SLA and at a minimum include agency and cloud providers 2 Define key terms such as dates and performance Performance measures 3 • • • Define clear measures for performance by the contractor Include which party is responsible for measuring performance Examples of such measures would include Level of service e g service availability—duration the service is to be available to the agency Capacity and capability of cloud service e g maximum number of users that can access the cloud at one time and ability of provider to expand services to more users Response time e g how quickly cloud service provider systems process a transaction entered by the customer response time for responding to service outages 4 Specify how and when the agency has access to its own data and networks This includes how data and networks are to be managed and maintained throughout the duration of the SLA and transitioned back to the agency in case of exit termination of service 5 Specify the following service management requirements How the cloud service provider will monitor performance and report results to the agency When and how the agency via an audit is to confirm performance of the cloud service provider • • 6 Provide for disaster recovery and continuity of operations planning and testing including how and when the cloud service provider is to report such failures and outages to the agency In addition how the provider will remediate such situations and mitigate the risks of such problems from recurring 21 This report identifies key practices for cloud computing SLAs including a key practice that specifies consequences for missing SLA performance measures This key practice is defined only in terms of consequences and available remedies that are specifically linked to the SLA performance measures and does not refer to enforcement mechanisms such as termination for default that are made available in the standard terms of federal government contracts generally Page 12 GAO-16-325 Cloud Computing 7 Describe any applicable exception criteria when the cloud provider’s performance measures do not apply e g during scheduled maintenance or updates Security 8 Specify metrics the cloud provider must meet in order to show it is meeting the agency’s security performance requirements for protecting data e g clearly define who has access to the data and the protections in place to protect the agency’s data 9 Specifies performance requirements and attributes defining how and when the cloud service provider is to notify the agency when security requirements are not being met e g when there is a data breach Consequences 10 Specify a range of enforceable consequences such as penalties for non-compliance with SLA performance measures Source GAO analysis of data from public and private organizations I GAO-16-325 Roles and responsibilities 1 Define the roles and responsibilities of the major stakeholders involved in the performance of the SLA and cloud contract These definitions would include for example the persons responsible for oversight of the contract audit performance management maintenance and security 2 Define key terms including activation date performance and identify any ambiguities in the definitions of cloud computing terms in order to provide the agency with the level of service they can expect from their cloud provider Without clearly defined roles responsibilities and terms the agency may not be able to appropriately measure the cloud provider’s performance Performance measures 1 Define the performance measures of the cloud service including who is responsible for measuring performance These measures would include among other things the availability of the cloud service the number of users that can access the cloud at any given time and the response time for processing a customer transaction Providing performance parameters provides both the agency and service provider with a well-defined set of instructions to be followed 2 Specify how and when the agency would have access to its data including how data and networks will be managed and maintained throughout the life cycle of the service Provide any data limitations such as who may or may not have access to the data and if there are any geographic limitations 3 Specify management requirements for example how the cloud service provider would monitor the performance of the cloud report incidents and how and when they would plan to resolve them In addition identify how and when the agency would conduct an audit to monitor the performance of the service provider including access to the provider’s performance logs and reports 4 Provide for disaster recovery and continuity of operations planning and testing This includes among other things performing a risk management assessment how the cloud service would be managed by the provider in the case of a disaster how data would be recovered and what remedies would apply during a service Page 13 GAO-16-325 Cloud Computing failure 5 Describe applicable exception criteria for when the cloud provider’s service performance measures do not apply such as during scheduled cloud maintenance or when updates occur Without any type of performance measures in place agencies would not be