NAVY ECHELON I HIGH RISK ESCALATION PROCESS:

1 NAVADMINs are known that refer back to this one:
NAVADMIN ID Title
NAVADMIN 023/22 NAVY HIGH RISK REVIEW PROCESS
UNCLASSIFIED//

ROUTINE

R 111857Z JUL 19

FM CNO WASHINGTON DC

TO NAVADMIN

INFO CNO WASHINGTON DC

BT
UNCLAS

NAVADMIN 154/19

PASS TO OFFICE CODES:
FM CNO WASHINGTON DC//N2N6//
INFO CNO WASHINGTON DC//N2N6//

MSGID/GENADMIN/CNO WASHINGTON DC/N2N6/JUL//

SUBJ/NAVY ECHELON I HIGH RISK ESCALATION PROCESS//

REF/A/DOC/DODI 8510.01/DOD/28JUL17//

REF/B/DOC/OPNAVINST 5239.1D/CNO/18JUL18//

REF/C/LTR/DON CIO MEMORANDUM/DON/15NOV2015//

REF/D/DOC/SECNAV/DON/MARCH 2019//

REF/E/LTR/NAVY SECURITY CONTROL ASSESSOR (SCA) RISK MANAGEMENT FRAMEWORK 
(RMF) ASSESSMENT AND AUTHORIZATION TESTING GUIDANCE//

REF/F/RMG/CNO/261805Z DEC 18//

NARR/REF A IS DEPARTMENT OF DEFENSE INSTRUCTION 8510.01, RISK MANAGEMENT 
FRAMEWORK (RMF) FOR DOD INFORMATION TECHNOLOGY (IT).  REF B IS CHIEF OF NAVAL 
OPERATIONS INSTRUCTION 5239.1D, U.S. NAVY CYBERSECURITY PROGRAM.  REF C IS 
DEPARTMENT OF THE NAVY CHIEF INFORMATION OFFICER MEMORANDUM ADDITIONAL 
REQUIREMENTS FOR NAVY HIGH RISK ESCALATION PACKAGES.  REF D IS THE SECRETARY 
OF THE NAVYS CYBERSECURITY READINESS REVIEW.  REF E IS THE NAVY SECURITY 
CONTROL ASSESSOR (SCA) RISK MANAGEMENT FRAMEWORK (RMF) ASSESSMENT AND 
AUTHORIZATION TESTING GUIDANCE.  REF F IS NAVADMIN 315/18, COMPILE TO COMBAT 
IN 24 HOURS REQUIREMENT (C2C24) IMPLEMENTATION FRAMEWORK.// 
POC/GURLEY/CIV/OPNAV N2N6G5/TEL: 571-256-8522/
EMAIL:  stephen.r.gurley1@navy.mil//

RMKS/1.  This NAVADMIN provides direction on the Navy Echelon I High Risk 
Escalation (HRE) process.  It applies to all U.S. Navy (USN) Information 
Technology (IT) as defined in references (a) and (b) that have been 
determined in accordance to the criteria described in this message.  The HRE 
process provides operational risk, impact, and mission criticality 
assessments to the HRE Advisory Group
(HREAG) which will determine whether to recommend the continued operation of 
a network, system, or circuit with aggregated high or very high risk.

2.  Background.  Per references (a) through (c), the Department of the Navy 
(DON) Deputy Chief Information Officer (Navy) (DDONCIO (N)) must review and 
document concurrence on all USN IT with aggregated high or very high risk, as 
determined by the cognizant Security Controls Assessor (SCA) at the system 
level and authorized by the Authorizing Official (AO) at the operational 
level, to the DON Office of the Chief Information Officer (OCIO).  The SCA 
determines systems as either high or very high risk in the system level 
Security Assessment Report (SAR) per reference (b).  The SCA will determine 
risk levels based on a risk assessment in accordance with federal and 
Department of Defense (DoD) guidance with focus on operational risk, mission 
criticality, aggregate lower-level risk and any potential negative impacts to 
DoD networks.  The AO considers the current security state of the system (as 
reflected by the risk assessment and recommendations provided in the SAR) and 
weighs this against the system criticality.  OCIO must review high risk 
systems every six (6) months in accordance with DoD guidance as outlined in 
reference (a).

3.  The HREAG is comprised of representatives from OCIO, Deputy Assistant 
Secretary of the Navy for Command, Control, Communications, Computers, and 
Intelligence (DASN C4I), Deputy Chief of Naval Operations for Information 
Warfare (OPNAV N2N6), Senior Information Security Officers (SISO), Program 
Offices, Resource Sponsors, Systems Commands Functional Authorizing 
Officials(FAO), Functional SCAs (FSCA), Naval Information Warfare Systems 
Command
(NAVWAR) acting as the Navy SCA, and Fleet Cyber Command acting as the Navy 
Authorizing Official (NAO).

