Background Federal agencies and our nation’s critical infrastructures—such as  energy, transportation systems, communications, and financial services—  are dependent on computerized (cyber) information systems and  electronic data to carry out operations and to process, maintain, and  report essential information. The information systems and networks that  support federal operations are highly complex and dynamic,  technologically diverse, and often geographically dispersed. This  complexity increases the difficulty in identifying, managing, and protecting  the myriad of operating systems, applications, and devices comprising the  systems and networks. Cybersecurity professionals can help to prevent or mitigate the  vulnerabilities that could allow malicious individuals and groups access to  federal IT systems. The ability to secure federal systems depends on the  knowledge, skills, and abilities of the federal and contractor workforce that  uses, implements, secures, and maintains these systems. Nevertheless, the Office of Management and Budget (OMB) has noted  that the federal government and private industry face a persistent  shortage of cybersecurity and IT talent to implement and oversee  information security protections to combat cyber threats. In addition, the  RAND Corporation and the Partnership for Public Service have reported  that there is a nationwide shortage of cybersecurity experts, in particular,  in the federal government. According to these reports, this shortage of  cybersecurity professionals makes securing the nation’s networks more  challenging and may leave federal IT systems vulnerable to malicious  attacks. The persistent shortage of cyber-related talent has given rise to  efforts to identify and assess the federal cybersecurity workforce. The National Initiative for  Cybersecurity Education  (NICE) Created a  Framework for Defining  Cybersecurity Workforce  Positions NICE, led by NIST, is a partnership among government, academia, and  the private sector focused on cybersecurity education, training, and  workforce development. The mission of NICE is to energize and promote  a robust network and an ecosystem of cybersecurity education, training,  and workforce development. NICE fulfills this mission by coordinating with  government, academic, and industry partners to build on existing  successful programs, facilitate change and innovation, and bring  leadership and vision to increase the number of skilled cybersecurity  professionals that are helping to keep our nation secure. NICE issued an  initial draft of the National Cybersecurity Workforce Framework (National  Framework) for public comment in September 2011 and the final version  1.0 in April 2013. The National Framework was intended to help identify,  describe, and assess all cybersecurity roles within an organization. The  National Framework organized cybersecurity job functions into 7  categories and 31 specialty areas: Category: a high-level grouping of common cybersecurity functions. Categories group together work and workers that share common  major functions, regardless of job titles or other occupational terms. Specialty area: an area of concentrated work, or function, within  cybersecurity and related work. Related specialty areas are grouped  together into categories. In version 1.0 of the National Framework,  each specialty area was also associated with a distinct set of  cybersecurity related tasks and knowledges, skills, and abilities. In November 2016, NIST issued draft special publication 800-181 which  revised and replaced earlier versions of the National Framework. The  draft was co-authored by NIST, DOD, and DHS and was renamed the  NICE Cybersecurity Workforce Framework (NICE Framework). In August  2017, NIST published the final version of the special publication. The NICE Framework is intended to help the federal government better  identify cybersecurity workforce needs by enabling agencies to examine  specific cybersecurity work roles, and identify personnel skills gaps,  rather than merely examine the number of vacancies by job series. The  NICE Framework added 2 additional specialty areas within the 7  categories. Figure 1 identifies the 7 categories and the 33 specialty areas  in the NICE Framework. The NICE Framework also introduced the concept of work roles as the  third component of cybersecurity job functions. Work roles provide a more  detailed description of the roles and responsibilities of cybersecurity job  functions than do the category and specialty area components of the  NICE Framework. The NICE Framework defines one or more work roles  within each specialty area. For example, as depicted in figure 2, the  NICE Framework defined 11 work roles within the 7 specialty areas in the  “Securely Provision” category. OPM Has Led Several  Efforts to Assess the  Federal Cybersecurity  Workforce In October 2012, in coordination with a NICE interagency working group,  OPM published a cybersecurity employment coding structure that aligned  with the initial draft version of the National Cybersecurity Workforce  Framework. The coding structure assigned a unique 2-digit cybersecurity  employment code to each category and specialty area in the NICE  Framework. According to OPM, the coding of federal positions with  cybersecurity functions was intended to enhance agencies’ ability to  identify critical cybersecurity workforce needs, recruit and hire employees  with needed skills, and provide appropriate training and development  opportunities to cybersecurity employees. In July 2013, OPM initiated the Special Cybersecurity Workforce Project  to support federal efforts to reduce the cybersecurity workforce skills gaps  across agencies. Agencies were to use the definitions of cybersecurity  work, as described in the National Cybersecurity Workforce Framework,  along with OPM’s cybersecurity coding structure, to code positions  performing cybersecurity work by the end of fiscal year 2014. The project  was intended to enable agencies to identify and address their needs for  cybersecurity skill sets to meet their missions. In July 2016, OPM and the Office of Management and Budget (OMB)  issued the Federal Cybersecurity Workforce Strategy. The strategy  details government-wide actions to identify, expand, recruit, develop,  retain, and sustain a capable and competent workforce in key functional  areas to address complex and ever-evolving cyber threats. The strategy  identifies a number of actions intended to address cybersecurity  workforce challenges in: (1) identifying cybersecurity workforce needs, (2)  expanding the cybersecurity workforce through education and training, (3)  recruiting and hiring highly skilled talent, and (4) retaining and developing  highly skilled talent. The strategy states that OPM is to expand cybersecurity position coding  and agencies are to conduct strategic workforce planning. These actions  are related to the requirements of the Federal Cybersecurity Workforce  Assessment Act of 2015, under which OPM is to establish an  employment coding structure and agencies are to identify and report on  cybersecurity workforce critical needs. Figure 3 depicts a timeline of recent efforts to assess the federal  cybersecurity workforce. OPM Issued a  Cybersecurity  Position Coding  Structure,  Procedures, and  Progress Report  Later Than the  Deadlines  Established in the Act  OPM Developed a 3-digit  Cybersecurity Coding  Structure As required by the Federal Cybersecurity Workforce Assessment Act of  2015, OPM developed a cybersecurity coding structure under NICE,  issued guidance to implement the coding structure to identify all federal  civilian cybersecurity positions, and provided a progress report to  Congress on the implementation of the act. However, the coding structure  and procedures were issued later than the act’s deadlines because OPM  was working with the National Institute of Standards and Technology  (NIST) to align the structure and procedures with the draft version of the  NICE Cybersecurity Workforce Framework, which NIST issued later than  planned. The delays in issuing the coding structure and procedures have  extended the expected time frames for implementing subsequent  provisions of the act. The Federal Cybersecurity Workforce Assessment Act of 2015 (the act)  required OPM, in coordination with NIST, to develop a cybersecurity  coding structure by June 15, 2016. OPM addressed this requirement by developing a 3-digit cybersecurity  employment coding structure that fully aligns with the NICE Cybersecurity  Workforce Framework. OPM issued version 1 of the coding structure on  November 15, 2016, 5 months after the deadline established in the act. The coding structure assigns a unique 3-digit cybersecurity employment  code to each work role outlined in the draft version of the NICE  Cybersecurity Workforce Framework. Table 1 presents an example of the  3-digit employment codes associated with one category—”Securely  Provision”—and its component specialty areas and work roles. Although the act had called for the coding structure to be established by  June 15, 2016, OPM officials explained that the coding structure was  issued 5 months later than the established deadline because the structure  was to be aligned with the NICE Cybersecurity Workforce Framework.  