able to determine whether the cloud services under contract are meeting expectations Security 1 Specify the security performance requirements that the service provider is to meet This would include describing security performance metrics for protecting data such as data reliability data preservation and data privacy Cleary define the access rights of the cloud service provider and the agency as well as their respective responsibilities for securing the data applications and processes to meet all federal requirements 2 Describe what would constitute a breach of security and how and when the service provider is to notify the agency when the requirements are not being met Without these safeguards computer systems and networks as well as the critical operations and key infrastructures they support may be lost and information—including sensitive personal information—may be compromised and the agency’s operations could be disrupted Consequences Specify a range of enforceable consequences including the terms under which a range of penalties and remedies would apply for non-compliance with the SLA performance measures Identify how such enforcement mechanisms would be imposed or exercised by the agency Without penalties and remedies the agency may lack leverage to enforce compliance with contract terms when situations arise OMB Guidance Addresses Seven of the Ten Key Practices Guidance issued in February 2012 at the direction of OMB highlighted SLAs as being a key factor for ensuring the success of cloud-based services and advised that federal agencies should include an SLA or a reference within the contract when creating a cloud computing contract The guidance provides areas of an SLA to be addressed for example it states that an SLA should define performance with clear terms and definitions demonstrate how performance is being measured and identify what enforcement mechanisms are in place to ensure the conditions are being met However the guidance addressed only seven of the ten key practices listed in table 1 that could help agencies better track performance and thus ensure the effectiveness of their cloud services Specifically the guidance did not specify how and when the agency would have access to Page 14 GAO-16-325 Cloud Computing its data provide for disaster recovery and continuity of operations planning and describe any exception criteria OMB staff members said that although the guidance drafted by the Chief Information Officers Council and the Chief Acquisition Officers Council was a good start including all ten key practices should be considered Without complete guidance from OMB there is limited assurance that agencies will apply all the key SLA practices into their cloud computing contracts and therefore may be unable to hold contractors accountable when performance falls short of their goals Selected Agencies Incorporated Most of the Key Practices but Differed in Addressing Them Many of the 21 cloud service contracts we reviewed at the five selected agencies incorporated a majority of the key practices but the number of practices differed among contracts Specifically seven of the cloud service contracts reviewed met all 10 of the key practices This included three from DHS three from Treasury and one from VA The following figure shows the total cloud service contracts reviewed and the number that met the 10 key practices at the five selected agencies Page 15 GAO-16-325 Cloud Computing Figure 2 Number of Cloud Service Contracts That Met All 10 Key Practices at Selected Agencies Of the remaining 14 cloud service contracts 13 incorporated five or more of the key practices and 1 did not meet any of the key practices Figure 3 shows each of the cloud service contracts we reviewed and the extent to which the agency had included key practices in its SLA contracts Appendix II includes our analysis of all the cloud services we reviewed by agency Page 16 GAO-16-325 Cloud Computing Figure 3 Number of 10 Key Practices Met on 21 Cloud Service Contracts at Selected Agencies A primary reason that the agencies did not include all of the practices was that they lacked guidance that addresses these SLA practices Of the five agencies only DOD had developed cloud service contracting guidance that addressed some of the practices More specifically DOD’s guidance only addressed three of the key practices disaster recovery and continuity of operations planning metrics on security performance requirements and notifying the agency when there is a security breach In addition the guidance partially addressed the practice on access to agency data specifically with regard to transitioning data back to the agency in case of exit termination of service Agency officials responsible for the cloud services that did not meet or only partially met key practices provided the following additional reasons for not including all ten practices • Officials from DOD’s Office of the Chief Information Officer told us that the reason key practices were not always fully addressed is that when the contracts and associated SLAs were developed they did not have the aforementioned DOD guidance on cloud service acquisition and use—namely the agency’s memorandum on Page 17 GAO-16-325 