Information Security: Continued Efforts Needed to Fully Implement
Statutory Requirements (24-JUN-03, GAO-03-852T).		 
                                                                 
Since 1996, GAO has reported that poor information security in	 
the federal government is a widespread problem with potentially  
devastating consequences. Further, GAO has identified information
security as a governmentwide high-risk issue in reports to the	 
Congress since 1997--most recently in January 2003. To strengthen
information security practices throughout the federal government,
information security legislation has been enacted. This testimony
discusses efforts by federal departments and the administration  
to implement information security requirements mandated by law.  
In so doing, it examines overall information security weaknesses 
and challenges that the government faces, and the status of	 
actions to address them, as reported by the Office of Management 
and Budget (OMB). GAO's evaluation of agency efforts to implement
federal information security requirements and correct identified 
weaknesses. New requirements mandated by the Federal Information 
Security Management Act of 2002 (FISMA).			 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-03-852T					        
    ACCNO:   A07355						        
  TITLE:     Information Security: Continued Efforts Needed to Fully  
Implement Statutory Requirements				 
     DATE:   06/24/2003 
  SUBJECT:   Computer security					 
	     Information resources management			 
	     Information systems				 
	     Information technology				 
	     Internal controls					 
	     Performance measures				 
	     Strategic planning 				 

******************************************************************
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GAO-03-852T

Testimony Before the Subcommittee on Technology, Information Policy,
Intergovernmental Relations and the Census, House Committee on Government
Reform

United States General Accounting Office

GAO For Release on Delivery Expected at 10: 00 a. m. EDT Tuesday, June 24,
2003 INFORMATION SECURITY

Continued Efforts Needed to Fully Implement Statutory Requirements

Statement of Robert F. Dacey Director, Information Security Issues

GAO- 03- 852T

Based on the fiscal year 2002 reports submitted to OMB, the federal
government has made limited overall progress in implementing statutory
information security requirements, although a number of benefits have
resulted. Among these benefits are several actions taken and planned to
address governmentwide information security weaknesses and challenges,
such as lack of senior management attention. Nevertheless, as indicated by
selected quantitative performance measures for the largest federal
agencies, progress has been limited. Specifically, excluding data for one
agency that were not comparable for fiscal years 2001 and 2002,
improvements for 23 agencies ranged from 3 to 10 percentage points for the
selected measures (see figure). GAO*s analyses of agencies* reports and
evaluations confirmed that many

agencies have not implemented security requirements for most of their
systems, such as performing risk assessments and testing controls.
Further, the usefulness of agency corrective action plans may be limited
when they do not identify all weaknesses or contain realistic completion
dates. Agencies also continue to face challenges in effectively
implementing and managing their overall information security programs.

FISMA provisions establish additional requirements that, among other
things, can assist agencies in implementing effective information security
programs. However, attaining significant and sustainable results in

implementing such requirements will also likely require processes that
prioritize and routinely monitor and manage agency efforts, as well as
continued congressional and administration oversight.

Performance Measure Percentages for Selected Information Security
Requirements a a Excludes National Aeronautics and Space Administration
data.

Since 1996, GAO has reported that poor information security in the federal
government is a widespread problem with potentially devastating
consequences. Further, GAO has identified information security as a
governmentwide highrisk issue in reports to the Congress since 1997* most
recently in January 2003. To strengthen information security

practices throughout the federal government, information security
legislation has been enacted.

This testimony discusses efforts by federal departments and the
administration to implement

information security requirements mandated by law. In so doing, it
examines  overall information security

weaknesses and challenges that the government faces, and the status of
actions to address them, as reported by the Office of Management and
Budget (OMB);  GAO*s evaluation of agency efforts to implement federal

information security requirements and correct identified weaknesses; and 
new requirements mandated by the Federal Information Security Management
Act of 2002 (FISMA).

www. gao. gov/ cgi- bin/ getrpt? GAO- 03- 852T. To view the full product,
including the scope and methodology, click on the link above. For more
information, contact Robert F. Dacey at (202) 512- 3317 or daceyr@ gao.
gov. Highlights of GAO- 03- 852T, testimony

before the Subcommittee on Technology, Information Policy,
Intergovernmental Relations and the Census, House Committee on Government
Reform

June 24, 2003

INFORMATION SECURITY

Continued Efforts Needed to Fully Implement Statutory Requirements

Page 1 GAO- 03- 852T Implementing Security Requirements

Mr. Chairman and Members of the Subcommittee: I am pleased to be here
today to discuss efforts by federal departments and agencies and the
administration to implement statutory information security requirements.
Since 1996, 1 we have reported that poor information security in the
federal government is a widespread problem with potentially devastating
consequences. Further, we have identified

information security as a governmentwide high- risk issue in reports to
the Congress since 1997* most recently in January 2003. 2 Concerned with
accounts of attacks on commercial systems via the Internet and reports of
significant weaknesses in federal computer systems that make them
vulnerable to attack, in October 2000 the Congress passed and the

President signed into law Government Information Security Reform
provisions (commonly known as GISRA) to strengthen information security
practices throughout the federal government. 3 GISRA established
information security program, evaluation, and reporting requirements for
federal agencies, which are now permanently authorized and strengthened
through the recently enacted Federal Information Security Management Act
of 2002 (FISMA). 4 In my testimony today, I will first summarize the
federal government*s

overall information security weaknesses and challenges, as well as the
status of the administration*s efforts to address them as discussed in the
May 2003 Office of Management and Budget (OMB) report to the Congress on
fiscal year 2002 GISRA implementation. 5 I will also discuss the results
of our evaluation of efforts by OMB and 24 of the largest federal agencies
to implement federal information security requirements and correct

identified weaknesses. Finally, I will describe new information security 1
U. S. General Accounting Office, Information Security: Opportunities for
Improved OMB Oversight of Agency Practices, GAO/ AIMD- 96- 110
(Washington, D. C.: Sept. 24, 1996). 2 U. S. General Accounting Office,
High Risk Series: Protecting Information Systems Supporting the Federal
Government and the Nation*s Critical Infrastructures,

GAO- 03- 121 (Washington, D. C.: January 2003). 3 Government Information
Security Reform, Title X, Subtitle G, Floyd D. Spence National Defense
Authorization Act for Fiscal Year 2001, P. L. 106- 398, October 30, 2000.
4 Federal Information Security Management Act of 2002, Title III, E-
Government Act of

2002, P. L. 107- 347, December 17, 2002. This act superseded an earlier
version of FISMA that was enacted as Title X of the Homeland Security Act
of 2002. 5 Office of Management and Budget, FY 2002 Report to Congress on
Federal Government Information Security Reform., May 16, 2003.

Page 2 GAO- 03- 852T Implementing Security Requirements

requirements contained in FISMA that can assist agencies in implementing
effective information security.

In conducting this review, we analyzed OMB*s May 2003 report to the
Congress on GISRA implementation. We also compared the results of OMB*s
report with the results of our analyses of fiscal year 2002 GISRA
reporting by 24 of the largest federal agencies and their inspectors
general (IGs), which we had previously reported in testimony before your

subcommittee in April 2003. 6 We did not validate the accuracy of the data
reported by OMB or by the agencies. We also analyzed the provisions of
FISMA. We performed our work in June 2003, in accordance with generally
accepted government auditing standards.