However, the draft version of the NICE Framework was not issued until  November 2, 2016. According to NIST officials, the issuance of the draft NICE Framework  was delayed because some of the knowledge, skills, and abilities (KSA)  and task statements that had been originally developed by the  intelligence community were marked as sensitive. NIST delayed  publication of the draft NICE Framework until officials in the intelligence  community had removed any sensitivity designations on the KSAs and  task statements. OPM Developed  Government-wide  Procedures for Assigning  Codes to Civilian  Cybersecurity Positions The act required OPM, in coordination with NIST, DHS, and ODNI to  establish procedures to assist agencies in implementing the cybersecurity  coding structure. OPM was to develop the procedures no later than  September 18, 2016. In accordance with this requirement, OPM coordinated with NIST, DHS,  and ODNI to develop its Guidance for Assigning New Cybersecurity  Codes to Positions with Information Technology, Cybersecurity, and  Cyber-Related Functions. The guidance provides instructions on how  agencies are to assign the 3-digit cybersecurity employment codes to  filled and vacant positions, including required activities for identifying and  assigning codes to cybersecurity positions. The guidance also referenced  additional updates and guidance that were to be posted on OMB’s MAX  website. OPM posted the guidance on the Chief Human Capital Officers Council  website on January 4, 2017, 4 months after the deadline established in  the act. OPM officials said they delayed issuance of the guidance so that  it could be released in coordination with the cybersecurity coding  structure, which was dependent on the release of the draft NICE  Framework. OPM Submitted a  Progress Report to  Congress The act required OPM to report on the progress of agencies’  implementation of the act’s requirements, as well as OPM’s efforts to  develop a coding structure and government-wide coding procedures.  OPM was to submit the progress report to the appropriate congressional  committees no later than June 15, 2016. OPM prepared and submitted its progress report to the congressional  committees identified in the act on July 12, 2016, about 1 month after the  act’s deadline. Among other things, the report stated the following: OPM was coordinating closely with NICE to revise the cybersecurity  coding structure to align with the latest version of the NICE  Framework, which was scheduled to be finalized in September 2016. OPM had begun an education campaign to inform the federal  community of the act and its requirements and was collaborating with  stakeholders and interagency partners on ideas for how to implement  the requirements of the act. An official in OPM’s Employee Services division stated that OPM was  delayed in completing and submitting the report to congressional  committees due to the agency’s internal review process. OPM’s Delays in  Completing Required  Activities Have Resulted in  Later Implementation of  Other Provisions of the Act Because the deadlines for agencies to implement certain provisions of the  act are contingent on the completion of earlier activities, delays by OPM  in issuing the revised cybersecurity coding structure and the government- wide coding procedures have extended the due dates for agencies to  implement other provisions of the act by about 4 months. Specifically: The act required agencies to establish procedures for identifying all IT  or cybersecurity positions and for assigning the appropriate  employment code to each position no later than 3 months after OPM  issued the government-wide coding procedures. If OPM had issued  the coding procedures by September 2016 as the act required,  agencies would have been required to establish their coding  procedures by December 2016. However, because OPM did not issue  the government-wide procedures until January 2017, agencies did not  have to develop their coding procedures until April 2017. Similarly, agencies were to assign employment codes to all of their  cybersecurity positions no later than 1 year after establishing their  coding procedures. Had agencies been required to establish their  procedures by December 2016, they would have been required to  assign the employment codes by December 2017. However, because  they did not have to develop coding procedures until April 2017, they  were therefore required to complete the assignment of employment  codes by April 2018. Further, agencies are required to identify and report on cybersecurity  work roles of critical need beginning 1 year after the employment  codes are assigned. If agencies had been required to assign  employment codes by December 2017, they would have to begin  reporting on their critical needs by December 2018. However,  because they did not have to complete the assignment of employment  codes until April 2018, they are therefore required to identify and  begin reporting on critical needs by April 2019. Figure 4 depicts the delays in earlier activities which can result or have  resulted in later implementation of subsequent provisions of the act. Most CFO Act  Agencies Submitted  Baseline  Assessments, but the  Results May Not Be  Reliable Most of the 24 CFO Act agencies conducted baseline assessments  identifying the extent to which their cybersecurity employees held  certifications and submitted them to Congress as required by the act.  However, 3 agencies did not complete the assessments for various  reasons, such as a lack of resources and tools to do so. Further, of the 21  agencies that did complete the assessments, 4 agencies did not address  all of the reportable information, such as the extent to which personnel  without certifications were ready to obtain them or strategies for mitigating  any gaps. In addition, the assessments conducted by the 21 agencies did  not contain complete, comprehensive, or consistent information on the  certifications held by agencies’ cybersecurity employees due to limitations  in the ability of the agencies to collect the needed information. As a result,  the information collected and reported by most agencies about the  certifications held by agency cybersecurity personnel may be of limited  value for assessing the credentials and qualifications of their  cybersecurity workforces. Most CFO Agencies  Conducted Baseline  Assessments but Several  Agencies Did Not Include  All Reportable Information The Federal Cybersecurity Workforce Assessment Act of 2015 required  agencies to prepare baseline assessment reports identifying the extent to  which their cybersecurity workforces held industry-recognized  certifications as identified under NICE. OPM’s August 2016  memorandum on the requirements and time frames of the act further  stated that agencies were to report the results of the assessments to the  appropriate congressional committees of jurisdiction by December  2016. In the absence of a NICE-defined list of appropriate industry-recognized  certifications, 21 of the 24 agencies covered by the CFO Act had  conducted baseline assessments of the certifications held by their  cybersecurity workforces and submitted the baseline assessment reports  to Congress as of March 2018. Table 2 shows the status of the  agencies’ submissions of the baseline assessments as of March 2018. Three agencies did not conduct baseline assessments:  Instead of conducting a baseline assessment as called for by the act,  DHS submitted its 2016 Comprehensive Cybersecurity Workforce  Update to Congress in March 2017. However, this report did not  include a baseline assessment of the department’s workforce as  called for by the act. The report noted that DHS’s Office of the Chief  Human