Cloud Computing acquiring cloud services that was released in December 2014 22 and the current Defense Federal Acquisition Regulation Supplement which was finalized in August 2015 23 However as previously stated this updated guidance addressed three of the ten key practices and part of one other • Officials from DHS’s Office of the Chief Information Officer stated that the Infrastructure as a Service cloud service addressed the partially met and not met key practices but did not provide supporting documentation to show that the practices were in place If key practices have not been incorporated the system may have decreased performance and the cloud service may not meet its intended goals • HHS officials from the National Institutes of Health attributed unmet or partially met practices for four cloud services—Remedy Force Medidata the BioMedical Imaging and BioEngineering website and the Drug Abuse public website—to the fact that they evaluate the cloud vendor’s ability to meet defined agency needs rather than negotiate with vendors on SLA requirements While this may explain their shortfalls in not addressing all SLA key practices the agency may be placing their systems at risk of not conducting adequate service level measurements which may result in decreased service levels HHS officials from the Administration of Children and Families stated that the reason key practices were partially addressed or not addressed for the Grant Solutions cloud service was that these practices were being managed by HHS personnel using other tools and plans rather than via the SLA established for this service For example according to the officials they are using a management information system to monitor performance of the cloud provider In addition with respect to disaster management the officials said that they have their own disaster recovery plan Nonetheless leading studies show that these practices should still be incorporated as part of the cloud service contract to ensure agencies have the proper control over their cloud services 22 DOD Memorandum Updated Guidance on the Acquisition and Use of Commercial Cloud Computing Services December 15 2014 23 80 Fed Reg 51739 August 26 2015 adding 48 C F R Subpart 239 76 Page 18 GAO-16-325 Cloud Computing • Treasury officials said the reason among other things the SLAs for Treasury Web Services and IRS Portal Environment only partially met certain key practices was because the practices were being provided by support contractors hired by the cloud service provider and were not directly subject to the SLAs established between Treasury and the cloud service provider Nonetheless while having contractors perform practices is an acceptable approach Treasury officials were unable to provide supporting documentation to show that support contractors were assisting with the practices in question • Officials from VA’s Office of Information and Technology said the reason the key practice associated with penalties and remedies was not included in the Terremark SLA was because penalties were addressed within other parts of the contract however officials were not able to provide documentation identifying such penalties With regard to an SLA for eKidney officials told us they had not addressed any of the key practices due to the fact that an SLA was not developed between the agency and cloud service provider Without including an SLA in cloud service contracts the agency runs the risk of not having the mechanisms in place to effectively evaluate or control contractor performance Until these agencies develop SLA guidance and incorporate all key practices into their cloud computing contracts they may be limited in their ability to measure the performance of the services and therefore may not receive the services they require Conclusions Although OMB has provided agencies guidance to better manage contracts for cloud computing services this guidance does not include all the key practices that we identified as necessary for effective SLAs Similarly Defense Homeland Security Health and Human Services Treasury and Veterans Affairs have incorporated many of the key practices in the cloud service contracts they have entered into Overall this is a good start towards ensuring that agencies have mechanisms in place to manage the contracts governing their cloud services However given the importance of SLAs to the management of these million-dollar service contracts agencies can better protect their interests by incorporating the pertinent key practices into their contracts in order to ensure the delivery and effective implementation of services they contract for In addition agencies can improve management and control over their cloud service providers by implementing all recommended and applicable SLA key practices Page 19 GAO-16-325 Cloud Computing Recommendations for Executive Action Agency Comments and Our Evaluation • To ensure that agencies are provided with more complete guidance for contracts for cloud computing services we recommend that the Director of OMB include all ten key practices in future guidance to agencies • To help ensure continued progress in the implementation of effective cloud computing SLAs we recommend