In its fiscal year 2002 report to the Congress, OMB reported that the
federal government had made significant strides in addressing serious and
pervasive information technology (IT) security problems, but that much
work remained. It highlighted actions and progress to address previously
identified governmentwide weaknesses, such as lack of senior management
attention to information security, as well as planned actions to address
newly- reported challenges, such as agencies continuing to

identify the same security weaknesses year after year. OMB also reported
significant progress in agencies* IT security performance as indicated by
the quantitative performance measures that OMB required agencies to

report beginning in fiscal year 2002. These measures include the number of
systems that have been assessed for risk, have an up- to- date security
plan, and for which security controls have been tested. In particular, for
selected performance measures for 24 large federal agencies, OMB*s report
showed increases from fiscal year 2001 to fiscal year 2002 ranging from 18
to 27 percentage points.

Although our review of GISRA implementation also showed a number of
benefits resulting from this legislation, our analyses of governmentwide
performance measures showed more limited overall progress. Excluding one
of the 24 agencies because its performance data for these fiscal years was
not comparable, our analyses showed that increases for these measures
ranged from only 3 to 10 percentage points. Further, our

6 U. S. General Accounting Office, Information Security: Progress Made,
But Challenges Remain to Protect Federal Systems and the Nation*s Critical
Infrastructures, GAO03- 546T (Washington, D. C.: Apr. 8, 2003). Results in
Brief

Page 3 GAO- 03- 852T Implementing Security Requirements

analyses of individual agency reports showed that significant challenges
remained in implementing information security requirements. For example,
of the 24 agencies, 11 reported that they had assessed risk for 90 to 100
percent of their systems for fiscal year 2002, but 8 reported that they
had assessed risk for less than 50 percent of their systems.

Developing effective corrective action plans is key to ensuring that
remedial action is taken to address significant deficiencies. However, our
analyses of agencies* OMB- required corrective action plans for fiscal
year 2002, IGs* evaluations of these plans, and available quarterly
updates showed that plan usefulness could be limited when plans do not
identify all weaknesses, provide realistic completion estimates, or
prioritize actions. For example, of 14 agency IGs who reported whether
their agency*s corrective action plan addressed all identified significant
weaknesses, 5 reported that their agency*s plan did and 9 reported that it
did not.

The governmentwide weaknesses identified by OMB, as well as the limited
progress in implementing key information security requirements, continue
to emphasize that, overall, agencies are not effectively implementing and
managing their information security programs. For several years we have

reported that most agencies have significant weaknesses in security
program management and pointed out that agencies should implement a cycle
of risk management activities* activities that are now required by law.
Although agency reporting provides performance information, it is
important for agencies to ensure that they have the appropriate management
structures and processes in place to strategically manage

information security, as well as to ensure the reliability of performance
information. For example, disciplined processes can routinely provide the
agency with timely, useful information for day- to- day management of
information security.

FISMA provisions establish additional requirements that can assist the
agencies in implementing effective information security programs, help
ensure that agency systems incorporate appropriate controls, and provide
information for administration and congressional oversight. These

requirements include the designation of and establishment of specific
responsibilities for an agency senior information security officer,
implementation of minimum information security requirements for agency
information and information systems, and required agency reporting to the
Congress.

Page 4 GAO- 03- 852T Implementing Security Requirements

In addition to continued congressional and administration oversight, we
believe that achieving significant and sustainable results, including the
implementation of new requirements, will require agencies to integrate the
use of techniques, such as corrective action plans and performance
measures, into overall security management programs and processes that
prioritize and routinely monitor and manage their information security
efforts. Development of management strategies that identify specific
actions, time frames, and required resources may also help to
significantly improve performance.

On October 30, 2000, the Congress enacted GISRA, which became effective
November 29, 2000, for a period of 2 years. GISRA supplemented information
security requirements established in the Computer Security Act of 1987,
the Paperwork Reduction Act of 1995, and the Clinger- Cohen Act of 1996,
and was consistent with existing information security

guidance issued by OMB 7 and NIST, 8 as well as audit and best practice
guidance issued by us. 9 GISRA consolidated these separate requirements
and guidance into an

overall framework for managing information security and established new
annual review, independent evaluation, and reporting requirements to help
ensure agency implementation and both OMB and congressional oversight.
GISRA assigned specific responsibilities to OMB, agency heads and chief
information officers (CIOs), and IGs. OMB was responsible for establishing
and overseeing policies, standards, and guidelines for information
security. This included the authority to approve agency information
security programs, but delegated OMB*s responsibilities

regarding national security systems to national security agencies. OMB was
also required to submit an annual report to the Congress summarizing
results of agencies* evaluations of their information security programs.

7 Primarily OMB Circular A- 130, Appendix III, *Security of Federal
Automated Information Resources,* February 1996. 8 Numerous publications
made available at http:// www. itl. nist. gov/ including National
Institute of Standards and Technology, Generally Accepted Principles and
Practices for Securing Information Technology Systems, NIST Special
Publication 800- 14, September

1996. 9 U. S. General Accounting Office, Federal Information System
Controls Manual, Volume 1* Financial Statement Audits, GAO/ AIMD- 12.19.6
(Washington, D. C.: January 1999);

Information Security Management: Learning from Leading Organizations,

GAO/ AIMD- 98- 68 (Washington, D. C.: May 1998). Background

Page 5 GAO- 03- 852T Implementing Security Requirements

OMB released its fiscal year 2001 report in February 2002 10 and its
fiscal year 2002 report in May 2003.

GISRA required each agency, including national security agencies, to
establish an agencywide risk- based information security program to be
overseen by the agency CIO and ensure that information security is
practiced throughout the life cycle of each agency system. Specifically,
this program was to include

 periodic risk assessments that consider internal and external threats to
the integrity, confidentiality, and availability of systems, and to data
supporting critical operations and assets;  the development and
implementation of risk- based, cost- effective policies

and procedures to provide security protections for information collected
or maintained by or for the agency;

 training on security responsibilities for information security personnel
and on security awareness for agency personnel;

 periodic management testing and evaluation of the effectiveness of
policies, procedures, controls, and techniques;

 a process for identifying and remediating any significant deficiencies;
 procedures for detecting, reporting, and responding to security
incidents;

and  an annual program review by agency program officials.

In addition to the responsibilities listed above, GISRA required each
agency to have an annual independent evaluation of its information
security program and practices, including control testing and compliance
assessment. The evaluations of non- national- security systems were to be
performed by the agency IG or an independent evaluator, and the results of
these evaluations were to be reported to OMB. For the evaluation of
national security systems, special provisions included having national
security agencies designate evaluators, restricting the reporting of
evaluation results, and having the IG or an independent evaluator perform
10 Office of Management and Budget, FY 2001 Report to Congress on Federal
Government

Information Security Reform. February 2002.

Page 6 GAO- 03- 852T Implementing Security Requirements

an audit of the independent evaluation. For national security systems,
only the results of each audit of an evaluation were to be reported to
OMB.

For first- year GISRA implementation, OMB provided guidance to the
agencies in January 2001, and in June issued final instructions on
reporting results of annual agency security program reviews and inspector
general

independent evaluations to OMB to provide a basis for its annual report to
the Congress. 11 These instructions listed specific topics that the
agencies were to address in their reporting, many of which were referenced
back to corresponding GISRA requirements. Agencies were to report their
results to OMB in September 2001* the same time they were to submit their
fiscal year 2003 budget materials. In October 2001, OMB also issued
detailed guidance to the agencies on reporting their strategies for
correcting the security weaknesses identified through their reviews,
evaluations, and other reviews or audits performed throughout the
reporting period. 12 This information was to include a *plan of action and
milestones* (corrective action plan) that, among other things, listed the
weaknesses; showed required resources, milestones, and completion dates;
and described how the agency planned to address those weaknesses. The
guidance also required agencies to submit quarterly status updates of
their corrective action plans to OMB. Corrective action plans were due to
OMB by the end of October, and the first quarterly updates were due
January 31, 2002.

