[Audit Report on General and Application Controls  Over the
Technical Information Management System, Offshore Minerals
Management, Minerals Management Service]
[From the U.S. Government Printing Office, www.gpo.gov]

Report No. 00-i-647

Title: Audit Report on General and Application Controls  Over the
       Technical Information Management System, Offshore Minerals
       Management, Minerals Management Service

Date:  August 31, 2000



                  **********DISCLAIMER**********

This file contains an ASCII representation of an OIG report.
No attempt has been made to display graphic images or
illustrations.

Some tables may be included, but may not resemble those in the
printed version.  A printed copy of this report may be obtained
by referring to the PDF file or by calling the Office of
Inspector General, Division of Acquisition and Management
Operations at (202) 208-4599.

                  ******************************





U.S. Department of the Interior
Office of Inspector General


AUDIT REPORT
GENERAL AND APPLICATION CONTROLS 
OVER THE TECHNICAL INFORMATION MANAGEMENT SYSTEM,
OFFSHORE MINERALS MANAGEMENT,
MINERALS MANAGEMENT SERVICE


REPORT NO. 00-I-647

AUGUST 2000



EXECUTIVE SUMMARY

General and Application Controls Over
the Technical Information Management System,
Offshore Minerals Management,
Minerals Management Service (No. 00-i-647)


BACKGROUND

The Minerals Management Service (MMS) manages the Nation's
natural gas, oil, and other mineral resources on the Outer
Continental Shelf and collects, accounts for, and disburses
revenues from offshore and onshore mineral leases on Federal and
Indian lands.  MMS's Offshore Minerals Management (OMM) program
manages the Outer Continental Shelf mineral leases.  These leases
result in more than $4 billion of royalties being collected
annually.  Also, OMM provides oversight to ensure safe and
environmentally sound exploration and production of the Nation's
mineral resources on the Outer Continental Shelf.  To accomplish
its mission and to automate business and regulatory functions,
OMM designed, developed, and implemented the Technical
Information Management System (TIMS), an MMS mission-critical
system and a comprehensive corporate database. 

OBJECTIVE

The objective of the audit was to determine whether OMM had
effective general and application controls over TIMS and whether
TIMS was operated in compliance with applicable Federal laws and
regulations.  In addition, we performed this audit to support the
Office of Inspector General's examination of the financial
statements of MMS by evaluating the reliability of the controls
over computer-generated data that support the Royalty Management
Program's portion of the financial statements.  

RESULTS IN BRIEF

Overall, we concluded that OMM had established adequate general
and application controls over TIMS.  However, improvements are
needed in four areas in OMM's general and application controls
over TIMS.  These areas are the security program, the continuity
of operations plan to protect data in the event of a disaster or
a system failure, controls over access to TIMS data, and software
development and change management.  Federal laws and regulations
and Department of the Interior and MMS policies and procedures
require that general and application controls be established and
implemented to protect information in computer systems.
Weaknesses existed in the controls over TIMS because OMM
management had not developed an adequate security program and had
not ensured that policies and procedures were followed.  The lack
of adequate controls increased the risk that TIMS data could be
accessed and modified or disclosed by unauthorized users, that
TIMS software and data could be stolen or destroyed, that TIMS
functions and processes could not be recovered  in the event of a
disaster or a system failure, and that TIMS could not perform as
intended.  

RECOMMENDATIONS

We made 15 recommendations related to MMS's controls over TIMS.
These recommendations related to improving (1) OMM's security
program over TIMS, (2) TIMS' continuity of operations plan, (3)
access controls to TIMS and its databases, and (4) the policies
and procedures for making changes to TIMS software and for
testing the changes.

AUDITEE COMMENTS AND OIG EVALUATION

MMS concurred with the report's 15 recommendations.  Based on the
response, we considered eight recommendations resolved and
implemented and seven recommendations resolved but not
implemented.




AUDIT REPORT                                    A-IN-MMS-001-99-R

Memorandum

     To:  Director, Minerals Management Service

   From:  Roger La Rouche
          Acting Assistant Inspector General for Audits

Subject:  Audit Report on General and Application Controls 
          Over the Technical Information Management System,
          Offshore Minerals Management, Minerals Management
          Service (No. 00-i-647)

INTRODUCTION

This report presents the results of our review of general and
application controls over the Minerals Management Service's (MMS)
Technical Information Management System (TIMS).  The objective of
the audit was to determine whether MMS had effective controls
over TIMS and whether TIMS was operated in compliance with
applicable Federal laws and regulations.  In addition, we
performed this audit to support the Office of Inspector General's
examination of the financial statements of MMS by evaluating the
reliability of the controls over computer-generated data that
support the Royalty Management Program's portion of the financial
statements.  