that the Secretary of Defense direct the appropriate officials to ensure key practices are fully incorporated for cloud services as the contracts and associated SLAs expire These efforts should include updating the DOD memorandum on acquiring cloud services and current Defense Acquisition Regulations System to more completely include the key practices • To help ensure continued progress in the implementation of effective cloud computing SLAs we recommend that the Secretaries of Health and Human Services Homeland Security Treasury and Veterans Affairs direct appropriate officials to develop SLA guidance and ensure key practices are fully incorporated as the contract and associated SLAs expire In commenting on a draft of this report four of the agencies—DOD DHS HHS and VA—agreed with our recommendations and OMB and one agency Treasury had no comments The specific comments from each agency are as follows • In an e-mail received on March 25 2016 OMB staff from the Office of E-Government and Information Technology stated that the agency had no comments at this time • In written comments the Department of Defense concurred with our recommendation and described actions it plans to take to address the recommendation Specifically DOD stated that it will update its cloud computing guidance and contracting guidance as appropriate The Department of Defense’s comments are reprinted in appendix III • In written comments the Department of Homeland Security concurred with our recommendation and described actions it plans to take to address the recommendation Specifically the department will establish common cloud computing service level agreement guidance DHS also provided technical comments which we have incorporated in the report as appropriate The Department of Homeland Security’s comments are provided in appendix IV Page 20 GAO-16-325 Cloud Computing • In written comments the Department of Health and Human Services concurred with our recommendation but noted that it was not directed by a federal mandate We acknowledge that our recommendation is not directed by a mandate however implementing leading practices for cloud computing can result in significant benefits The department also provided technical comments which we have incorporated in the report as appropriate The Department of Health and Human Service’s comments are provided in appendix V • In an e-mail received on March 18 2016 an audit liaison from the Department of the Treasury’s Office of the CIO stated that the department had no comment • In written comments the Department of Veterans Affairs concurred with our recommendation and described planned actions to address it For example the department will develop service level agreement guidance to include the 10 key practices The Department of Veterans Affairs comments are provided in appendix VI We are sending copies of this report to interested congressional committees the Secretaries of Defense Health and Human Services Homeland Security the Treasury and Veterans Affairs and the Director of the Office of Management and Budget and other interested parties This report will also be available at no charge on our website at http www gao gov If you or your staffs have any questions on matters discussed in this report please contact me at 202 512-9286 or pownerd@gao gov Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report GAO staff who made major contributions to this report are listed in appendix VII David A Powner Director Information Technology Management Issues Page 21 GAO-16-325 Cloud Computing Appendix I Objectives Scope and Methodology Appendix I Objectives Scope and Methodology Our objectives were to 1 identify key practices used in cloud computing service level agreements SLA to ensure service is performed at specified levels and 2 determine the extent to which federal agencies have incorporated such practices into their cloud computing service level agreements To identify key practices used in cloud computing service level agreements we analyzed SLA research studies and guidance developed and used by federal agencies and private entities We then performed a comparative analysis of the practices to identify the practices that were recommended by at least two sources Specifically we analyzed information from publications and related documentation issued by the following ten public and private organizations to determine key SLA practices • • • • • • • • • • Federal Chief Information Officer Council Chief Acquisitions Officers Council National Institute of Standards and Technology European Commission Directorate General for Communications Networks Content and Technology Office of Management and Budget Gartner MITRE Corporation Cloud Standards Customer Council International Organization for Standardization International Electrotechnical Commission Next we organized these practices into management areas and validated our analysis through interviews with experts from these organizations We also had officials from the Office of Management and Budget OMB review and validate that these practices are the ones the office expects federal agencies to follow In cases where experts disagreed we analyzed their responses including the reasons