For fiscal year 2002, OMB provided the agencies with updated reporting
instructions and guidance on preparing and submitting corrective action
plans. 13 Agencies were again to report their GISRA review and evaluation
results to OMB in September with corrective action plans due October 1,
2002, and the next quarterly update due on January 1, 2003. Although

11 Office of Management and Budget, *Guidance on Implementing the
Government Information Security Reform Act,* Memorandum for the Heads of
Executive Departments and Agencies,* Jack Lew, Director, M- 01- 08,
January 16, 2001; *Reporting Instructions for

the Government Information Security Reform Act,* Memorandum for the Heads
of Executive Departments and Agencies, Mitchell E. Daniels, Jr., Director,
M- 01- 24, June 22, 2001.

12 Office of Management and Budget, *Guidance for Preparing and Submitting
Security Plans of Action and Milestones,* Memorandum for the Heads of
Executive Departments and Agencies, Mitchell E. Daniels, Jr., Director, M-
02- 01, October 17, 2001.

13 Office of Management and Budget, *Reporting Instructions for the
Government Information Security Reform Act and Updated Guidance on
Security Plans of Action and Milestones,* Memorandum for Heads of
Executive Departments and Agencies, Mitchell E. Daniels, Jr., M- 02- 09,
July 2, 2002.

Page 7 GAO- 03- 852T Implementing Security Requirements

similar to its previous guidance, in response to agency requests and
recommendations we made to OMB as a result of our review of fiscal year
2001 GISRA implementation, 14 this guidance also incorporated several
significant changes to help improve the consistency and quality of
information being reported for oversight by OMB and the Congress. These
changes included the following:

 Reporting instructions provided new high- level management performance
measures that the agencies and IGs were required to use to report on
agency officials* performance. These included, for example, the number and
percentage of systems assessed for risk, the number and percentage of
systems certified and accredited, 15 the number of contractor operations
or facilities reviewed, and the number of employees with significant
security responsibilities that received specialized training.  OMB
confirmed that agencies were expected to review all systems

annually. It explained that GISRA requires senior agency program officials
to review each security program for effectiveness at least annually, and
that the purpose of the security programs discussed in GISRA is to ensure
the protection of the systems and data covered by the program. Thus, a
review of each system is essential to determine the program*s
effectiveness, and only the depth and breadth of such system reviews are
flexible.

 Agencies were generally required to use all elements of NIST*s Security
Self- Assessment Guide for Information Technology Systems to review their
systems unless an agency and its IG confirmed that any agency

14 U. S. General Accounting Office, Information Security: Additional
Actions Needed to Fully Implement Reform Legislation, GAO- 02- 407
(Washington, D. C.: May 2, 2002). 15 Accreditation is the authorization of
an IT system to process, store, or transmit information, granted by a
management official that provides a form of quality control and challenges
managers and technical staff to find the best fit for security, given
technical constraints, operational constraints, and mission requirements.
Certification is the comprehensive evaluation of the technical and non-
technical security controls of an IT system to support the accreditation
process that establishes the extent to which a particular design and
implementation meets a set of specified security requirements.
Certification provides the necessary information to a management official
to formally declare that an IT system is approved to operate at an
acceptable level of risk. The accreditation decision is based on the
implementation of an agreed upon set of

management, operational, and technical controls, and by accrediting the
system, the management office accepts the risk associated with it.

Page 8 GAO- 03- 852T Implementing Security Requirements

developed methodology captured all elements of the guide. 16 The guide
uses an extensive questionnaire containing specific control objectives and
techniques against which an unclassified system or group of interconnected
systems can be tested and measured.

 OMB requested that IGs verify that agency corrective action plans
identify all known security weaknesses within an agency, including
components, and are used by the IG and the agency, major components, and
program officials within them, as the authoritative agency management
mechanism to prioritize, track, and manage all agency efforts to close
security

performance gaps.  OMB authorized agencies to release certain information
from their

corrective action plans to assist the Congress in its oversight
responsibilities. Agencies could release this information, as requested,
excluding certain elements, such as estimated funding resources and the
scheduled completion dates for resolving a weakness.

In its fiscal year 2002 report to the Congress, OMB stated that the
federal government had made significant strides in addressing serious and
pervasive IT security problems, but that more needed to be done,
particularly to address both the governmentwide weaknesses identified its
fiscal year 2001 report to the Congress and new challenges. Also, as

discussed in a later section, OMB reported significant progress in
agencies* IT security performance, primarily as indicated by the
quantitative governmentwide performance measures that OMB required
agencies to disclose beginning with their fiscal year 2002 reports.

OMB previously reported six common security weaknesses for the federal
government. Actions and progress for these weaknesses reported by OMB in
its fiscal year 2002 report were as follows:

Lack of senior management attention to information security. OMB reports
that based on agencies* security reviews, remediation efforts, and IT
budget materials, it either conditionally approves or disapproves agency
security programs, and the OMB Director communicates this decision
directly to each agency head. Further, OMB used the President*s Management
Agenda Scorecard to focus attention on serious IT security

16 National Institute of Standards and Technology, Security Self-
Assessment Guide for Information Technology Systems, NIST Special
Publication 800- 26, November 2001. OMB Reports

Significant Progress and Actions to Address Governmentwide Weaknesses

Page 9 GAO- 03- 852T Implementing Security Requirements

weaknesses and, along with senior agency officials, to monitor agency
progress on a quarterly basis. As a result, OMB concluded that senior
executives at most agencies are paying greater attention to IT security.

Inadequate accountability for job and program performance related to IT
security. OMB*s instructions to federal agencies for fiscal year 2002
GISRA reporting included high- level management performance measures to
assist agencies in evaluating their IT security status and the performance
of officials charged with implementing specific security requirements.

Limited security training for general users, IT professionals, and
security professionals. OMB stated that through the administration*s
*GoLearn* e- government initiative on establishing and delivering
electronic training, IT security courses were available to all federal
agencies in late 2002. 17 Initial courses are targeted to CIOs and program
managers, with additional courses to be added for IT security managers and
the general workforce.

Inadequate integration of security into the capital planning and
investment control process. OMB continues to address this issue through
the budget process to ensure that adequate security is incorporated
directly into and funded over the life cycle of all systems and programs
before funding is approved. Further, OMB stated that through this process,
agencies could demonstrate explicitly how much they are spending on
security and associate that spending with a given level of performance.
OMB also provided agencies with guidance in determining the security costs
of their IT investments.

Poor security for contractor- provided services. Through the
administration*s Committee on Executive Branch Information Systems
Security of the President*s Critical Infrastructure Protection Board
(since eliminated), an issue group was created to review this problem and
develop recommendations for its resolution, to include addressing how
security is handled in contracts themselves. This issue is currently under
review by the Federal Acquisition Regulatory Council to develop, for
governmentwide use, a clause to ensure that security is appropriately
addressed in contracts.

17 Launched in July 2002 by the Office of Personnel Management, the www.
golearn. gov site offers training in an online environment.

