Abstract
Abstract—Federal and regulated organizations continue to rely on document-centric Authorization to Operate (ATO) processes even as the NIST Risk Management Framework (RMF), continuous monitoring guidance, Zero Trust Architecture (ZTA), and continuous authorization initiatives require more continuous, evidence-driven risk management [1]-[3], [13], [15]. Manual System Security Plan (SSP) updates, spreadsheet-based Plan of Action and Milestones (POA&M) tracking, and disconnected assessment evidence create governance latency: the delay between operational security events and authorization-ready governance response. This paper presents OpenGRCRMF, a proposed open, vendor-neutral reference framework that models RMF lifecycle activities as workflow states, treats authorization artifacts as structured governance objects, and maps DevSecOps and Zero Trust telemetry into authorization-relevant evidence. Using Design Science Research, the study develops the OpenGRCRMF architecture, formalizes its data and risk model, and evaluates expected governance effects through a synthetic simulation of 1,500 findings across 180 assets and 320 controls [9]. OpenGRCRMF is evaluated as a reference framework rather than a production platform using a self-contained simulation specification and sensitivity analysis. In the simulation, the OpenGRCRMF-enabled workflow reduced modeled governance processing time by 36.8 percent, increased modeled evidence completeness by 41.5 percent, and increased modeled control-to-evidence traceability by 52.7 percent compared with a document-centric baseline. These results are modeled outcomes under stated assumptions, not production deployment proof. The paper contributes a governance object model, governance latency construct, reproducibility-oriented simulation design, threat-to-validity analysis, and education-oriented framework for teaching how operational telemetry becomes authorization evidence.
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