Balancing security with cloud solutions is a significant consideration for U.S. Department of Defense (DoD) organizations as more applications migrate to the cloud. Cloud-based teaching and learning solutions offer the DoD many benefits, such as scalability, cost-efficiency, and anytime-anywhere learning – but they also introduce security challenges.
DoD requires protection of its data at the appropriate impact levels (ILs), which differ from the low, moderate, and high levels used by the Federal Risk and Authorization Management Program (FedRAMP). For example, DoD considers For Official Use Only (FOUO), Personal Identifiable Information (PII), and Protected Health Information (PHI) to be Controlled Unclassified Information (CUI), which require protection at DoD Impact Level 4 (IL4). FedRAMP, however, would require that same data to be protected at a FedRAMP Moderate level, which equates to the lower DoD Impact Level 2 (IL2).
DoD IL4 requires cloud solutions to meet additional security controls beyond what is necessary for FedRAMP Moderate compliance.
Similar to how cloud service providers (CSPs) work through the FedRAMP Program Management Office (PMO) to obtain a FedRAMP authorization, CSPs must work with the Defense Information Systems Agency (DISA) to obtain a Provisional Authorization to Operate (P-ATO) at the appropriate impact level. The FedRAMP PMO and DISA authorization processes are similar, requiring security assessments, extensive documentation, continuous monitoring, and a significant investment of a CSP’s time and money.
Few learning management systems (LMS) and learning experience platform (LXP) cloud solutions can meet the more sensitive and rigorous DoD requirements.
The intersection of DoD IL4 and CUI compliance with LMS’ and LXPs underscores the need for specialized solutions and a heightened focus on data security. Organizations, including LMS and LXP providers, should be prepared to go the extra mile to meet the DoD’s stringent requirements, ensuring the protection of DoD-sensitive data and compliance with DoD-specific regulations. The journey toward compliance in this context is not just about technology but also about a commitment to security and continuous improvement.
Offering innovative and modern cloud-based eLearning solutions designed to meet the DoD’s unique security requirements is vital to ensuring the readiness, effectiveness, and safety of U.S. military and defense personnel.