Capital Officer lacked the ability to view or easily produce  consolidated reports on employee certifications from all DHS  components, and lacked consistent and detailed information about the  readiness of additional employees to complete certification exams and  specific certifications identified by components as being required for  success in their positions. The report further noted that the  department was working with cybersecurity subject matter experts  from each component to revalidate the certifications most important to  the work of their organizations and to organize the information  according to the NICE Framework. The Department of Housing and Urban Development (HUD) prepared  an assessment of IT specialist skills, but did not conduct a baseline  assessment that identified the extent to which its cybersecurity  workforce held industry-recognized certifications. Officials in HUD’s  Office of the Chief Information Officer (CIO) and Office of the Chief  Human Capital Officer stated that the department intends to conduct a  workforce assessment of its cybersecurity employees. The officials  did not provide a time frame for when the assessment would be  conducted. The CIO and Chief Human Capital Officer of the Small Business  Administration (SBA) stated that the agency has been unable to  complete a baseline assessment due to resource constraints. The  officials added that the agency intends to conduct workforce planning  efforts in the future. However, they did not provide a time frame for  when the assessment would be conducted. By not conducting baseline assessments, DHS, HUD, and SBA lack  valuable information about the knowledge and skills of their cybersecurity  employees. This lack of information limits the agencies’ ability to  effectively gauge the competency of individuals who are charged with  ensuring the confidentiality, integrity, and availability of federal information  and information systems. Additionally, by not conducting or reporting on  the assessment, the agencies have not provided Congress the  information it required in the act regarding existing credentials and  certifications of personnel with information technology, cybersecurity, or  other cyber-related job functions. Not All Agencies That  Prepared Baseline  Assessment Reports  Addressed Reportable  Information The act required agencies’ baseline assessment reports to identify the  following:  the percentage of personnel with cybersecurity job functions who held  the appropriate industry-recognized certifications as identified under  NICE;  the level of preparedness of cybersecurity personnel without existing  credentials to take certification exams; and a strategy for mitigating any gaps in (1) personnel holding industry- recognized certifications and (2) the preparedness of personnel  without existing credentials to take certification exams. In September 2016, OPM provided a template that agencies could use in  reporting on their baseline assessments. Using the template, agencies  could report on the number and percentage of surveyed staff with current  certifications and the number and percentage of staff without such  certifications that were planning to obtain them within the next year.  Human resource strategists and program management officials in OPM’s  Employee Services division stated that the template was a guide to help  agencies with the reporting process; however, agencies were not required  to use the template or report their results in the format described in the  template. The 21 CFO agencies that prepared baseline assessment reports did not  always address the reportable information in their baseline assessments.  Specifically, of the 21 assessments that the CFO agencies had prepared,  all of the assessments included information on the percentage of  cybersecurity personnel holding certifications; 17 assessments discussed  the level of preparedness for personnel without certifications to take  certification exams; and 20 included strategies for mitigating certification  gaps. Table 3 shows the extent to which the 21 agencies’ assessments  reported this information. Moreover, 4 of the 21 agencies did not address all reportable information  in their baseline assessments. Specifically: The Department of Commerce did not assess and did not report  information on (1) the level of preparedness for personnel who did not  hold certifications to take certification exams or (2) strategies for  mitigating gaps. Officials in Commerce’s Office of Human Resources  Management and Office of the CIO stated that information on the level  of preparedness and gaps was not readily available because they  have not fully identified and coded the department’s cybersecurity  workforce, and there is no federal requirement for cybersecurity  personnel to hold certifications. The officials stated that they did not  have the time or resources to assess these reporting requirements. Officials in the Department of Energy’s Office of the Chief Human  Capital Officer stated that they did not assess the level of  preparedness for personnel without certifications to take certification  exams because the department does not require its cybersecurity  personnel to hold certifications. As a result, they did not have criteria  for identifying personnel who are prepared to take certification exams. According to the Department of the Interior’s Principal Deputy  Assistant Secretary for Policy, Management, and Budget, the  department did not assess the level of preparedness for personnel  without certifications to take certification exams because neither OPM  nor the department currently requires certifications for these  cybersecurity positions. However, the department's Office of Human  Resources and Office of the Chief Information Officer are exploring  options to determine the level of preparedness across its IT  workforce. According to the National Aeronautics and Space Administration’s  (NASA) baseline assessment report, the agency did not assess the  level of preparedness for personnel without certifications to take  certification exams because the agency does not require its  cybersecurity personnel to maintain certifications. The agency did not  know how many of its personnel were planning to seek certifications  on their own. Data regarding the number of cybersecurity employees that hold  certifications and the level of preparedness of personnel without  certifications can be a useful indicator of the skills and knowledge of an  agency’s cybersecurity workforce. In addition, strategies for addressing  gaps can help an agency increase the skills and knowledge of its  cybersecurity workforce. By not including all reportable information in the  assessments, these four agencies may lack valuable information that  could help them identify and meet the certification and training needs of  their cybersecurity employees who are charged with protecting federal  information and information systems from cyberattacks. However, as  discussed later in this report, the absence of NICE identified appropriate  industry-recognized certifications may have also contributed to  uncertainty for agencies in their efforts to comply with the requirements of  the act. Limitations in Agency  Baseline Assessments  Raise Concerns About the  Reliability of Information  about Certifications Held  by Agencies’  Cybersecurity Employees Limitations in the 21 agencies’ baseline assessments raise concerns  about the reliability of the assessments, thus constraining the conclusions  that can be drawn from their results about the federal cybersecurity  workforce’s certifications. The 21 agencies in our review that conducted  assessments were not able to collect complete, comprehensive, or  consistent information about the certifications held by their cybersecurity  workforces for various reasons. As a result, these agencies had limited  assurance that the certification information contained in their baseline  assessment reports was reliable, thereby diminishing the usefulness of  the assessments in determining the certification and training needs of  their cybersecurity employees. Agencies Were Required to  Assess Cyber Employees’  Certifications before They Had  Fully Defined Their  Cybersecurity Workforces As previously noted, OPM’s August 2016 memorandum on the  requirements of the act stated that, agencies were to report their baseline  assessments to Congress by December 2016. However, according to  OPM’s January 2017 coding guidance, agencies were not required to  