they disagreed and made changes as appropriate These actions resulted in our list of key practices for cloud service SLAs To determine the extent to which federal agencies have incorporated key practices into their cloud computing contracts we selected five agencies to review based in part on those with the largest fiscal year 2015 IT budgets and planned spending on cloud computing services The agencies selected were the Departments of Defense DOD Homeland Security DHS Health and Human Services HHS Treasury and Veterans Affairs VA Page 22 GAO-16-325 Cloud Computing Appendix I Objectives Scope and Methodology We selected these agencies based on the following two factors First they have the largest planned IT budgets for fiscal year 2015 Their budgets which collectively totaled $57 billion represent about 72 percent of the total federal IT budget $78 billion Second these agencies plan to spend relatively large amounts on cloud computing Specifically based on our analysis of OMB’s fiscal year 2015 budget data each of the five departments were in the top 10 for the largest amount budgeted for cloud computing and collectively planned to spend $1 2 billion on cloud computing which represents about 57 percent of the total amount that federal agencies plan to invest in cloud computing $2 1 billion To select and review the cloud services used by the agencies we obtained an inventory of cloud services for each of the five agencies and then for each agency we listed their cloud services in a random fashion and selected the first two cloud services in the list for each of the three major cloud service models infrastructure platform and software In certain cases the agency did not have two cloud services for a service model so the number chosen for that service model was less than two This resulted in a non-generalizable sample of 23 cloud services However near the end of our engagement agencies identified 2 of the services as being in a pilot stage one from DHS and one from HHS and thus not operational We excluded these services from our analysis as our methodology to only assess operational cloud services Due to the stage of the engagement we were unable to select additional services for review Further because no computer-generated data was used we determined that there were no data reliability issues For each of the selected services we compared its cloud service contract if one existed and any associated SLA documentation to our list of key practices to determine if there were variances and if so their cause and impact To do so two team analysts independently reviewed the cloud service contracts against the key practices using the following criteria • • • Met all aspects of the key practices were fully addressed Partially met some key practices were addressed Did not meet no key practices were addressed In cases where analysts differed on the assessments we discussed what the rating should be until we reached a consensus We also interviewed agency officials to corroborate our analysis and identify the causes and impacts of any variances Page 23 GAO-16-325 Cloud Computing Appendix I Objectives Scope and Methodology We conducted this performance audit from January 2015 to April 2016 in accordance to generally accepted government auditing standards Those standards require that we plan and perform the audit to obtain sufficient appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objectives We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objectives Page 24 GAO-16-325 Cloud Computing Appendix II Analysis of Agencies’ Cloud Service SLAs against Key Practices Appendix II Analysis of Agencies’ Cloud Service SLAs against Key Practices The following tables show each of the five agencies’—DOD DHS HHS Treasury and VA—cloud services we assessed and our analysis of each contract for cloud services against the key practices In cases where the SLA partially met a practice the analysis also includes discussion of the rationale for why that assessment was provided Note M – met P – partially met NM – did not meet Table 2 Analysis of DOD’s Cloud Service SLAs against Key Practices DOD cloud services Air Force Integrated Risk Information System NM M M X X X X Terms and dates X X X X Measurable performance objectives X X X X X X Service management requirements X X Disaster recovery planning X X Exception criteria X X Notification of security breach X Consequences X Total 5 X 9 NM M P X X X X X X X X 1 7 NM X X X 4 P X X 1 M X X Security performance requirements NM Navy Navy Web Portal Stakeholder roles and responsibilities X P Army Email as a Service Key practices Access to agency data P Air Force Case Tracking X 2 1 5 2 3 Source GAO analysis of DOD data I GAO-16-325 With regard to those services that partially met key practices Air Force • The Integrated Risk Information System partially addressed one key practice on how and when the agency was to have access to its data and networks It included how the data would be transitioned but did not specify how access to data and networks was to be managed or maintained Page 25 GAO-16-325 Cloud Computing Appendix II Analysis of Agencies’ Cloud Service SLAs against Key Practices • The Case Tracking cloud service