Page 10 GAO- 03- 852T Implementing Security Requirements

Limited capability to detect, report, and share information on
vulnerabilities or to detect intrusions, suspected intrusions, or virus
infections. OMB stated that addressing this weakness begins through
incident detection and reporting by individual agencies to incident
response centers at the Department of Homeland Security (DHS), the FBI,
the Department of Defense, or elsewhere. OMB also noted that agencies must
actively install corrective patches for known vulnerabilities and reported
that the Federal Computer Incident Response Center (FedCIRC) awarded a
contract on patch management to disseminate patches to all agencies more
effectively. 18 Among other actions, OMB and the CIO Council have
developed and deployed a process to rapidly identify and respond to cyber
threats and critical vulnerabilities.

Although not highlighted in OMB*s report, in our April 2003 testimony
before this subcommittee, we identified other activities undertaken to
address these common weaknesses. 19 In particular, during the past year,
NIST has issued related security guidance, including

 draft guidelines on designing, developing, implementing, and maintaining
an awareness and training program within an agency*s IT security program;
20  a draft guide on security considerations in federal IT procurements,

including specifications, clauses, and tasks for areas such as IT security
18 FedCIRC, formerly within the General Services Administration and now
part of the Department of Homeland Security, was established to provide a
central focal point for incident reporting, handling, prevention and
recognition for the federal government.

FedCIRC introduced its Patch Authentication and Dissemination Capability
Program in January 2003 as a free service to federal civilian agencies.
According to FedCIRC, this service provides a trusted source of validated
patches and notifications on new threats and vulnerabilities that have
potential to disrupt federal government mission critical systems and
networks. It is a Web- enabled service that obtains patches from vendors,
validates that the patch only does what it states that it was created to
correct, and provides agencies notifications based on established
profiles. 19 GAO- 03- 564T.

20 National Institute of Standards and Technology, Building an Information
Technology Security Awareness and Training Program, NIST Draft Special
Publication 800- 50 (July 19, 2002).

Page 11 GAO- 03- 852T Implementing Security Requirements

training and awareness, personnel security, physical security, and
security features in systems; 21 and  procedures for handling security
patches that provided principles and

methodologies for establishing an explicit and documented patching and
vulnerability policy and a systematic, accountable, and documented process
for handling patches. 22 In addition to these identified weaknesses, in
its fiscal year 2001 report,

OMB stated that it would direct all large agencies to undertake a Project
Matrix review to more clearly identify and prioritize the security needs
for government assets. Project Matrix is a methodology developed by the
Critical Infrastructure Assurance Office (CIAO) (recently transferred to
the Department of Homeland Security) that identifies the critical assets
within an agency, prioritizes them, and then identifies interrelationships
with other agencies or the private sector. 23 OMB reported that once
reviews have been completed at each large agency, it would identify
crossgovernment activities and lines of business for Project Matrix
reviews so that it will have identified both vertically and horizontally
the critical operations and assets of the federal government*s critical
enterprise architecture and their relationship beyond government. In its
fiscal year 2002 report, OMB acknowledged this requirement, but did not
assess agencies* overall progress or indicate a goal for when this process
will be complete. As we testified in April 2003, 14 agencies reported they
had identified their critical assets and operations* 10 using Project
Matrix and

4 using other methodologies. Five more agencies reported that they were in
some stage of identifying their critical assets and operations, and three
more planned to do so in fiscal year 2003. However, this process may take

21 National Institute of Standards and Technology, Security Considerations
in Federal Information Technology Procurements: A Guide for Procurement
Initiators, Contracting Officers, and IT Security Officials, NIST Draft
Special Publication 800- 4A (Oct. 9, 2002).

22 National Institute of Standards and Technology, Procedures for Handling
Security Patches* Recommendations of the National Institute of Standards
and Technology, NIST Special Publication 800- 40 (August 2002). 23 The
Project Matrix methodology defines *critical* as the responsibilities,
assets, nodes, and networks that, if incapacitated or destroyed, would
jeopardize the nation*s survival; have a serious, deleterious effect on
the nation at large; adversely affect large portions of

the American populace; and require near- term, if not immediate,
remediation (currently defined as within 72 hours). It defines *assets* as
tangible equipment, applications, and facilities that are owned, operated,
or relied upon by the agency, such as information technology systems or
networks, buildings, vehicles (aircraft, ships, or land), satellites, or
even a team of people.

Page 12 GAO- 03- 852T Implementing Security Requirements

several more years to complete because OMB has not established any
deadlines for the completion of Project Matrix reviews.

OMB*s fiscal year 2002 report also identifies several additional
governmentwide issues and trends as concerns. These are as follows: 
Agencies identify the same security weaknesses year after year, such as a
lack of system- level security plans. OMB reports that it will assist
agencies in prioritizing and reallocating funds to address these problems.

 Some IGs and CIOs have vastly different views of the state of the
agency*s security programs, and OMB reports that it will highlight such
discrepancies to agency heads.

 Many agencies are not adequately prioritizing their IT investments and
are seeking funding to develop new systems while significant security
weaknesses exist in their legacy systems. OMB reports that it will assist
agencies in reprioritizing their resources through the budget process.

 Based on the information in the reports, not all agencies are
successfully reviewing all programs and systems each year, as required by
information security law.

 More agency program officials must engage and be held accountable for
ensuring that the systems that support their programs and operations are
secure, rather than thinking of IT security as the responsibility of a
single agency official or the agency*s IT security office. As part of its
fiscal year 2002 report, OMB listed five areas in which it will

continue to work with agencies to ensure progress in safeguarding the
federal government*s information and systems: (1) the plan of action and
milestones process, (2) IT security performance measures, (3) the
President*s Management Agenda Scorecard, (4) governmentwide milestones for
IT security, and (5) the threat and vulnerability response process. Key
actions identified for these areas include the following:

 To ensure that remediation plans continue to be developed, implemented,
and corrective actions prioritized and tracked, OMB guidance will instruct
IGs, as part of their fiscal year 2003 FISMA work, to assess whether each
agency has in place a robust agencywide plan of action and milestone
process. A robust process, verified by agency IGs, is one of three
criteria agencies must meet to *get to green* for security on the
Expanding EGovernment Scorecard.

Page 13 GAO- 03- 852T Implementing Security Requirements

 To assist agencies and OMB in better tracking progress, along with their
plan of action and milestone updates, agencies will also be required to
begin quarterly reporting of their status against the OMB- prescribed IT
security performance measures.

 OMB set targeted milestones for improvement for some of the critical IT
security weaknesses in the President*s FY 2004 budget. Targets for
improvement include that by the end of 2003  all agencies are to have an
adequate agencywide process in place for

developing and implementing program- and system- level plans,  80 percent
of federal IT systems shall be certified and accredited, and  80 percent
of the federal government*s fiscal year 2004 major IT

investments shall appropriately integrate security into the life cycle of
the investment.

Our analyses of agency performance measure data and individual agencies*
efforts to implement information security requirements showed limited
progress in many cases. This limited progress is indicated despite other
benefits that that have resulted from GISRA implementation, such as
increased management attention to and accountability for information
security; important actions by the administration, such as integrating
information security into the President*s Management Agenda Scorecard; an
increase in the types of information being reported and made available

for oversight: and the establishment of a baseline for measuring agencies*
performance. 24 As mentioned previously, for fiscal year 2002 OMB required
agencies to

report performance measure data related to key information security
requirements, such as assessing systems for risk and having up- to- date
system security plans. Summarizing these data for 24 large federal
agencies and comparing results between fiscal years 2001 and 2002, OMB
reported in its fiscal year 2002 report that these data indicated that
agencies had made significant progress. Table 1 shows the governmentwide
results of this analysis reported by OMB for selected

24 U. S. General Accounting Office, Information Security: Additional
Actions Needed to Fully Implement Reform Legislation, GAO- 02- 470T
(Washington, D. C.: Mar. 6, 2002); GAO03- 564T. Agencies Show

Limited Progress in Implementing Security Requirements

Page 14 GAO- 03- 852T Implementing Security Requirements

performance measures, which indicates improvements for these measures
ranging from 18 to 27 percentage points.