4.  Legacy application owners with applications in HRE who modernize their 
applications in accordance with the Compile to Combat in 24 Hours (C2C24) 
framework can take advantage of the streamlined Risk Management Framework 
(RMF) accreditation process by inheriting security controls of using shared 
infrastructure.  This streamlined RMF process, called Rapid Assess and 
Incorporate for Software Engineering in a Day (RAISED), significantly reduces 
the time and effort applications need to complete RMF.  This enables a more 
responsive cybersecurity environment where new vulnerabilities can be quickly 
remediated.  Resources are better spent modernizing applications to be more 
secure and agile vice continuing to try to keep legacy applications compliant 
with current and emerging cybersecurity challenges.  Reference (f) is 
germane.

5.  HRE Timeline.  Below is the HRE expected timeline for dates of actions to 
be taken to achieve an authorization from the appropriate AO for systems with 
an existing authorization.  OCIO, OPNAV N2N6, or NAO reserves the right to 
adjust this timeline as required and to work individually with stakeholders 
to help expedite completion.  A visual timeline is available at 
https://portal.secnav.navy.mil/orgs
/OPNAV/N2N6/DDCION/N2N6BC4/HRE/SitePages/Home.aspx.
    a.  Fleet Cyber Command (FCC) issues two monthly Warning Orders 
WARNORDs), one identifying systems and one identifying circuits within 180 
days of expiration in 30 day increments.  These WARNORDs capture what is 
nearing expiration, or not on glideslope to attain a follow-on authorization, 
and therefore indicates if a system or circuit is at risk for moving into a 
high risk/very high risk status.  The systems WARNORD capture systems under 
NAO responsibility only.  The circuits WARNORD captures circuits under NAO 
and Defense Security Service (DSS) responsibility.
    b.  At 70 days prior to the HREAG conference, the appropriate AO will 
send the conference agenda to OPNAV N2N6 and applicable Echelon II CIOs and 
program Package Submitting Officer (PSO) for systems or circuits that have 
moved into HRE status.  The appropriate AO will provide a listing of systems 
and circuits under his/her responsibility only.
    c.  At 55 days prior to the HREAG conference, Echelon II CIOs and /or 
program PSOs will provide a signed Certification Determination
(CD) or a SAR no older than 90 days in accordance with current policy.  If 
there is not a current signed CD/SAR, the affected system or circuit will not 
proceed further in the HRE process and will not be considered for 
authorization.  For HRE purposes, the following are minimum requirements for 
the SCA to conduct a risk assessment and issue a CD/SAR.
        (1) Completed automated scans (both Assured Compliance Assessment 
Solution (ACAS) and automated Security Technical Implementation Guide (STIG) 
checks per reference (e).
        (2) Documented vulnerabilities in Enterprise Mission Assurance 
Support System (eMASS).
        (3) Completed internal risk assessment on those vulnerabilities as 
documented on the risk assessment tab (if requesting a SAR).
        (4) Plan of Action and Memorandum entries for items that have not 
been completed (e.g. missing ACAS scans, or automated STIG
checks) and a plan to get those items completed as codified in reference (a).
    d.  At 35 days prior to the HREAG conference, the Echelon II CIO and/or 
program PSO will submit the HRE package for the affected system or circuit to 
the appropriate AO.  The contents of the package will include:
        (1) Quad chart with C2C24 Submission ID.
        (2) Signed CD/SAR uploaded into eMASS.
        (3) The re-accreditation/re-authorization request.
        (4) The Risk Evaluation Threat Assessment (RETA) form.  This includes 
intelligence from the Office of Naval Intelligence Top 20 list.
        (5) The signed flag officer/senior executive service endorsement.
        (6) Packages missing these components will be delayed to the 
following briefing month.  Any exceptions will require Echelon II flag 
officer request to Echelon I flag officer leadership for urgent high risk 
escalation.  If this delay will impact a Navy critical installation or 
capability, OPNAV and NAO will work with the PSO and Program Executive Office 
to determine an appropriate way ahead to support Fleet capability.
    e.  At 25 days prior to the HREAG conference, the appropriate AO will 
provide OPNAV N2N6 a compiled HRE brief.  OPNAV N2N6 will send a message 
requesting cognizant resource sponsor(s) presence at the upcoming HREAG 
conference and may advise Echelon II flag officers.
    f.  At five (5) days prior to the HREAG conference, the appropriate AO 
will provide a read-ahead package to the HREAG membership and applicable 
Echelon II CIOs and/or program PSOs.
    g.  HREAG conference occurs, caveats and determinations are issued.
        (1) The HREAG conference shall normally be scheduled to occur the 
first Wednesday of each month.
    h.  At plus seven (7) days, the appropriate AO will submit a consolidated 
brief to OPNAV N2N6 and FCC leadership.
    i.  At plus 10 days, the OPNAV N2N6 lead will brief the Deputy Chief of 
Naval Operations (DCNO (N2N6)) and DASN C4I.
    j.  At plus 14 days, OPNAV N2N6 will formalize the conclusion of the 
HREAG conference by communicating the outcome to the office of OCIO, copying 
the DASN C4I for further sharing with the Assistant Secretary of the Navy for 
Research, Development and Acquisition (ASN RDA).
    k.  At plus 21 days, OCIO will make the final determination in accordance 
with reference (a) and send to the appropriate AO.
        (1) For Nuclear Command Control Communications (NC3) and Mobile User 
Objective System (MUOS), OCIO will also send a recommendation to U.S.  
Strategic Command for final concurrence.
        (2) For circuits in the HRE approval process, a request to the 
Defense Information Systems Agency (DISA) for Authority To Connect (ATC) is 
required once NAO issues the Interim Authorization to Operate or 
Authorization to Operate with Conditions.  DISA requires 15 business days for 
circuit processing.
    l.  At plus 30 days, with a recommendation, the appropriate AO will issue 
an authorization in accordance with OCIO determination.

