Authority to Operate (ATO)

What the company delivers

APS Global LLC delivers gap analysis for systems that need an Authority to Operate. The Authorizing Official issues the ATO. APS Global finds what is covered, inherited, or missing and returns a defensible gap list and draft POA&M support to the ISSO and AO staff.

LLUCE is a compare-and-contrast assistant for existing artifacts. The assessment cell—FedRAMP (federal and HHS), enterprise architecture, and AI-assisted mapping—reviews findings. Certified staff retain professional judgment on the gap analysis. The tool does not sign a package.

Current cell capacity is four to five gap analyses in parallel per day. If the customer installs LLUCE on-premises, that throughput moves to the customer’s own authorization staff.

Federal Validation — DISA ATO Accelerator Pilot

In 2024–2025 APS Global conducted a formal ATO Accelerator Pilot with the Defense Information Systems Agency (DISA) Emerging Technology and Risk Management Directorates. The pilot was performed at the Capitol Technology University Tech Hub at no cost to the government.

Using a decommissioned DISA system and more than 300 historical compliance documents, the pilot demonstrated LLUCE’s ability to complete a full NIST SP 800-53 Revision 4 to Revision 5 gap analysis and associated POA&Ms in five business days — significantly faster than traditional RMF timelines. DISA Risk Management personnel reviewed the deliverables and noted the potential for cleaner ATO package submissions that can reduce review time.

Key Capabilities

• Gap analysis for DoD RMF and NIST SP 800-53 / 800-171 packages
• Control mapping and first-cut POA&M support
• Evidence compare-and-contrast across inherited and local controls
• Assessment cell review; certified staff own the findings
• Multi-vendor and system-of-systems package mapping
• On-prem or air-gapped analysis so CUI stays in the customer boundary

LLUCE assists the pass. APS Global does not replace the SCA or the Authorizing Official.