complete the assignment of the appropriate 3-digit employment codes to  each position until April 2018. Consequently, agencies were required to  submit their reports on the percentage of personnel performing  cybersecurity functions who possessed certifications before the agencies  had identified all members of their cybersecurity workforce and assigned  the 3-digit cybersecurity employment codes to each position. Because the agencies had not yet fully defined their cybersecurity  workforces using the NICE Framework and the 3-digit coding structure,  the 21 agencies in our review that prepared assessments did not use  consistent criteria to define the population of personnel with cybersecurity  job functions that were included in their baseline assessments. Examples  of the criteria that these agencies used to define the target populations for  their assessments included:  cybersecurity employees who had been coded with the 2-digit  cybersecurity employment codes during the 2013 Special  Cybersecurity Workforce Project; employees within certain occupational series, such as the 2210  Information Technology Management series; personnel within certain roles or organizations, such as the Office of  Information Security or the Office of the CIO; or personnel who performed cybersecurity duties for a defined  percentage of the time. As a result of not having fully defined their cybersecurity workforces prior  to conducting their baseline assessments, the agencies have limited  assurance that their baseline assessments reflected all relevant agency  positions or personnel performing cybersecurity functions as defined by  the NICE Framework. Agencies Were Not Always  Able to Obtain Certification  Information from All Relevant  Employees Several agencies reported that they were not able to obtain information  on certifications from all of the employees they surveyed when conducting  their baseline assessments. Specifically, 6 of the 21 agencies that  prepared assessments reported response rates of between 15 and 42  percent to their surveys or data calls to employees for such information.  Also, officials from two agencies told us that employees’ responses to  their information requests were voluntary due to union and legal  concerns. As a result, these agencies have limited assurance that their  baseline assessment reports conveyed comprehensive information about  all agency cybersecurity personnel and the certifications that they held  because of the limited response from employees. NICE Had Not Defined  Appropriate Industry- Recognized Certifications Although the act required agencies to report on the percentage of  personnel who held appropriate industry-recognized certifications as  identified under NICE, NICE had not defined such a list of certifications as  of the agencies’ reporting deadline of December 2016. In August 2017, a  NICE official told us that the organization did not believe it was  appropriate for NICE, which is led by NIST, to identify industry  appropriate certifications because doing so may be perceived as  endorsing certain private certifications over other certifications. Currently,  the NICE website describes an effort under a NICE working group—which  includes representatives from government, academia, and the private  sector—to map industry-recognized certifications to work roles based on  the updated NICE Framework. However, this effort has not yet been  completed. According to NICE officials, the mapping of certifications to  the NICE Framework is expected to be completed by November 2018. In the absence of a defined list of industry-recognized certifications, the  agencies in our review developed their own approaches for determining  the certifications on which they based their assessments. Examples of  agencies’ approaches included: asking that cybersecurity staff provide input on any or all certifications using a list of certifications developed by the DHS National Initiative  for Cybersecurity Careers and Studies, which was referenced in  OPM’s reporting template; using certifications identified in the Department of Defense’s (DOD) Information Assurance Workforce Improvement Program; or having the agency Office of the CIO or cybersecurity workforce- planning workgroup identify certifications to include in the  assessment. Because the baseline assessments were not based on a defined list of  certifications, there is limited assurance that the assessments consistently  or accurately conveyed the extent to which federal cybersecurity  professionals held industry-recognized certifications that are appropriate  for their job functions. Most Agencies Did Not  Require Cybersecurity  Personnel to Hold  Certifications In addition, no government-wide requirement exists for cybersecurity  personnel to hold certifications, and most of the agencies in our review  did not require certifications. Specifically: Although OPM guidance states that agencies may use certifications  as a selective factor for some positions where specific qualifications  are required, no government-wide requirement exists for positions  performing cybersecurity related functions to hold certifications. Most agencies did not require IT or cybersecurity personnel to hold  certifications. Only 6 of the 24 agencies reported that they had  requirements for personnel to hold an industry-recognized  certification, while only one agency—DOD—required certifications for  all cybersecurity positions. As a result, the information collected by most agencies about the  certifications held by agency cybersecurity personnel may be of limited  value for assessing the qualifications and skills of their cybersecurity  workforces. Most CFO Act  Agencies Established  Coding Procedures,  but Six Agencies’  Procedures Only  Partially Addressed  Activities Required by  OPM Almost all of the CFO Act agencies established procedures to identify all  of their civilian positions and assign the appropriate cybersecurity  employment codes to the positions as called for by the act. However, 6  agencies’ procedures did not fully address 1 or more of 7 activities  required by OPM, such as the activities to review all encumbered and  vacant positions and annotate reviewed position descriptions with the  appropriate employment code. Additionally, DOD did not establish  procedures for coding noncivilian cybersecurity positions. By not  developing coding procedures that address all of the required activities in  their procedures, these agencies may not have reasonable assurance  that they will fully realize the benefits of (1) comprehensively identifying  the cybersecurity workforce, and (2) applying the employment codes to  meet the intended goal of defining the workforce and helping to address  critical mission needs. Most Agencies  Established Coding  Procedures as Required  by the Act The act required agencies to establish procedures for identifying  cybersecurity positions and assigning employment codes to each  position. In January 2017, OPM issued a memorandum that required  agencies to establish their coding procedures by April 2017. The  memorandum also required agencies to perform a number of activities to  identify and assign codes to cybersecurity positions. Among others, the  memorandum stated that agencies were to: use the updated cybersecurity coding structure to find the appropriate  cybersecurity employment code(s);  identify encumbered and vacant positions with cybersecurity  functions; have their CIO staff, managers, and human resources (HR) and  classification staff work together to identify cybersecurity positions; annotate reviewed position descriptions with the appropriate  employment code(s); account for the fact that cybersecurity positions will extend beyond the  Information Technology Management 2210 (GS-2210) occupational  series; assign code “000” to positions that do not perform cybersecurity assign up to three employment codes to each position, in the order of  the level of criticality. Most of the agencies in our review had established coding procedures.  Specifically, of the 24 CFO Act agencies, 23 had established procedures.  