IAM for Government

1

CISA Zero Trust Maturity Model

The Cybersecurity and Infrastructure Security Agency (CISA) Zero Trust Maturity Model provides federal agencies with a roadmap for zero trust implementation across five pillars: Identity, Device, Network, Application, and Data. Identity is the first pillar and the foundation of zero trust architecture: every access decision begins with a verified identity claim. GCA delivers zero trust identity programs aligned to CISA's maturity model. It advances agencies from Traditional through Advanced to Optimal maturity.

• CISA Zero Trust Maturity Model Identity pillar assessment and gap analysis
• Enterprise identity governance aligned to zero trust principles
• Identity-aware access policy design for cloud and on-premises applications
• Continuous validation architecture replacing perimeter-based trust models

2

OMB M-22-09 Implementation

OMB Memorandum M-22-09, Moving the U.S. Government Toward Zero Trust Cybersecurity Principles, established specific zero trust implementation targets for federal civilian executive branch agencies. The identity-related requirements include agency-wide phishing-resistant MFA, enterprise-wide employee identity lifecycle management, and the elimination of password-only authentication for all federal employees and contractors. GCA provides implementation services that satisfy each identity requirement.

• Phishing-resistant MFA deployment across agency workforce
• Employee identity lifecycle management aligned to M-22-09 targets
• Password elimination roadmap and implementation
• M-22-09 compliance assessment and progress reporting

3

Executive Order on Cybersecurity (EO 14028)

Executive Order 14028, Improving the Nation's Cybersecurity (May 2021), directed federal agencies to adopt zero trust architecture, deploy phishing-resistant MFA, and improve identity credential and access management programs. The EO's implementation guidance, including CISA's Cloud Security Technical Reference Architecture and OMB's zero trust strategy memo, creates a multi-document compliance framework. GCA maps this directly to IAM architecture decisions.

• EO 14028 identity requirement mapping and compliance gap assessment
• Cloud IAM architecture aligned to EO 14028 and CISA TRA guidance
• Identity event logging and monitoring for CISA visibility requirements
• Agency-wide ICAM program assessment against EO 14028 targets

4

Contractor Identity Management

Federal agencies rely on large contractor workforces that require access to agency systems while operating under different employment and vetting processes than federal employees. Contractor identity management presents distinct challenges: identity proofing, credential issuance, access scoping, and timely deprovisioning. These require specific processes separate from the agency's employee identity lifecycle.

• Contractor onboarding and identity proofing workflows
• Time-bounded access aligned to contract period of performance
• Contractor access certification and periodic revalidation
• Automated deprovisioning triggered by contract and clearance events

1

Phishing-Resistant MFA

OMB M-22-09 and NIST SP 800-63B AAL3 both require phishing-resistant authentication for federal systems. Phishing-resistant authenticators, including FIDO2/WebAuthn hardware security keys and PIV-derived credentials, provide authentication assurance that credential phishing attacks cannot undermine. GCA implements phishing-resistant MFA programs that satisfy federal requirements and integrate with existing agency identity infrastructure.

• FIDO2/WebAuthn hardware security key deployment and management
• PIV-derived credential implementation for mobile and cloud access
• Phishing-resistant MFA rollout strategy and change management
• Legacy application authentication modernization to support AAL2/AAL3

2

CAC/PIV Integration

Common Access Cards (CAC) and Personal Identity Verification (PIV) cards are the primary phishing-resistant credentials for Department of Defense and federal civilian agency workforces respectively. Integrating CAC and PIV authentication with modern cloud applications, legacy on-premises systems, and remote work infrastructure requires specialized identity architecture expertise. GCA designs and implements CAC/PIV integration across diverse government IT environments. GCA handles certificate validation and OCSP responder configuration.