Table 1: Comparison of Fiscal Year 2001 and Fiscal Year 2002 Performance
Measure Data for 24 Large Federal Agencies Number of systems Total

Assessed for risk and assigned a level

of risk Have an up- to- date IT

security plan Authorized for

processing following certification &

accreditation Security

controls have been tested and evaluated in the last year

Have a contingency

plan Contingency

plan has been tested Year FY 01 FY 02 FY 01 FY 02 FY 01 FY 02 FY 01 FY 02
FY 01 FY 02 FY 01 FY 02 FY 01 FY 02

Number of systems 7,411 7,957 3,195 5,160 2,986 4,930 1,953 3,772 2,447
4,751 2,221 4,342 1,228 2,768 Percentage of total systems 43 65 40 62 26
47 33 60 30 55 17 35 Difference from FY01 to FY02 +546 systems +22% +22%
+21% +27% +25% +18% Source: OMB FY 2002 Report to Congress on Federal
Government Information Security Reform and GAO (analysis).

However, our analyses showed that most agencies experienced more limited
progress than the OMB analysis indicates. Specifically, excluding data for
the National Aeronautics and Space Administration (NASA), our

analysis showed that increases for these same measures only ranged from 3
to 10 percent. NASA*s performance measure data were excluded because
fiscal year 2001 data were based on a sample of 221 of its most critical
systems, but were compared with data for its total of 1,641 systems for
fiscal year 2002. As a result, including NASA data significantly affected
the overall levels of governmentwide progress shown. Figure 1 shows the
percentage change in performance measures based on our analysis, excluding
data for NASA.

Page 15 GAO- 03- 852T Implementing Security Requirements

Figure 1: Performance Measure Percentages for Selected Information
Security Requirements a a Excludes data for NASA.

In addition to the impact of the NASA data, the performance data reported
by the Department of Defense (DOD) also represents only a small sample of
the thousands of systems DOD identified in total for the department, and
could significantly affect overall governmentwide results if data on all
systems were available. DOD reported that because of its size and

complexity, the collection of specific metrics required sizable lead time
to allow for the collection and approval process by each military service
and agency. For this reason, DOD focused its fiscal year 2002 GISRA
efforts on (1) a sample of 366 of its networks and (2) a sample of 155
systems that were selected from the sample of systems used for DOD*s
fiscal year 2001 GISRA review. It is these 155 systems for which DOD
reported performance measure data.

In addition to the our analysis of these overall performance measures, we
analyzed fiscal year 2002 GISRA reports by the 24 agencies and focused on
the status of individual agencies in implementing federal information
security requirements related to these and other measures. These analyses
showed mixed agency progress but overall, many agencies still had not

Page 16 GAO- 03- 852T Implementing Security Requirements

established information security programs that implement these
requirements for most of their systems. Summaries of our analyses for
selected information security requirements and reported performance
measures follow. 25 Agencies are required to perform periodic threat-
based risk assessments

for systems and data. Risk assessments are an essential element of risk
management and overall security program management and, as our best
practice work has shown, are an integral part of the management processes
of leading organizations. 26 Risk assessments help ensure that the
greatest risks have been identified and addressed, increase the
understanding of risk, and provide support for needed controls. Our

reviews of federal agencies, however, frequently show deficiencies related
to assessing risk, such as security plans for major systems that are not
developed on the basis of risk. As a result, the agencies had accepted an
unknown level of risk by default rather than consciously deciding what
level of risk was tolerable.

OMB*s performance measure for this requirement mandated that agencies
report the number and percentage of their systems that have been assessed
for risk during fiscal year 2001 and fiscal year 2002. Our analyses of
reporting for this measure showed some overall progress. For example, of
the 24 agencies, 13 reported an increase in the percentage of systems
assessed for fiscal year 2002 compared with fiscal year 2001. In addition,
as illustrated in figure 2, for fiscal year 2002, 11 agencies reported
that they had assessed risk for 90 to 100 percent of their systems.
However, figure 2 also shows that further efforts are needed by other
agencies, including the 8 that reported that less than 50 percent of their
systems had been assessed for risk.

25 In performing our analyses, we summarized and categorized the reported
information including data provided for the OMB- prescribed performance
measures. There were several instances where agency reports either did not
address or provide sufficient data for

a question or measure. In addition, IGs* independent evaluations sometimes
showed different results than CIO reporting or identified data
inaccuracies. Further, IG reporting also did not always include comparable
data, particularly for the performance measures. In part, this was because
although OMB instructions said that the IGs should use the

performance measures to assist in evaluating agency officials*
performance, the IG was not required to review the agency*s reported
measures. 26 GAO/ AIMD- 98- 68. Many Systems Do Not

Have Risk Assessments

Page 17 GAO- 03- 852T Implementing Security Requirements

Figure 2: Percentage of Systems with Risk Assessments during Fiscal Year
2002

An agency head is required to ensure that the agency*s information
security plan is practiced throughout the life cycle of each agency
system. In its reporting instructions, OMB required agencies to report
whether the agency head had taken specific and direct actions to oversee
that program officials and the CIO are ensuring that security plans are up
to date and

practiced throughout the life cycle. Agencies also had to report the
number and percentage of systems that had an up- to- date security plan.
Our analyses showed that although most agencies reported that they had
taken such actions, IG reports disagreed for a number of agencies, and

many systems do not have up- to- date security plans. Specifically, 21
agencies reported that the agency head had taken actions to oversee that
security plans are up to date and practiced throughout the life cycle. In

comparison, of the 21 IGs that addressed this issue, 9 reported such
actions had been taken and 12 reported that they had not. One IG reported
that the agency*s security plan guidance predates revisions to NIST and
OMB guidance and, as a result, does not contain key elements, such as the
risk assessment methodology used to identify threats and vulnerabilities.
In addition, another IG reported that although progress had been made,
security plans had not been completed for 62 percent of the agency*s
systems.

Regarding the status of agencies* security plans, as shown in figure 3, 9
of the 24 agencies reported that they had up- to- date security plans for
less than 50 percent of their systems for fiscal year 2002. Of the
remaining 15 Systems Lack Up- to- Date

Security Plans

Page 18 GAO- 03- 852T Implementing Security Requirements

agencies, 7 reported up- to- date security plans for 90 percent or more of
their systems.

Figure 3: Percentage of Systems with Up- to- Date Security Plans during
Fiscal Year 2002

As one of its performance measures for agency program official
responsibilities, OMB required agencies to report the number and
percentage of systems that have been authorized for processing following
certification and accreditation. Our analysis of agencies* reports showed
mixed progress for this measure. For example, 10 agencies reported
increases in the percentage of systems authorized for processing following
certification and accreditation compared with fiscal year 2001, but 8

reported decreases and 3 did not change (3 others did not provide
sufficient data). In addition, as shown in figure 4, 11 agencies reported
that for fiscal year 2002, 50 percent or more of their systems had been
authorized for processing following certification and accreditation, with
only 3 of these reporting from 90 to 100 percent. And of the remaining 13
agencies reporting less than 50 percent, 3 reported that none of their

systems had been authorized. System Certification and

Accreditation Remains a Problem

Page 19 GAO- 03- 852T Implementing Security Requirements

Figure 4: Percentage of Systems during Fiscal Year 2002 that are
Authorized for Processing by Management after Certification and
Accreditation Note: Rounding used to total 100 percent.