Fourteen of these 23 agencies established their procedures by April 2017  as OPM required, while the remaining 9 agencies established their  procedures by March 2018. Officials from the 9 agencies that did not complete their procedures by  April 2017 gave several reasons for their late development or completion  of the procedures. For example: General Services Administration officials said that the procedures  were delayed due to their internal review processes. DOD officials said that the procedures were delayed because of the  size and complexity of the processes required to identify and code the  large number of civilian cybersecurity positions across the  department, and because of the length and complexity of the  department’s policy review processes. In October 2017, an official in DHS’s Office of the Chief Human  Capital Officer stated that the department did not plan to develop  procedures until the National Finance Center (NFC) payroll systems  were updated to accept the 3-digit cybersecurity codes. The NFC  systems were updated to accept the new codes in December 2017,  and DHS issued its procedures in March 2018. One agency—the Department of Energy—had not established coding  procedures: An official in the Department of Energy’s Office of the Chief Human  Capital Officer stated that, because responsibility for IT is not  centralized under the department-level CIO organization (but rather, is  distributed throughout the component agencies), the official had not  determined who had the authority to issue coding procedures for the  entire department. By not establishing coding procedures, the  Department of Energy faces increased risk that it will not fully identify  its cybersecurity workforce or assign the appropriate employment  codes to each position, limiting its ability to identify cybersecurity skills  gaps or work roles of critical need. Agency Procedures Did  Not Always Address  Required Coding Activities The agencies that developed coding procedures generally, but did not  always, address the seven required activities that we reviewed in their  procedures. Specifically, 17 of the 23 agencies that developed  procedures addressed all 7 activities in their procedures, while the  remaining 6 agencies partially addressed or did not address 1 or more of  the 7 activities. Table 4 describes the extent to which agency procedures  addressed the activities required by OPM. The six agencies that did not address all activities required by OPM cited  a variety of reasons for not including them in their coding procedures. For  example: An official in the Department of Education’s Office of Human  Resources explained that it was not necessary for the coding  procedures that were provided to each component to address  assigning code “000” to noncybersecurity positions because the Office  of Human Resources would assign the “000” code to any position that  did not have an assigned code. An official from the National Science Foundation’s Division of Human  Resources Management stated that not addressing all activities may  have been an oversight by the agency. Officials in NASA’s Office of Human Capital Management and its  Office of the CIO said they felt that it was unnecessary to address  assigning code “000” to noncybersecurity positions in the agency’s  coding procedures because the agencies’ existing guidance for  assigning the old 2-digit codes specified that such positions should be  coded with “00.” By not addressing all of the activities required by OPM in their  procedures, these 6 agencies lack assurance that the activities will be  performed or performed consistently throughout their organizations. DOD Did Not Establish  Coding Procedures for  Noncivilian Cybersecurity  Positions In addition to developing procedures for civilian positions, the act required  DOD to establish government-wide procedures for identifying and  assigning employment codes to noncivilian (i.e., military) positions with  cybersecurity job functions by June 2017. The act also required DOD to  establish its internal departmental procedures for military positions by  September 30, 2017. According to officials in the department’s Office of the CIO and Office of  the Chief Human Capital Officer, the only military personnel not currently  within DOD are in the Coast Guard (which resides within DHS).  Therefore, the department planned to fulfill its requirements to establish  government-wide procedures and internal departmental procedures for  identifying and coding military positions by establishing a single  consolidated procedure. The officials added that the consolidated  procedure is to include procedures for DHS to implement the coding  structure for uniformed Coast Guard personnel along with the internal  DOD procedures. However, as of February 2018, DOD had not finalized its consolidated  coding procedures. An official in the department’s Office of the CIO in  February 2018 stated that, because the military services use multiple  Human Resources systems that all have to be updated to accommodate  the cybersecurity employment codes, the office was working with each of  the military services on guidance to meet the act’s deadlines while the  services develop implementation plans for updating their human  resources systems. Until DOD establishes both government-wide and  DOD-specific procedures for identifying and coding noncivilian  cybersecurity positions, increased risk exists that DOD and DHS will not  be able to identify and code all positions in their noncivilian cybersecurity  workforce, limiting the departments’ ability to identify cybersecurity skills  gaps or work roles of critical need in their noncivilian cybersecurity  workforce. Conclusions To implement the objectives of the Federal Cybersecurity Workforce  Assessment Act of 2015, OPM and NIST, although delayed, have revised  the coding structure and cybersecurity workforce framework, and  developed coding procedures to support the identification and assignment  of codes to federal cybersecurity positions. In addition, most CFO Act  agencies have developed baseline assessments to identify cybersecurity  personnel within their agencies that held certifications. Having information  on the certifications held by cybersecurity employees can be a useful  indicator of the skills and knowledge of an agency’s cybersecurity  workforce. However, because agencies have not consistently defined the  workforce and NICE had not developed a list of appropriate certifications,  efforts such as conducting the baseline assessment to determine the  percentage of cybersecurity personnel that hold appropriate certifications  have yielded inconsistent and potentially unreliable results. By not  conducting assessments or including all required information in the  assessments, some of these agencies may lack valuable information that  could help them identify the certification and training needs of their  cybersecurity employees that are charged with protecting federal  information and information systems from cyberattacks. Lastly, while most CFO agencies have developed procedures for  assigning cybersecurity codes to positions, several agencies did not  address activities required by OPM. Unless those agencies address all of  the activities, they may not have reasonable assurance that they are  comprehensively identifying the cybersecurity workforce and applying the  correct employment codes. As such, increased risk exists that the federal  government will not meet its intended goal to define the cybersecurity  workforce and address the critical mission needs for a qualified  cybersecurity workforce. Recommendations for  Executive Action We are making a total of 30 recommendations to 13 agencies in our  review to develop and submit their baseline assessments and to fully  address the required activities in OPM’s guidance in their procedures for  assigning employment codes to cybersecurity positions. Specifically:  The Secretary of Commerce should evaluate the level of preparedness  for cybersecurity personnel not currently holding certifications to take  certification exams, identify strategies for mitigating any gaps identified,  and report this information to Congress. (Recommendation 1) The Secretary of Defense should develop, document, and implement  government-wide procedures for identifying IT, cybersecurity, and cyber- related noncivilian positions and assigning employment codes to those  positions. (Recommendation 2) The Secretary of Defense should develop, document, and implement  internal departmental procedures for identifying IT, cybersecurity, and  cyber-related noncivilian positions and assigning employment codes to  those positions. (Recommendation 3) The Secretary of Education should include requirements to assign code  “000” to positions that do not perform IT, cybersecurity, and cyber-related  functions in departmental procedures. (Recommendation 4) The Secretary of Energy should evaluate the level of preparedness for  cybersecurity personnel not currently holding certifications to take  certification exams and report this information to Congress.  (Recommendation 5) The Secretary of Energy should develop, document, and implement  departmental procedures for identifying IT, cybersecurity, and cyber- related positions and assigning employment codes to those positions,  taking into account the key elements described in OPM’s instructions for  agencies’ procedures. (Recommendation 6) The Secretary of Homeland Security should conduct a baseline  assessment of the department’s cybersecurity workforce that includes (1)  the percentage of personnel with IT, cybersecurity, or other cyber-related  job functions who hold certifications; (2) the level of preparedness of other  cyber personnel without existing credentials to take certification exams;  and (3) a strategy for mitigating any gaps identified with appropriate  training and certification for existing personnel. (Recommendation 7) The Secretary of Homeland Security should submit a report of the  department’s baseline assessment of its existing cybersecurity workforce  to the appropriate congressional committees of jurisdiction.  (Recommendation 8) The Secretary of Housing and Urban Development should conduct a  baseline assessment of the department’s cybersecurity workforce that  includes (1) the percentage of personnel with IT, cybersecurity, or other  cyber-related job functions who hold certifications; (2) the level of  preparedness of other cyber personnel without existing credentials to take  certification exams; and (3) a strategy for mitigating any gaps identified  with appropriate training and certification for existing personnel.  (Recommendation 9) The Secretary of Housing and Urban Development should submit a report  of the department’s baseline assessment of its existing cybersecurity  workforce to the appropriate congressional committees of jurisdiction.  (Recommendation 10) The Secretary of the Interior should evaluate the level of preparedness for  cybersecurity personnel not currently holding certifications to take  certification exams and report this information to Congress.  (Recommendation 11) The Secretary of Labor should include requirements to annotate reviewed  position descriptions with the appropriate cybersecurity data standard  code(s) in departmental procedures. (Recommendation 12) The Secretary of Labor should ensure that departmental procedures fully  account for the fact that IT, cybersecurity, and cyber-related positions will  extend beyond the Information Technology Management 2210  occupational series. (Recommendation 13) The Secretary of Labor should fully clarify requirements to assign code  “000” to positions that do not perform IT, cybersecurity, and cyber-related  functions in departmental procedures. (Recommendation 14) The Secretary of Labor should include requirements to assign up to three  employment codes per position in order of their criticality in departmental  procedures. (Recommendation 15) The Administrator of the National Aeronautics and Space Administration  should evaluate the level of preparedness for cybersecurity personnel not  currently holding certifications to take certification exams and report this  information to Congress. (Recommendation 16) The Administrator of the National Aeronautics and Space Administration  should include requirements to assign code “000” to positions that do not  perform IT, cybersecurity, and cyber-related functions in agency  procedures. (Recommendation 17) The Director of the National Science Foundation should fully clarify  requirements to review all encumbered and vacant positions performing  IT, cybersecurity, and cyber-related functions in agency procedures.  (Recommendation 18) The Director of the National Science Foundation should include  requirements to annotate reviewed position descriptions with the  appropriate cybersecurity data standard code(s) in agency procedures.  (Recommendation 19) The Director of the National Science Foundation should ensure that  agency procedures account for the fact that IT, cybersecurity, and cyber- related positions will extend beyond the Information Technology  Management 2210 occupational series. (Recommendation 20) The Director of the National Science Foundation should include  requirements to assign code “000” to positions that do not perform IT,  cybersecurity, and cyber-related functions in agency procedures.  (Recommendation 21) The Director of the National Science Foundation should include  requirements to assign up to three employment codes per position in  order of their criticality in agency procedures. (Recommendation 22) The Chairman of the Nuclear Regulatory Commission should ensure that  agency procedures account for the fact that IT, cybersecurity, and cyber- related positions will extend beyond the Information Technology  Management 2210 occupational series. (Recommendation 23) The Chairman of the Nuclear Regulatory Commission should fully clarify  requirements to assign up to three employment codes per position in  order of their criticality in agency procedures. (Recommendation 24) The Administrator of the Small Business Administration should conduct a  baseline assessment of the department’s cybersecurity workforce that  includes (1) the percentage of personnel with IT, cybersecurity, or other  cyber-related job functions who hold certifications; (2) the level of  preparedness of other cyber personnel without existing credentials to take  certification exams; and (3) a strategy for mitigating any gaps identified  with appropriate training and certification for existing personnel.  (Recommendation 25) The Administrator of the Small Business Administration should submit a  report of its baseline assessment of its existing cybersecurity workforce to  the appropriate congressional committees of jurisdiction.  (Recommendation 26) The Administrator of the U.S. Agency for International Development  should fully clarify requirements to review all encumbered and vacant  positions performing IT, cybersecurity, and cyber-related functions in  agency procedures. (Recommendation 27) The Administrator of the U.S. Agency for International Development  should fully clarify requirements to annotate reviewed position  descriptions with the appropriate cybersecurity data standard code(s) in  agency procedures. (Recommendation 28) The Administrator of the U.S. Agency for International Development  should include requirements to assign code “000” to positions that do not  perform IT, cybersecurity, and cyber-related functions in agency  procedures. (Recommendation 29) The Administrator of the U.S. Agency for International Development  should include requirements to assign up to three employment codes per  position in order of their criticality in agency procedures.  (Recommendation 30) Agency Comments  and Our Evaluation We provided a draft of this report to the 24 CFO Act agencies for their  review and comment. Of the 13 agencies to which we made  recommendations, 7 agencies stated that they agreed with all of the  recommendations directed to them; 1 agency agreed with one and did not  agree with one recommendation; 2 agencies provided comments but did  not state whether they agreed or disagreed with the recommendations; 2  agencies stated that they had no comments; and 1 agency—DOD—did  not respond to our request for comments on the report. In addition, of the 11 agencies to which we did not make  recommendations, 2 provided comments on the report and 9 responded  that they had no comments on the report. We also received technical  comments from 2 agencies, which we have incorporated into the report  as appropriate. The following seven agencies agreed with our recommendations:  In its written comments (reprinted in appendix II), the Department of  Commerce agreed with our recommendation. The department stated  that it will evaluate the level of preparedness for cybersecurity  personnel who do not hold certifications to take certification exams,  identify strategies for mitigating any gaps identified, and report this  information to Congress. In its written comments (reprinted in appendix III), the Department of  Education agreed with our recommendation. The department stated  that it had updated its coding guidance to require that positions that  do not perform substantial work in information technology,  cybersecurity, or cyber-related functions be assigned a code of “000.” In its written comments (reprinted in appendix IV), the Department of  Energy agreed with our recommendations and stated that it has  planned, or taken steps to address them. Specifically, with regard to  our recommendation concerning cybersecurity certification, the  department stated that it plans to conduct a department-wide  evaluation of the level of preparedness for its cybersecurity personnel  without existing credentials to take certification exams and will report  the information to Congress. In addition, the department stated that it had developed and issued  procedures for identifying and coding IT, cybersecurity, and cyber- related positions, as we recommended, and that it had since  completed its coding of applicable positions across the department.  