6.  C2C24  Application owners requesting an authorization through the HRE 
process for systems that fall under C2C24 Category I in accordance with 
reference (f), must have submitted their C2C24 system surveys.  Application 
owners shall provide the C2C24 Submission ID as part of their packages.  
Category I systems that have not submitted C2C24 system surveys will not be 
considered by the HREAG.  This requirement does not apply to circuits, cloud-
based Software-as-a-Service, systems decommissioning or sun-setting within
24 months, non-government of the shelf applications or systems that are not 
within the scope of reference (a).  Further guidance can be found at 
https://portal.secnav.navy.mil/orgs/OPNAV/N2N6/DDCION/C2C24/.

7.  OPNAV N2N6 reserves the right to reconsider funding for IT Procurement 
Requests (ITPR) and Defense Business System (DBS) certification in the 
following cases:
    a.  Systems or circuits active within the HRE process for which program 
managers have not performed due diligence in the mitigation of cybersecurity 
weaknesses.
    b.  Applicable systems for which program managers have not submitted a 
C2C24 system survey.
    c.  Systems or circuits with incomplete testing annotated on their 
CD/SAR, the validity of justification for incomplete testing will be vetted 
by the SCA.
    d.  Systems or circuits without a SCA signed CD/SAR.
    e.  Systems or circuits with multiple iterations through the HRE process 
that are not considered Fact of Life (FOL).

8.  FOL Continuous Monitoring
    a.  A system that does not have an exit strategy out of a high risk 
status within two years of HREAG approval is eligible to be designated as a 
FOL system.  The Navy will implement a continuous monitoring process for FOL 
systems to verify that the system or circuit is maintaining its cyber hygiene 
as agreed to by the Program Manager, the appropriate SCA and AO.  To be 
considered for FOL status, a system or circuit must meet the following 
criteria:
        (1) Operational commander acknowledgement of high or very high risk.
        (2) SCA determination and documentation in the SAR of an assessment 
of overall systems level of risk, to be passed to the AO.
        (3) AO consideration of the current security state of the system 
based on the following information.  Weighing the below factors, the AO 
renders a final determination of risk to DoD operations and assets, 
individuals and other organizations from the operation and use of the system 
or circuit.
            (a) SCA provided risk assessment and recommendations identified 
in the CD/SAR.
            (b) Operational need for the system identified by the operational 
commander.
            (c) Any applicable risk-related guidance from the DoD, SISO, 
Principle Authorizing Official (PAO), DoD Information Security Risk 
Management Committee (DOD ISRMC), Defense Security /Cybersecurity 
Authorization Working Group (DSAWG), DoD Component SISO, or mission owner(s).
    b.  All FOL determinations shall be made by Echelon I Navy senior 
leadership to include the Chief Information Security Officer and OCIO with 
support from the appropriate SCA and AO and reviewed by the Navy 
Cybersecurity Executive Committee (EXCOM).  The EXCOM review process is 
designed to ensure Echelon I senior leaders are aware of the extent of 
aggregated risk and possible mission impacts.
        (1) Systems and circuits designated as FOL will be moved out of an 
active HRE status and into a continuous monitoring status with subsequent 
monitoring oversight by the SCA, appropriate AO and OPNAV N2N6.
        (2) Program managers must continue to conduct scans on FOL systems 
and circuits, meet OCIO and/or AO stipulations as part of the authorization, 
and provide six month Interim Progress Reports
(IPRs) to the HREAG.  This is a significant reduction in paperwork as 
compared to a full HRE package.  IPR format is available at 
https://portal.secnav.navy.mil/orgs/OPNAV/N2N6/DDCION/N2N6BC4/HRE
/SitePages/Home.aspx.  FOL circuits will require updated and signed CD/SARs 
as part of the DISA ATC renewal process.
        (3) The SCA, in coordination with the appropriate AO, shall recommend 
that systems or circuits with an increased risk level to be transitioned back 
to an active HRE status.

9.  Exiting the HRE process:  Program managers who effectively demonstrate 
compliance with DoD policies, regulations, and procedures and have 
appropriately applied mitigations to failed security controls and documented 
vulnerabilities may have their respective systems or circuits removed from 
the HRE process as codified by the SCA and issued a moderate or lower 
authorization by the appropriate AO.

10.  This NAVADMIN will remain in effect until canceled or superseded.

11.  Released by VADM Matthew J. Kohler, Deputy Chief of Naval Operations for 
Information Warfare, OPNAV N2N6.//

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UNCLASSIFIED//