In addition to this mixed progress, IG reports identified instances in
which agencies* certification and accreditation efforts were inadequate.
For example, one agency reported that 43 percent of its systems were
authorized for processing following certification and accreditation. IG
reporting agreed, but also noted that over a quarter of the systems
identified as authorized had been operating with an interim authorization
and did not meet all of the security requirements to be granted
accreditation. The IG also stated that, due to the risk posed by systems
operating without certification and full accreditation, the department
should consider identifying this deficiency as a material weakness.

An agency head is responsible for ensuring that the appropriate agency
officials evaluate the effectiveness of the information security program,
including testing controls. Further, the agencywide information security
program is to include periodic management testing and evaluation of the
effectiveness of information security policies and procedures.
Periodically evaluating the effectiveness of security policies and
controls and acting to address any identified weaknesses are fundamental
activities that allow an organization to manage its information security
risks cost- effectively,

rather than reacting to individual problems ad hoc only after a violation
Further Security Control Testing and Evaluation

Needed

Page 20 GAO- 03- 852T Implementing Security Requirements

has been detected or an audit finding has been reported. Further,
management control testing and evaluation as part of the program reviews
can supplement control testing and evaluation in IG and our audits to help
provide a more complete picture of the agencies* security postures.

As a performance measure for this requirement, OMB required agencies to
report the number and percentage of systems for which security controls
have been tested and evaluated during fiscal years 2001 and 2002. Our
analyses of the data agencies reported for this measure showed that
although 15 agencies reported an increase in the overall percentage of
systems being tested and evaluated for fiscal year 2002, most agencies are
not testing all of their systems. As shown in figure 5, our analyses
showed that 10 agencies reported that they had tested the controls of less
than 50 percent of their systems for fiscal year 2002. Of the remaining 14
agencies,

4 reported that they had tested and evaluated controls for 90 percent or
more of their systems.

Figure 5: Percentage of Systems with Security Controls Tested during
Fiscal Year 2002

Note: Rounding used to total 100 percent.

Contingency plans provide specific instructions for restoring critical
systems, including such items as arrangements for alternative processing
facilities, in case the usual facilities are significantly damaged or
cannot be accessed. At many of the agencies we have reviewed, plans and
Lack of Contingency Plan

Testing Is a Major Weakness

Page 21 GAO- 03- 852T Implementing Security Requirements

procedures to ensure that critical operations can continue when unexpected
events occur, such as temporary power failure, accidental loss of files,
or major disaster, were incomplete. These plans and procedures were
incomplete because operations and supporting resources had not been fully
analyzed to determine which were critical and would need to be restored
first. Further, existing plans were not fully tested to identify their
weaknesses. As a result, many agencies have inadequate assurance that

they can recover operational capability in a timely, orderly manner after
a disruptive attack.

As another of its performance measures, OMB required agencies to report
the number and percentage of systems for which contingency plans have been
tested in the past year. As shown in figure 6, our analyses indicated

that for fiscal year 2002, only 2 agencies reported that they had tested
contingency plans for 90 percent or more of their systems, and 19 had
tested contingency plans for less than 50 percent of their systems. One
reported that none had been tested.

Figure 6: Percentage of Systems with Recently Tested Contingency Plans for
Fiscal Year 2002

Note: Rounding used to total 100 percent.

Page 22 GAO- 03- 852T Implementing Security Requirements

Agencies are required to provide training on security awareness for agency
personnel and on security responsibilities for information security
personnel. Our studies of best practices at leading organizations have
shown that such organizations took steps to ensure that personnel involved
in various aspects of their information security programs had the skills
and knowledge they needed. They also recognized that staff expertise had
to be frequently updated to keep abreast of ongoing changes in threats,
vulnerabilities, software, security techniques, and security monitoring
tools. However, our past information security reviews at individual
agencies have shown that they have not provided adequate computer security
training to their employees, including contractor staff.

Among the performance measures for these requirements, OMB mandated that
agencies report the number and percentage of employees* including
contractors* who received security training during fiscal years 2001 and
2002, and the number of employees with significant security

responsibilities who received specialized training. Our analyses showed
that 16 agencies reported that they provided security training to 50
percent or more of their employees and contractors for fiscal year 2002,
with 9 reporting 90 percent or more. Of the remaining 8 agencies, 4
reported that such training was provided for less than half of their

employees/ contractors, 1 reported that none were provided with this
training, and 3 provided insufficient data for this measure.

For specialized training for employees with significant security
responsibilities, some progress was indicated, but additional training is
needed. As indicated in figure 7, our analyses showed that 12 agencies
reported that 50 percent or more of their employees with significant
security responsibilities had received specialized training for fiscal
year 2002, with 5 reporting 90 percent or more. Of the remaining 12
agencies, 9 reported that less than half of such employees received
specialized

training, 1 reported that none had received such training, and 2 provided
insufficient data for this measure. Security Training Efforts

Show Mixed Progress

Page 23 GAO- 03- 852T Implementing Security Requirements

Figure 7: Percentage of Employees with Significant Security
Responsibilities Receiving Specialized Security Training during Fiscal
Year 2002

Agencies are required to implement procedures for detecting, reporting,
and responding to security incidents. Although even strong controls may
not block all intrusions and misuse, organizations can reduce the risks
associated with such events if they promptly take steps to detect
intrusions and misuse before significant damage can be done. In addition,
accounting for and analyzing security problems and incidents are effective

ways for an organization to gain a better understanding of threats to its
information and of the cost of its security- related problems. Such
analyses can also pinpoint vulnerabilities that need to be addressed to
help ensure

that they will not be exploited again. In this regard, problem and
incident reports can provide valuable input for risk assessments, help in
prioritizing security improvement efforts, and be used to illustrate risks
and related trends in reports to senior management.

Our information security reviews also confirm that federal agencies have
not adequately (1) prevented intrusions before they occur, (2) detected
intrusions as they occur, (3) responded to successful intrusions, or (4)
reported intrusions to staff and management. Such weaknesses provide
Incident- Handling

Capabilities Established, but Implementation Incomplete

Page 24 GAO- 03- 852T Implementing Security Requirements

little assurance that unauthorized attempts to access sensitive
information will be identified and appropriate actions taken in time to
prevent or minimize damage.

OMB included a number of performance measures in agency reporting
instructions that were related to detecting, reporting, and responding to
security incidents. These included the number of agency components with an
incident- handling and response capability, whether the agency and its
major components share incident information with FedCIRC in a timely
manner, and the numbers of incidents reported. OMB also required that
agencies report on how they confirmed that patches have been tested and
installed in a timely manner.

Our analyses of agencies* reports showed that although most agencies
reported that they have established incident- response capabilities,
implementation of these capabilities is still not complete. For example,
12 agencies reported that for fiscal year 2002, 90 percent or more of
their components had incident handling and response capabilities and 8
others reported that they provided these capabilities to components
through a central point within the agency. However, although most agencies
report having these capabilities for most components, in at least two
cases, the IGs* evaluations identified instances in which incident-
response capabilities were not always implemented. For example, one IG
reported that the agency established and implemented its computer security
incident- response capability on August 1, 2002, but had not enforced
procedures to ensure that components comply with a consistent methodology
to identify, document, and report computer security incidents. Another IG
reported that the agency had released incidenthandling procedures and
established a computer incident- response team, but had not formally
assigned members to the team or effectively communicated procedures to
employees.

