02/23/2026
Bruce Dillon
Senior Principal | RMF Cybersecurity Architect
Senior Principal | RMF Cybersecurity Architect
A song can speak to our soul so well and can tell a compelling story. I thought deeply about the title of this post and what would strike the right tone. In the end, Elvis won! His famous song “Risk Me Tender”… or something like that, was perfect for the message. I had some solid runner-ups though. One of Poison’s great songs we all love – “Talk NISTy to me” or Olivia Newton-John’s famous song – “Let’s get Residual” hopefully would have kept you reading too. Elvis’s song is more about the whole relationship and not just a one night stand. So let me try to close the gap and connect the dots of the RMF love language.
In the Department of War cybersecurity ecosystem, few words carry as much weight as “ATO.” For some, it represents validation and mission readiness. For others, it signals documentation sprints, artifact scrambles, and the quiet anxiety of waiting for an Authorizing Official (AO) that might say “no.” While the Risk Management Framework (RMF) is formally structured around categorization, control selection, implementation, assessment, authorization, and continuous monitoring, anyone who has lived through multiple ATO cycles understands a deeper truth: RMF is fundamentally about relationships. Controls matter. Artifacts matter. Evidence matters. But what ultimately drives successful Authorizations to Operate is trust between developers, engineers, ISSMs & ISSOs, Security Control Assessors (SCAs), and AO offices.
Each of these groups operates with different incentives, pressures, and professional dialects. Developers focus on speed, features, and delivering operational capability. Engineers think in terms of architecture, reliability, segmentation, and long-term design integrity. ISSMs & ISSOs translate technical implementation into control narratives, parameter alignment, and audit-ready evidence. SCAs are charged with independent validation, ensuring controls are implemented effectively and demonstrably. AO offices absorb enterprise-level risk and must make defensible decisions that can withstand scrutiny. When these perspectives are misaligned, friction builds. When they are aligned, ATOs become smoother, findings decrease, and innovation moves forward more confidently.
One of the most common breakdowns in the RMF process occurs between developers and security staff during implementation. Developers often feel they have “done the security work” once encryption is enabled, logging is turned on, or multifactor authentication is integrated. From their perspective, the technical safeguard exists. From the ISSM’s perspective, however, implementation is only the beginning. Can key management be demonstrated? Are boundary protections clearly defined? Is the control described in a way that aligns with policy language? The gap here is not about competence but translation. Developers need to understand why a control exists in operational risk terms, and ISSMs need to understand how the system actually works before crafting narratives. Teams that embed security into architecture discussions early avoid the painful retrofit cycle that slows so many ATO efforts. When ISSMs and ISSOs are brought in at design time rather than artifact-collection time, compliance becomes intentional instead of reactive.
The dynamic between engineers and ISSOs introduces another layer of complexity, particularly in modern cloud architectures. Engineers design around trust zones, identity boundaries, managed services, and automation pipelines. ISSOs must translate those design decisions into evidence and inheritance documentation. In cloud environments, especially at higher impact levels, inheritance strategy becomes critical. If the division of responsibility between platform, provider, and tenant is unclear, assessment quickly turns into discovery. Discovery during assessment often results in findings. Successful teams address this by producing clear boundary diagrams, mapping control inheritance early, and developing responsibility matrices that align technical ownership with specific controls. This documentation is not bureaucratic overhead; it is relational currency that builds credibility with assessors and AO offices.
SCAs, in particular, are frequently misunderstood. They are sometimes perceived as obstacles to authorization rather than independent validators of risk posture. In reality, SCAs value objectivity, repeatability, and evidence sufficiency. Their greatest frustration arises not from minor technical gaps but from misalignment between narrative and reality. When control descriptions do not match system behavior, or when evidence is incomplete or delivered at the last moment, trust erodes. Mature teams conduct internal pre-assessments before formal evaluation. They align on test procedures in advance and provide indexed, well-organized artifacts. Transparency about known weaknesses builds more confidence than a claim of perfection ever could. A clean assessment report (not perfect) significantly influences an AO’s comfort level with authorization.