The department also provided us its updated coding procedures,  along with its written comments. In its written comments (reprinted in appendix V), the Department of  Homeland Security agreed with our recommendations. Regarding the  recommendation to conduct a baseline assessment of its  cybersecurity workforce, the department stated that it is taking steps  to collect data about certifications relevant to DHS cybersecurity work.  The department also stated that it plans to identify the percentage of  its cybersecurity workforce that holds certifications, the percentage  prepared to take a relevant certification exam, and strategies for  mitigating any gaps. The department added that it plans to provide  this information to Congress, as we recommended. The department  also provided technical comments, which we have incorporated into  this report as appropriate. In its written comments (reprinted in appendix VI), the Department of  the Interior stated that it agreed with our recommendation. The  department also indicated that it is exploring options to determine the  extent to which its cybersecurity employees who currently do not hold  certifications are prepared to take certification exams. In its written comments (reprinted in appendix VII), the Small Business  Administration agreed with our recommendations. The agency also  stated that it had recently completed an assessment of its IT  workforce and reported on existing skills gaps, and that it plans to  execute its IT workforce plan to address the requirements of the  Federal Cybersecurity Workforce Assessment Act of 2015. In comments on a draft of this report provided via email on May 15,  2018, a Program Analyst in the National Science Foundation’s Office  of Integrative Activities stated that the agency concurred with our  recommendations. One agency did not agree with one of the two recommendations directed  to it:  In its written comments (reprinted in appendix VIII), the National  Aeronautics and Space Administration did not agree with our first  recommendation and agreed with the second. Specifically: NASA did not concur with our recommendation to evaluate the  level of preparedness for cybersecurity personnel not currently  holding certifications to take certification exams and report this  information to Congress. The agency stated that there is no  federal or NASA requirement for employees in cybersecurity  positions to hold and/or maintain a certification, and therefore the  agency has no plans to assess the readiness of its cybersecurity  personnel to take certification exams. Nonetheless, we continue to believe our recommendation remains  valid because the level of preparedness of personnel without  certifications to take certification examinations can be a useful  indicator of the skills and knowledge of an agency’s cybersecurity  workforce. In addition, this information could help the agency  identify and meet the certification and training needs of its  cybersecurity employees who are charged with protecting NASA’s  information and information systems from cyberattacks. Moreover,  the act contains provisions that demonstrate congressional  interest in assessing agency use of professional certifications. NASA concurred with our recommendation to include in the  agency’s coding procedures, requirements to assign code “000” to  positions that do not perform IT, cybersecurity, and cyber-related  functions. The agency stated that it planned to update its  procedures to include this requirement, and indicated that  supervisors and human resource specialists had been trained to  assign cybersecurity codes to all positions, including code “000.” The following two agencies provided comments, but did not state whether  they agreed or disagreed with our recommendations:  In its written comments (reprinted in appendix IX), the Nuclear  Regulatory Commission stated that it was in general agreement with  the overall content of the draft report. However, the agency asked that  we revise the final report to reflect that the Nuclear Regulatory  Commission had updated its cybersecurity coding procedures to  include language explaining that IT, cybersecurity, and cyber-related  positions will extend beyond the GS-2210 occupational series, and to  outline the requirement that positions can be assigned up to three  different employment codes in order of criticality. The agency provided  its updated coding procedures along with its written comments. In its written comments (reprinted in appendix X), the U.S. Agency for  International Development stated that it had completed various  actions related to coding its cybersecurity positions which addressed  our four recommendations. For example, among other actions, the  agency said it had updated its plan for coding cybersecurity positions  to include procedures for assigning codes for multiple functional  areas, with the predominant functional area being coded first. In addition, two agencies to which we made recommendations---the  Departments of Housing and Urban Development and Labor—stated via  email that they did not have comments on the report. The agencies did  not state whether they agreed or disagreed with our recommendations. Of the agencies to which we did not make recommendations, the Social  Security Administration also provided a letter acknowledging its review of  the report. The agency’s letter is reprinted in appendix XI. The remaining nine agencies to which we did not make  recommendations—the Departments of Agriculture, Health and Human  Services, Justice, State, Transportation, and Treasury; the Environmental  Protection Agency; the General Services Administration; and the Office of  Personnel Management—stated that they did not have any comments on  our report. We are sending copies of this report to interested congressional  committees, the Director of the Office of Management and Budget, the  secretaries and agency heads of the departments and agencies  addressed in this report, and other interested parties. In addition, this  report will be available at no charge on the GAO website at  http://www.gao.gov. If you have any questions regarding this report, please contact me at  (202) 512-6244 or wilshuseng@gao.gov. Contact points for our Offices of  Congressional Relations and Public Affairs may be found on the last page  of this report. Key contributors to this report are listed in appendix XII. Appendix I: Objectives, Scope, and  Methodology Our objectives were to determine whether (1) OPM developed a coding  structure and procedures for assigning codes to cybersecurity positions  and submitted a progress report to Congress, (2) Chief Financial Officers  (CFO) Act agencies submitted complete and reliable baseline  assessment reports of their cybersecurity workforces, and (3) CFO Act  agencies established procedures to identify and assign codes to  cybersecurity positions. The scope of our review included the 24 departments and agencies  (hereafter referred to as agencies) covered by the Chief Financial Officers  Act of 1990. It also included OPM, DOD, DHS, and NIST in their roles  related to the development of a cybersecurity coding structure and related  guidance. Our work focused on the agencies’ cybersecurity positions and  on workforce planning actions that the act required the agencies to  complete by November 2017. To address the first objective, we obtained and compared OPM’s federal  cybersecurity employment coding structure, issued in November 2016, to  the work roles described in the National Initiative for Cybersecurity  Education (NICE) Cybersecurity Workforce Framework, issued in draft  form by NIST in November 2016. We also examined OPM  memorandums to identify if and when OPM had issued procedures to  agencies for identifying cybersecurity positions and