Our analyses also showed that for fiscal year 2002, 13 agencies reported
that they had oversight procedures to verify that patches had been tested
and installed in a timely manner, and 10 reported that they did not. Of
those that did not have procedures, several specifically mentioned that
they planned to participate in FedCIRC*s patch management process.

Page 25 GAO- 03- 852T Implementing Security Requirements

Agencies are required to develop and implement risk- based, cost-
effective policies and procedures to provide security protection for
information collected or maintained either by the agency or for it by
another agency or contractor. In its fiscal year 2001 GISRA report to the
Congress, OMB identified poor security for contractor- provided services
as a common weakness and for fiscal year 2002 reporting, included
performance measures to help indicate whether the agency program officials
and CIO used appropriate methods, such as audits and inspections, to
ensure that service provided by a contractor are adequately secure and
meet security requirements.

Our analyses showed that a number of agencies reported that they have
reviewed a large percentage of services provided by a contractor, but
others have reviewed only a small number. For operations and assets under
the control of agency program officials, 17 agencies reported that for
fiscal year 2002 they reviewed 50 percent or more of contractor operations
or facilities, with 7 of these reporting that they reviewed 90 percent or
more. Four agencies reported that they had reviewed less than 30 percent
of contractor operations or facilities.

For operations and assets under the control of the CIO, 13 agencies
reported that for fiscal year 2002 they reviewed 50 percent or more of
contractor operations or facilities, with 7 of these reporting that they
reviewed 90 percent or more. Of the remaining agencies, 3 reported that
they reviewed less than 30 percent of contractor operations or facilities
and 5 reported that they had no services provided by a contractor or
another agency.

Developing effective corrective action plans is key to ensuring that
remedial action is taken to address significant deficiencies. Further, a
centralized process for monitoring and managing remedial actions enables
the agency to identify trends, root causes, and entitywide solutions. OMB
has required agency heads to work with CIOs and program officials to
provide a strategy to correct security weaknesses identified through
annual program reviews and independent evaluations, as well as other
reviews or audits performed throughout the reporting period by the IG or
us. Agencies are also required to submit corrective action plans for all
programs and systems where a security weakness has been identified. OMB
guidance requires that these plans list the identified weaknesses and, for
each, identify a point of contact, the resources required to resolve the
weakness, the scheduled completion date, key milestones with completion
dates for the milestones, milestone changes, the source of the weakness
Some Reported

Improvement in Efforts to Ensure Security of Contractor- Provided Services

Processes Needed to Ensure Effective Corrective Actions

Page 26 GAO- 03- 852T Implementing Security Requirements

(such as a program review, IG audit, or GAO audit), and the status
(ongoing or completed). Agencies are also required to submit quarterly
updates of these plans that list the total number of weaknesses identified
at the program and system levels, as well as the numbers of weaknesses

for which corrective actions were completed on time, ongoing and on
schedule, or delayed. Updates are also to include the number of new
weaknesses discovered subsequent to the last corrective action plan or
quarterly update.

As reported in its fiscal year 2002 report to the Congress, OMB requires
that agencies establish and maintain an agencywide process for developing
and implementing program- and system- level corrective action plans and
that these plans serve as an agency*s authoritative management tool to
ensure that program- and system- level IT security weaknesses are
remediated. In addition, OMB requires that every agency maintain a central
process through the CIO*s office to monitor agency remediation activity.

Our analyses of agencies* fiscal year 2002 corrective action plans, IGs*
evaluations of these plans, and available quarterly updates showed that
the usefulness of these plans as part of agency management*s overall
process to identify and correct their information security weaknesses
could be limited when they do not identify all weaknesses or provide
realistic completion estimates. For example, of 14 agency IGs that
reported on whether or not their agency*s corrective action plan addressed
all identified significant weaknesses, only 5 reported that their agency*s
plan did so, and 9 specifically reported that their agency*s plan did not.
Further, in several instances, corrective action plans did not indicate
the current status of weaknesses identified or include information
regarding whether actions were on track as originally scheduled.

In addition, most agencies did not indicate the relative priority of
weaknesses for corrective action. As a result, it was difficult to
determine whether an agency*s actions are focused on achieving results for
its most significant weaknesses. Further, three IGs reported that their
agencies did not have a centralized tracking system to monitor the status
of corrective actions, and one IG specifically questioned the accuracy of
unverified, selfreported corrective actions reported in the agency*s plan.

In its report, OMB highlighted several actions that may help to address
such concerns. For example, OMB reported that since completion of their
fiscal year 2002 reviews, agencies have been working to prioritize their
IT security weaknesses. In addition, OMB stated that fiscal year 2003
FISMA

Page 27 GAO- 03- 852T Implementing Security Requirements

reporting guidance would direct agency IGs to verify whether an agency has
a central process to monitor remediation, as required by OMB.

The governmentwide weaknesses identified by OMB in its reports to the
Congress, as well as the limited progress in implementing key information
security requirements, continue to emphasize that agencies have not
effectively implemented programs for managing information security. For

the past several years, we have analyzed the audit results for 24 of the
largest federal agencies and found that all 24 had significant weaknesses
in the policies, procedures, and technical controls that apply to all or a
large segment of their information systems and help ensure their proper
operation. In particular, our analyses in both 2001 and 2002 found that
all 24 had weaknesses in security program management, which is

fundamental to the appropriate selection and effectiveness of the other
categories of controls. Security program management covers a range of
activities related to understanding information security risks; selecting
and implementing controls commensurate with risk; and ensuring that
controls, once implemented, continue to operate effectively. 27
Establishing a strong security management program requires that agencies

take a comprehensive approach that involves both (1) senior agency program
managers who understand which aspects of their missions are the most
critical and sensitive and (2) technical experts who know the agencies*
systems and can suggest appropriate technical security control techniques.
We studied the practices of organizations with superior security programs
and summarized our findings in a May 1998 executive guide entitled
Information Security Management: Learning From Leading Organizations. 28
Our study found that these organizations managed their information
security risks through a cycle of risk management activities. These
activities, which are now among the federal government*s statutory
information security requirements, included

 assessing risks and determining protection needs, 27 U. S. General
Accounting Office, Computer Security: Improvements Needed to Reduce Risk
to Critical Federal Operations and Assets, GAO- 02- 231T (Washington, D.
C.: Nov. 9, 2001); and Computer Security: Progress Made, but Critical
Federal Operations and Assets Remain at Risk, GAO- 03- 303T (Washington,
D. C.: Nov. 19, 2002). 28 GAO/ AIMD- 98- 68. Agencies Face

Continuing Challenges to Implement Effective Information Security
Management Programs

Page 28 GAO- 03- 852T Implementing Security Requirements

 selecting and implementing cost- effective policies and controls to meet
those needs,  promoting awareness of policies and controls and of the
risks that

prompted their adoption among those responsible for complying with them,
and

 implementing a program of routine tests and examinations for evaluating
the effectiveness of policies and related controls and reporting the
resulting conclusions to those who can take appropriate corrective action.
Although GISRA reporting provides performance information on these areas,
it is important for agencies to ensure that they have the appropriate
management structures and processes in place to strategically manage

information security, as well as ensure the reliability of performance
information. For example, disciplined processes can routinely provide the
agency with timely, useful information for day- to- day management of
information security. Also, development of management strategies that
identify specific actions, time frames, and required resources may help to
significantly improve performance.