• CAC/PIV integration with Microsoft Entra ID and cloud applications
• PIV authentication for VPN and remote access infrastructure
• Certificate validation and OCSP responder configuration
• Derived PIV credential programs for mobile workforce access

3

ICAM Program Assessment

Federal agencies are required to maintain a documented Identity, Credential, and Access Management (ICAM) program. GCA provides ICAM program assessments that measure current state against NIST SP 800-63, FICAM guidance, and OMB policy requirements - producing a gap analysis, maturity rating, and prioritized remediation roadmap that agencies can use to drive program investment and report to oversight bodies. For agencies implementing on-premises identity governance to support contractor lifecycle management and periodic access revalidation, GCA deploys platforms including Netwrix Identity Manager. GCA documents assurance level selections and maps controls to specific NIST requirements.

• ICAM program maturity assessment against FICAM playbook
• NIST SP 800-63 assurance level alignment review
• Identity governance gap analysis and remediation roadmap
• OMB M-22-09 compliance gap assessment and target state design

CJIS Authentication Requirements

CJIS mandates advanced authentication for all access to Criminal Justice Information systems. This includes multi-factor authentication for remote access and sophisticated access controls tied to the role and responsibility of the user. GCA implements MFA and credential programs aligned to CJIS security policy requirements for state and local law enforcement agencies and their IT service providers.

• Advanced MFA design for CJI system access (remote and on-premises)
• Badge reader integration for law enforcement facilities
• Contract compliance verification for third-party access
• CJIS audit trail design and retention policy implementation

Identity Governance for Law Enforcement

Law enforcement identity lifecycle differs from civilian government. Officer hiring, transfers, and separation follow law enforcement-specific processes. Contractors and vendors supporting police and sheriff departments require separate identity governance reflecting their external status and time-bound access tied to contract performance periods. GCA designs identity programs that respect the law enforcement context.

• Officer identity lifecycle aligned to law enforcement hiring and separation processes
• Contractor access governance for IT service providers and software vendors
• Role-based access control scoped to investigative job function
• Access audit and compliance reporting for state oversight bodies

NIST SP 800-171 Identity Control Implementation

GCA implements the IA and AC control families from NIST SP 800-171 in nonfederal contractor environments. This includes identification and authentication (IA-2, IA-4, IA-5), access control design, privileged access management, and audit logging that satisfies both CMMC assessment and contract compliance requirements. Our implementations are calibrated for both on-premises and GCC / GCC High cloud environments.

• IA-2 authentication and MFA for CUI systems in contractor environment
• IA-4 and IA-5 identifier and credential lifecycle management
• AC-2 and AC-3 role-based access control for CUI data environments
• Audit and accountability controls (AU-2, AU-12) for CMMC assessment

CMMC 2.0 Supply Chain Assessment

CMMC assessments are flow-down requirements — a prime contractor's certification depends on their subcontractors' compliance. A subcontractor's identity and access control gaps become the prime contractor's compliance risk. GCA provides assessment and remediation services designed to meet CMMC assessor expectations and satisfy contract language requiring assessment-ready identity programs.

• CMMC 2.0 IA and AC control readiness assessment
• Gap remediation against NIST SP 800-171 baseline
• Subcontractor compliance verification and aggregate supply-chain risk reporting
• Evidence documentation and assessment-day support

1

NIST SP 800-63 Digital Identity Guidelines

NIST SP 800-63 and its companion volumes (800-63A for enrollment and identity proofing, 800-63B for authentication and lifecycle management, 800-63C for federation and assertions) establish the definitive federal framework for digital identity. GCA designs identity programs against these volumes. GCA documents assurance level selections and map controls to specific NIST requirements. For agency-to-agency and contractor federation requirements, GCA implements standards-compliant federation architectures using platforms such as Ping Identity, which supports the SAML 2.0 and OIDC profiles required for FAL2 and FAL3 federation in federal environments.