partially included the practice on specifying metrics for security performance requirements It specified how security needs were to be met but did not give specific metrics for doing so Army • Email as a Service partially addressed two key practices For the practice on specifying service management requirements it specified how the cloud service provider was to monitor performance but did not address how the provider was to report performance or how the agency was to confirm the performance For the other practice on specifying metrics for security performance requirements it included how security needs were to be met but did not specify the security metrics Navy • The Web Portal partially incorporated two key practices For the practice on how and when the agency was to have access to its data and networks it specified how the data was to be transitioned but not how access to data and networks was to be managed or maintained For the other practice on specifying metrics for security performance requirements it included monitoring of the contractor regarding security but did not specify security metrics Page 26 GAO-16-325 Cloud Computing Appendix II Analysis of Agencies’ Cloud Service SLAs against Key Practices Table 3 Analysis of DHS’s Cloud Service SLAs against Key Practices DHS Cloud Services Business Intelligence as a Service P NM E-mail as a Service M P NM Web Content Management as a Service Infrastructure as a Service Key practice M Stakeholder roles and responsibilities M X X X X Terms and dates X X X X Measurable performance objectives X X X X Access to agency data X X X X Service management requirements X X X X Disaster recovery planning X X X X Exception criteria X X X X Security performance requirements X X X X Notification of security breach X X Consequences X X X Total 10 10 7 P NM M X X 1 10 P NM X 2 Source GAO analysis of DHS data I GAO-16-325 Infrastructure as a Service partially incorporated two key practices For the practice on how and when the agency was to have access to its data and networks it specified how and when the agency was to have access to its data and networks but did not provide how data and networks was to be transitioned back to the agency in case of an exit For the other practice on service management requirements it described how the cloud service is to monitor performance but did not specify how and when the agency was to confirm audits of the service provider’s performance Page 27 GAO-16-325 Cloud Computing Appendix II Analysis of Agencies’ Cloud Service SLAs against Key Practices Table 4 Analysis of HHS’s Cloud Service SLAs against Key Practices National Institute of Bio-Medical Imaging and Bio-Engineering Public Website National Institute on Drug Abuse Pubic Website HHS Cloud Service Remedy Force Medidata Rave Key practice M M Stakeholder roles and responsibilities X X X X X Terms and dates X X X X X X X X Measurable performance objectives Access to agency data P NM P X X X Service management requirements X NM M P NM M X X X X X P X NM Grant Solutions M P NM X X Disaster recovery planning X X X X Exception criteria X X X X Security performance requirements X X X X X Notification of security breach X X X X X Consequences X Total 8 X 1 1 8 2 X 9 1 8 X X X X 2 6 1 3 Source GAO analysis of HHS data I GAO-16-325 With regard to those services that partially met key practices • National Institute of Health’s Remedy Force partially addressed one key practice on defining measurable performance objectives It included various performance objectives such as levels of service and availability of the cloud service capacity and capability and measures for response time but it did not include which party was to be responsible for measuring performance • The National Institute of Health’s Medidata Rave partially incorporated two key practices It defined measurable performance objectives specifically it specified levels of service capacity and capability of the service and response time but did not specify the period of time that it was to be measured For the other practice on specifying a range of Page 28 GAO-16-325 Cloud Computing Appendix II Analysis of Agencies’ Cloud Service SLAs against Key Practices enforceable consequences it specified remedies but did not identify any penalties related to non-compliance with performance measures • The National Institute on Drug Abuse Public Website partially addressed two key practices For the practice on specifying how and when the agency is to have access to its data and networks it specified how and when the agency was to have access to its data and networks but did not identify how data and networks were to be managed throughout duration of the SLA For the other practice on specifying a range of enforceable consequences it included a number of remedies but did not specify a range of enforceable penalties • HHS’s Grant Solutions partially incorporated one key practice on specifying service management requirements It provided for when and how the agency was to confirm cloud provider performance but did not specify how the cloud service provider was to monitor performance and report results Page 29 GAO-16-325 Cloud Computing Appendix II Analysis of Agencies’ Cloud