With GISRA expiring on November 29, 2002, FISMA was enacted on December
17, 2002, to permanently authorize and strengthen the information security
program, evaluation, and reporting requirements established by GISRA. In
particular, FISMA provisions established additional requirements that can
assist the agencies in implementing effective information security
programs, help ensure that agency systems incorporate appropriate
controls, and provide information for administration and congressional
oversight. These specific requirements are described and discussed below.

FISMA requires an agency*s CIO to designate a senior agency information
security officer who, for the agency*s FISMA- prescribed information
security responsibilities, shall

 carry out the CIO*s responsibilities;  possess professional
qualifications, including training and experience, required to administer
the required functions; FISMA Provisions

Can Strengthen Information Security Implementation

Designating a Senior Agency Information Security Officer

Page 29 GAO- 03- 852T Implementing Security Requirements

 have information security duties as that official*s primary duty; and 
head an office with the mission and resources to assist in ensuring agency
compliance. In contrast, GISRA required the CIO to designate a senior
agency

information security official, but did not specify the responsibilities,
qualifications, or other requirements for this position. Agencies* fiscal
year 2002 GISRA reports showed that the CIOs had designated a senior
agency information security official for 22 of the 24 agencies (the
remaining 2

agencies* reports did not indicate whether they had designated such an
official), but OMB did not require the agencies to report any additional
information on the responsibilities of this official.

FISMA requires each agency to develop, maintain, and annually update an
inventory of major information systems (including major national security
systems) operated by the agency or under its control. This inventory is
also to include an identification of the interfaces between each system
and all other systems or networks, including those not operated by or
under the control of the agency. FISMA also mandates that OMB issue
guidance and oversee the implementation of this requirement. Although
GISRA did

not specifically require that agencies maintain an inventory of major
information systems, OMB reporting instructions for fiscal year 2002 did
require agencies to report the total number of agency systems, and most
agencies reported a total number in their GISRA reports. However, six IGs
specifically reported problems with the completeness of their agencies*
system inventories.

FISMA includes a number of requirements for NIST to develop
securityrelated standards and guidelines. These include, for systems other
than those dealing with national security, (1) standards to be used by all
agencies to categorize all of their information and information systems
based on the objectives of providing appropriate levels of information
security according to a range of risk levels, (2) guidelines recommending
the types of information and information systems to be included in each
category, and (3) minimum information security requirements for
information and information systems in each category.

For the first of these requirements* standards for security
categorization* NIST is to submit the standards to the Secretary of
Commerce for promulgation no later than 12 months after enactment
Developing, Maintaining,

and Updating an Inventory of Major Information Systems

NIST Development of Standards and Guidelines

Page 30 GAO- 03- 852T Implementing Security Requirements

(December 17, 2003). The guidelines on the types of information and
information systems to be included in each category are required to be
issued no later than 18 months after enactment (June 17, 2004). The
minimum information security requirements are required to be submitted to
the Secretary for promulgation no later than 36 months after enactment
(December 17, 2005).

On May 16, 2003, NIST issued an initial public draft of the standards for
security categorization for comment. 29 These proposed standards would
establish three levels of risk* low, moderate, and high 30 *and would
categorize information and information systems with respect to security by
having an agency assign the appropriate level of risk to each of three
security objectives: (1) confidentiality, defined as preserving authorized
restrictions on information access and disclosure, including means for

protecting personal privacy and proprietary information; (2) integrity,

defined as guarding against improper information modification or
destruction, and including ensuring information nonrepudiation and
authenticity; and (3) availability, defined as ensuring timely and
reliable access to and use of information. Also according to the draft
standard, because an information system may contain more than one type of
information that is subject to security categorization (such as privacy
information, medical information, proprietary information, financial
information, and contractor- sensitive information), the security
categorization of an information system that processes, stores, or

transmits multiple types of information should be at least the highest
risk level that has been determined for each type of information for each
security objective, taking into account dependencies among the objectives.

29 National Institute of Standards and Technology, Standards for Security
Categorization of Federal Information and Information Systems, Federal
Information Processing Standards Publication (FIPS PUB) 199, Initial
Public Draft, Version 1.0, May 2003.

30 As defined in the draft NIST standard, the level of risk is low if an
event could be expected to have a limited adverse effect on agency
operations (including mission, functions, image or reputation), agency
assets, or individuals; and cause a negative outcome or result in limited
damage to operations or assets, requiring minor corrective actions or
repairs. The level of risk is moderate if an event could be expected to
have a serious adverse effect on agency operations, agency assets, or
individuals; and cause significant degradation in mission capability,
place the agency at a significant disadvantage, or result in major damage
to assets, requiring extensive corrective actions or repairs. The level of
risk is high if an event could be expected to have a severe or
catastrophic adverse effect on agency operation, agency assets, or
individuals; and cause a loss of mission capability for a period that
poses a threat to human life, or results in a loss of major assets.

Page 31 GAO- 03- 852T Implementing Security Requirements

FISMA also requires NIST to develop, in conjunction with the Department of
Defense, including the National Security Agency, guidelines for
identifying an information system as a national security system. On June
3, 2003, NIST released a draft working paper of these guidelines that
provides the basis and method for identifying national security systems,
including agency determination and reporting responsibilities. 31 For non-
national- security programs, GISRA required those performing the

annual independent evaluations (essentially the IGs) to report the results
of their evaluations to OMB and required OMB to summarize these results in
an annual report to the Congress. In addition, OMB required the agencies
to report the results of their annual GISRA security reviews of systems
and programs. FISMA now requires agencies to report annually to OMB, as
well as to the House Committees on Government Reform and

Science; the Senate Committees on Governmental Affairs and Commerce,
Science, and Transportation; the appropriate congressional authorizing and
appropriations committees; and the Comptroller General; on the adequacy
and effectiveness of information security policies, procedures, and
practices, including compliance with each of FISMA*s requirements

for an agencywide information security program. In summary, with few
exceptions, agencies* implementation of federal information security
requirements has not yet shown significant progress. Legislation,
congressional oversight like today*s hearing, and efforts by OMB through
the budget process, the President*s Management Agenda Scorecard, and other
tools, such as corrective action plans and performance measures, have all
contributed to increasing agency management*s attention to information
security. Also, new techniques, such as establishing governmentwide
performance goals and quarterly reporting of performance measures, may
help to further encourage agency progress and facilitate congressional and
administration oversight.

However, in addition to these steps, achieving significant and sustainable
results will likely require agencies to integrate such techniques into
overall security management programs and processes that prioritize and
routinely monitor and manage their information security efforts. These
programs 31 National Institute of Standards and Technology, Guideline for
Identifying an Information System as a National Security System, NIST
Special Publication 800- 59,

Draft, Version 0.3, June 3, 2003. Agency Reporting to the

Congress

Page 32 GAO- 03- 852T Implementing Security Requirements

and processes must focus on implementing statutory security requirements,
including performing risk assessments, testing and evaluating controls,
and identifying and correcting weaknesses to ensure that the greatest
risks have been identified, security controls have been implemented to
address these risks, and that critical operations can continue when
unexpected events occur. Development of management strategies that
identify specific actions, time frames, and required resources may also
help to significantly improve performance. Further, agencies will need to
ensure that systems and processes are in place to provide information and
facilitate the day- to- day management of

information security throughout the agency, as well as to verify the
reliability of reported performance information.

Mr. Chairman, this concludes my statement. I would be pleased to answer
any questions that you or other members of the Subcommittee may have at
this time. If you should have any questions about this testimony, please
contact me at (202) 512- 3317. I can also be reached by E- mail at daceyr@
gao. gov.

(310194)

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