• Identity Assurance Level (IAL) determination and implementation
• Authenticator Assurance Level (AAL) selection and MFA deployment
• Federation Assurance Level (FAL) architecture for agency-to-agency federation
• NIST 800-63 revision 4 alignment for new and existing programs

2

NIST SP 800-53 Security Controls

NIST SP 800-53, Security and Privacy Controls for Information Systems and Organizations, provides the control catalog that FedRAMP and FISMA use as their baseline. The Identity and Access Management (IA) control family in 800-53 maps directly to IAM program requirements, covering identification, authentication, authorization, and access enforcement.

• IA control family implementation and documentation
• Access enforcement controls (AC family) design and implementation
• Audit and accountability (AU family) for identity event logging
• FISMA system authorization IAM control implementation

3

FedRAMP Authorization

FedRAMP (Federal Risk and Authorization Management Program) establishes a standardized approach to security assessment and authorization for cloud services used by federal agencies. FedRAMP Moderate and High baselines impose specific IAM requirements on cloud service offerings. Government contractors using cloud services must understand and satisfy these requirements.

• FedRAMP IAM control implementation for cloud service authorization
• Agency-side FedRAMP control inheritance for SaaS identity integration
• Continuous monitoring identity controls for FedRAMP authorized systems
• FedRAMP Moderate and High baseline IAM gap assessment

4

CISA Directives

CISA Binding Operational Directives (BODs) and Emergency Directives impose mandatory cybersecurity actions on federal civilian executive branch agencies. Several BODs directly address identity and authentication: BOD 22-02 (mitigating known exploited vulnerabilities), BOD 20-01 (HTTPS enforcement), and others. These create a continuous stream of mandatory identity program updates that agencies must implement and document.

• BOD compliance assessment for identity-relevant directives
• CISA Known Exploited Vulnerability remediation for identity systems
• CISA SCuBA (Secure Cloud Business Applications) identity guidance implementation
• Cross-agency identity event sharing and CISA reporting integration

FedRAMP Authorization Stalled by IA-Family Findings

Under the NIST SP 800-53 baseline that underpins FedRAMP, an Authorization to Operate is not granted with open IA control findings (IA-2: Authentication, IA-4: Identifier Management, IA-5: Authenticator Management, IA-6: Access Control). A cloud service offering with unresolved identity and access control gaps remains unauthorized. For cloud-first agencies, FedRAMP stalls mean systems cannot go into production, innovation initiatives are delayed, and legacy systems cannot retire. A single identity control gap can delay an entire cloud migration program by 6-12 months.

M-22-09 Deadline Slippage and Oversight Escalation

OMB M-22-09 set specific deadlines for phishing-resistant MFA and zero trust implementation. Agencies that miss these targets are measured against that failure in subsequent FISMA reporting cycles. Each missed deadline becomes the baseline for the next audit period. An agency behind on M-22-09 does not catch up; the gap widens. And the gap is not hidden — it appears in OIG (Office of Inspector General) reports and Congressional inquiry responses. Missing federal mandates creates a compliance narrative that affects agency funding, leadership credibility, and downstream modernization initiatives.

CMMC Assessment Failure and Supply Chain Disconnection

Defense contractors failing CMMC 2.0 assessment face a rapid audit cycle and remediation timeline — and until remediation is complete, they lose contract eligibility. Subcontractors' CMMC failures become prime contractor certification risks. In a supply chain where certification cascades, a single identity control gap at a subcontractor can stall the entire prime contractor's business development cycle. The cost is not a fine; it is exclusion from new work until remediation is complete and re-assessment confirms compliance.

CJIS Data Access Suspension for Law Enforcement

State and local law enforcement agencies failing to maintain CJIS compliance face data access suspension — disconnection from FBI criminal justice information systems and the ability to query national crime databases. For a police or sheriff department, this is operational shutdown. Officers cannot run background checks, agencies cannot participate in investigations requiring interstate information sharing, and the agency becomes non-functional for investigative operations. CJIS compliance is not a governance metric; it is a requirement for operating as a law enforcement agency in the United States.