Service SLAs against Key Practices Table 5 Analysis of Treasury’s Cloud Service SLAs against Key Practices Treasury Cloud Services Enterprise Asset Management System Key Practices M Stakeholder roles and responsibilities X X X X X Terms and dates X X X X X Measurable performance objectives X X X X X Access to agency data X X Service management requirements X X X X X Disaster recovery planning X X X X X Exception criteria X X X X X Security performance requirements X X X X X Notification of security breach X X X X X P Franchise Financial and Administrative Services NM M P NM IRS Portal Environment M P X Consequences X X X Total 10 10 9 NM Manufacturing Support Suite Treasury Web Solutions M M P NM X NM X X 1 P X 10 8 2 Source GAO analysis of Treasury data I GAO-16-325 With regard to those services that partially met key practices • Treasury’s Internal Revenue Service’s Portal Environment partially included one key practice on specifying how and when the agency was to have access to its data and networks It specified how and when the agency was to have access to its data and networks but it did not provide on how data and networks were to be transitioned back to the agency in case of an exit • The Treasury’s Web Solutions partially addressed two key practices For the practice on specifying how and when the agency was to have access to its data and networks it specified how and when the agency was to have access to its data and networks but it did not provide how data and networks would be transitioned back to the agency in case of an exit For the other practice on specifying a range Page 30 GAO-16-325 Cloud Computing Appendix II Analysis of Agencies’ Cloud Service SLAs against Key Practices of enforceable consequences it did not provide detailed information on a range of enforceable penalties and remedies for non-compliance with SLA performance measures Table 6 Analysis of VA’s Cloud Service SLAs against Key Practices VA Cloud Services Customer Relationship Management Key Practices M Stakeholder roles and responsibilities P NM eKidney M P Terremark NM M X X X Terms and dates X X X Measurable performance objectives X X X Access to agency data X X X Service management requirements X X X Disaster recovery planning X X X Exception criteria X X X Security performance requirements X X X Notification of security breach X X X Consequences X X Total 10 10 P NM X 9 1 Source GAO analysis of VA data I GAO-16-325 Page 31 GAO-16-325 Cloud Computing Appendix III Comments from the Department of Defense Appendix III Comments from the Department of Defense Page 32 GAO-16-325 Cloud Computing Appendix Comments from the Department of Defense GAO DRAFT REPORT DATED FEBRUARY 19 2016 GAO CODE 311411 COMPUTING AGENCIES NEED TO INCORPORATE KEY PRACTICES TO ENSURE EFFECTIVE DEPARTMENT OF DEFENSE COMMENTS TO THE GAO RECOMMENDATION RECOMMENDATION To help ensure continued progress in the implementation of effective cloud computing SLAs GAO recommends that the Secretary of Defense direct the appropriate of cials to ensure key practices are fully incorporated for cloud services as the contracts and associated SLAs expire These efforts should include updating the DOD memorandum on acquiring cloud services and current Defense Federal Acquisition Regulations to more completely include the key practices RESPONSE Concur The Department agrees that the key practices identi ed by GAO are important considerations and should be included in SLAs In recognition of this the CIO will update cloud computing guidance by the end of the calendar year and work with Defense Acquisition Procurement Policy DPAP to update contracting guidance as appropriate Since the key practices identi ed by GAO are applicable across the Federal Government the Federal Acquisition Regulation FAR rather than the Defense Acquisition Regulations System DFARS may be the best place to address the requirement Page 33 GAO-16-325 Cloud Computing Appendix IV Comments from the Department of Homeland Security Appendix IV Comments from the Department of Homeland Security Page 34 GAO-16-325 Cloud Computing Appendix IV Comments from the Department of Homeland Security Page 35 GAO-16-325 Cloud Computing Appendix V Comments from the Department of Health Human Services Appendix V Comments from the Department of Health Human Services Page 36 GAO-16-325 Cloud Computing Appendix V Comments from the Department of Health Human Services Page 37 GAO-16-325 Cloud Computing Appendix VI Comments from the Department of Veterans Affairs Appendix VI Comments from the Department of Veterans Affairs Page 38 GAO-16-325 Cloud Computing Appendix VI Comments from the Department of Veterans Affairs Page 39 GAO-16-325 Cloud Computing Appendix VII GAO Contact and Staff Acknowledgments Appendix VII GAO Contact and Staff Acknowledgments GAO Contact David A Powner 202 512-9286 or pownerd@gao gov Staff Acknowledgments In addition to the contact name above individuals making contributions to this report included Gary Mountjoy assistant director Gerard Aflague Scott Borre Nancy Glover Lori Martinez Tarunkant Mithani Karl Seifert and Andrew Stavisky 311411 Page 40 GAO-16-325 Cloud Computing GAO’s 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