Understanding the AO perspective is essential for teams seeking consistent ATO success. An AO is not approving architecture elegance or endorsing technical preference. They are accepting risk on behalf of the mission and the organization. Their considerations extend beyond individual controls to enterprise precedent, mission impact, and cumulative exposure. When new ideas are introduced—whether Zero Trust, federated identity models, serverless architectures, or automated DevSecOps pipelines—the question is not whether the technology is modern or efficient. The question is whether the associated risk is understood, bounded, monitored, and defensible. Teams that present innovation in terms of risk reduction, attack surface minimization, improved logging fidelity, or tighter identity enforcement speak directly to AO priorities. Innovation framed as modernization may stall; innovation framed as measurable risk improvement gains traction.
Several inflection points within RMF frequently determine whether an ATO progresses smoothly or stalls. Boundary definition is one of the most significant. Ambiguous system boundaries create confusion about control applicability, inheritance, and assessment scope. When boundaries shift late in the process, timelines expand and trust can suffer. Freezing and socializing the boundary early—aligning it with diagrams, data flows, and contractual responsibilities—prevents unnecessary turbulence. AOs appreciate clarity. They respond positively to risk-based decisions that are aligned with categorization and justified through analysis rather than fear.
The handling of POA&Ms reveals much about a RMF team’s maturity. Many organizations treat POA&Ms as admissions of failure. In reality, well structured POA&Ms can accelerate authorization. An AO is often more comfortable approving a system with a clearly documented weakness, defined mitigation steps, accountable ownership, and realistic timelines than approving one that claims flawless implementation. The key is proactive communication. Late-breaking findings that surprise leadership damage confidence far more than known and managed gaps discussed early in the process.
Continuous monitoring is perhaps the most powerful credibility engine available to RMF teams. Static compliance artifacts provide a snapshot in time; automated monitoring demonstrates sustained vigilance. When teams can show real-time vulnerability scanning, automated configuration management, centralized log aggregation, and disciplined review cycles, the narrative shifts from “checklist compliance” to active risk management. Automation reduces uncertainty, and reduced uncertainty increases the likelihood of authorization decisions that support innovation. For AOs, mature monitoring reduces the perceived impact of approving new architectural approaches because the system demonstrates resilience and visibility.
Predictability is another often overlooked driver of successful ATOs. AO offices and SCAs value stability in process. Regular status updates, monthly risk reviews, structured communication cadence, and early engagement reduce the emotional volatility that sometimes accompanies authorization cycles. When packages arrive organized, narratives align with architecture, and assessment findings are minimal and unsurprising, confidence builds. Over time, that confidence translates into smoother renewals and greater openness to new concepts.
Ultimately, the RMF teams that consistently achieve successful ATOs share several common traits. Security is embedded in design rather than layered on at the end. Control ownership is clearly defined. Evidence collection is automated where possible. Pre-assessments are conducted honestly. AO offices are engaged early and often. Risk is communicated clearly, without exaggeration or minimization. Continuous monitoring is treated as an active discipline rather than a rubber stamp reporting requirement. Most importantly, professional respect flows in all directions. Developers recognize that RMF staff are mission enablers. ISSMs understand the operational pressures facing engineers. SCAs are treated as partners in validation rather than adversaries. AO offices are approached with transparency rather than persuasion.
RMF is a structured dialogue about risk that enables mission execution. When relationships are strained, RMF feels heavy and adversarial. When relationships are healthy, RMF becomes a trust architecture. That trust allows AOs to say yes more often—not because risk disappears, but because it is understood, bounded, and monitored. Successful ATOs are not defined by zero findings or flawless documentation. They are defined by credibility. They reflect teams that understand each other’s pressures, communicate in shared language, and approach risk as a collective responsibility.
In the end, an ATO is not simply a technical milestone. It is a leadership decision backed by evidence and influenced by relationships. My professional deference is to the word risk, but to lean into RMF success it means Relationship Management Framework too. When teams learn the RMF love language—when they understand what developers need, what ISSMs value, what SCAs expect, and what AOs must defend—the process becomes more efficient and far more sustainable. People want to be able to trust other people. And when that alignment happens, the word every program hopes to hear becomes far more common.
Yes.