assigning  employment codes. Additionally, we reviewed any progress reports  submitted by OPM to Congress on the implementation of the act. We  compared the issuance date of each of these documents to the deadlines  by which OPM was to issue them, as established in the act. Also, we  interviewed OPM and NIST officials about their efforts to develop these  documents and the reasons for any delays. To address the second objective, we obtained available baseline  assessments from each of the 24 CFO Act agencies and evaluated them  against the act’s requirements to include information on (1) cybersecurity  personnel holding certifications, (2) the level of preparedness of other  personnel to take certification exams, and (3) strategies for mitigating any  gaps identified. We also obtained agencies’ letters transmitting their  assessments to the relevant congressional committees and evaluated  them against the reporting deadline established in OPM guidance. In  addition, we analyzed other relevant agency documentation and  interviewed cognizant agency officials about their efforts to identify the  appropriate certifications, identify relevant personnel, and collect  information on employee certifications. We obtained the officials’ views on  the reasons for any delays in agencies’ submissions of the assessments  and the reliability of assessment results. To address the third objective, we obtained and analyzed available  cybersecurity coding procedures established by each of the 24 CFO Act  agencies. We reviewed the required coding activities described in OPM’s  Guidance for Assigning New Cybersecurity Codes to Positions with  Information Technology, Cybersecurity, and Cyber-Related Functions.  We judgementally selected seven of the activities that we determined to  be particularly important for effectively identifying and coding all relevant  encumbered and vacant cybersecurity positions. We then evaluated each  agency’s procedures against these seven required coding activities. We  also compared the issuance date of the procedures to the deadline  established in OPM’s coding guidance for agencies to issue the  procedures. In addition, we interviewed agency officials about their efforts  to complete the procedures by the required deadline and the reasons for  any delays. Further, the Federal Cybersecurity Workforce Assessment Act of 2015  established a separate requirement and deadline for DOD to develop  government-wide procedures for implementing the coding structure for  federal noncivilian cyber positions. As such, we reviewed relevant  documentation and interviewed cognizant officials from the Department of  Defense’s Office of the Chief Information Officer and Office of the Under  Secretary for Personnel and Readiness about their efforts to establish  coding procedures for both civilian and noncivilian positions by the  deadlines set forth in the act. We conducted this performance audit from October 2016 to June 2018 in  accordance with 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. Appendix II: Comments from the Department  of Commerce Appendix III: Comments from the  Department of Education Appendix IV: Comments from the  Department of Energy Appendix V: Comments from the Department  of Homeland Security Appendix VI: Comments from the  Department of the Interior Appendix VII: Comments from the Small  Business Administration Appendix VIII: Comments from National  Aeronautics and Space Administration Appendix IX: Comments from the Nuclear  Regulatory Commission Appendix X: Comments from the United  States Agency for International Development Appendix XI: Comments from the Social  Security Administration Appendix XII: GAO Contact and Staff  Acknowledgments GAO Contact Staff  Acknowledgments In addition to the individual named above, Nick Marinos (director), Tammi  Kalugdan (assistant director), William Cook (analyst in charge), Chris  Businsky, Virginia Chanley, Wayne Emilien, Lisa Maine, David Plocher,  Priscilla Smith, Dwayne Staten, Daniel Wexler, and Merry Woo made  significant contributions to this report.
A key component of mitigating and responding to cyber threats is having a qualified, well-trained cybersecurity workforce. The Federal Cybersecurity Workforce Assessment Act of 2015 requires OPM and federal agencies to take several actions related to cybersecurity workforce planning. GAO is to monitor agencies' progress in implementing the act's requirements. For this report, GAO assessed whether: (1) OPM developed a coding structure and procedures for assigning codes to cybersecurity positions and submitted a progress report to Congress; (2) CFO Act agencies submitted complete, reliable baseline assessments of their cybersecurity workforces; and (3) CFO Act agencies established procedures to assign codes to cybersecurity positions. GAO examined OPM's coding procedures and progress report on the act's implementation, and baseline assessments and coding procedures from the 24 CFO Act agencies. GAO also interviewed relevant OPM and agency officials about efforts to address the act's requirements. As required by the Federal Cybersecurity Workforce Assessment Act of 2015 (act), the Office of Personnel Management (OPM) developed a cybersecurity coding structure under the National Initiative for Cybersecurity Education (NICE) as well as procedures for assigning codes to federal civilian cybersecurity positions. However, OPM issued the coding structure and procedures 5 and 4 months later than the act's deadlines because OPM was working with the National Institute of Standards and Technology (NIST) to align the structure and procedures with the draft NICE Cybersecurity Workforce Framework , which NIST issued later than planned. OPM also submitted a progress report to Congress on the implementation of the act 1 month after it was due. The delays in issuing the coding structure and procedures have extended the expected time frames for implementing subsequent provisions of the act. Most of the 24 agencies covered by the Chief Financial Officers (CFO) Act submitted baseline assessment reports to Congress but the results may not be reliable. As of March 2018, 21 of the 24 CFO Act agencies had conducted baseline assessments identifying the extent to which their cybersecurity employees held professional certifications and had submitted the assessment reports to Congress as required by the act. Three agencies had not conducted the assessments for various reasons, such as a lack of resources and tools to do so. Of the 21 agencies that did, 4 did not address all of the reportable information, such as the extent to which personnel without professional certifications were ready to obtain them or strategies for mitigating any gaps. Additionally, agencies were limited in their ability to obtain complete or consistent information about their cybersecurity employees and the certifications they held. This was because agencies had not yet fully identified all members of their cybersecurity workforces or did not have a consistent list of appropriate certifications for cybersecurity positions. As a result, the agencies had limited assurance that their assessment results accurately reflected all relevant employees or the extent to which those employees held appropriate certifications. This diminishes the usefulness of the assessments in determining the certification and training needs of these agencies' cybersecurity employees. Most of the 24 CFO Act agencies established coding procedures, but 6 agencies only partially addressed certain activities required by OPM in their procedures. Of the 24 agencies reviewed, 23 had established procedures to identify their civilian cybersecurity positions and assign the appropriate employment codes to the positions as called for by the act. However, 6 of the 23 agencies did not address one or more of 7 activities required by OPM in their procedures, such as the activities to review all filled and vacant positions and annotate reviewed position descriptions with the appropriate employment code. These 6 agencies cited a variety of reasons for not addressing all of the required activities in their coding procedures. For example, these agencies stated that they addressed the activities in existing guidance or did not include activities that their components did not have the responsibility to perform. By not addressing all of the required activities in their coding procedures, the 6 agencies lack assurance that the activities will be performed or performed consistently throughout their agency.