BACKGROUND

MMS manages the Nation's natural gas, oil, and other mineral
resources on the Outer Continental Shelf and collects, accounts
for, and disburses revenues from offshore and onshore mineral
leases on Federal and Indian lands.  In 1998, MMS collected $5.6
billion from Federal and Indian mineral leasees, of which $4.3
billion was from Outer Continental Shelf mineral leasees.  MMS
has two specialized operating programs, the Offshore Minerals
Management (OMM) program and the Royalty Management Program.  OMM
manages the Outer Continental Shelf mineral leases and provides
oversight to ensure the safe and environmentally sound
exploration and production of the Nation's mineral resources on
the Outer Continental Shelf.  OMM has its headquarters in
Washington, D.C., with offices in Herndon, Virginia, and has
regional offices in New Orleans, Louisiana; Anchorage, Alaska;
and Camarillo, California.  Also, the headquarters OMM Leasing
Division has its Mapping and Boundary Branch, located in Denver,
Colorado.  The Royalty Management Program manages the accounting
for and the collection and disbursement of royalty, rent, and
bonus revenues generated from Federal and Indian mineral leases.

To accomplish its mission, OMM designed, developed, and
implemented TIMS, an MMS mission-critical system and a
comprehensive corporate database that replaced and upgraded all
Federal information processing resources which supported the OMM
program.  TIMS was developed to modernize and replace several
critical offshore systems, including the Outer Continental Shelf
Information System, the Offshore Inspection System, the Automated
Cartographic System, and the Geological and Geophysical Database.
TIMS information is used, in part, to update the Royalty
Management Program system with oil and gas well production data
from offshore leases to assist in verifying the accuracy of
royalties collected  from the Outer Continental Shelf.

TIMS is a computerized information system that automates all
business and regulatory functions of OMM.  TIMS is a
three-tier[1] client/server platform with application servers
located at all the OMM regional offices (three) and district
offices (six) and database servers located at the regional
offices.  The Chief of the OMM Information Technology Division is
the owner of TIMS.  The Division is responsible for developing
and maintaining TIMS's database structures, and regional and
district offices are responsible for the data in the databases.
TIMS employs the Oracle relational database management system and
tools to manage data and support OMM business functions.  In
addition, TIMS includes commercial off-the-shelf software for OMM
geologic interpretative tools and mapping functions.  TIMS is
constructed of 41 business components[2] (the components are
listed in Appendix 2), which include more than 800 modules.  To
operate, TIMS uses approximately 55 different types of hardware
items, such as personal computers and network equipment, and 68
software items, such as Windows NT and UNIX operating systems,
ArcView, Geoquest, and Microsoft Office.  

SCOPE OF AUDIT

We reviewed OMM general and application controls over TIMS.
Specifically, we reviewed the following general controls:  (1)
software development and change management, (2) risk assessment,
(3) security plans, (4) service continuity, (5) system software,
and (6) access controls.  For application controls, we reviewed
input, processing, authorization, and output.  To accomplish our
objective, we interviewed OMM and contractor personnel, reviewed
application and systems documentation, observed and became
familiar with system operations and data structures, analyzed
access and security controls, and evaluated service continuity
procedures and testing.  The audit was conducted at the
Information Technology Division Office of OMM and the OMM Gulf of
Mexico Regional Office in New Orleans and Division headquarters
and the Information Management Division in Herndon.  Although
TIMS is installed at all of the regional offices, our review was
limited to the Gulf of Mexico Regional Office because this
regional office processes almost 90 percent of the data related
to oil and gas production and Outer Continental Shelf royalties.

Our audit was made in accordance with the "Government Auditing
Standards," issued by the Comptroller General of the United
States.  Accordingly, we included such tests of records and other
auditing procedures that were considered necessary under the
circumstances.

As part of our audit, we employed statistical test samples to
determine the adequacy of TIMS access controls and software
development and change management procedures.  Specifically, we
randomly selected 77 TIMS users from a list of 849 users who had
access to TIMS.  Also, we randomly selected 132 change requests
from a list of 1,157 change requests for the period of October
1998 through June 1999.

During our audit, the Department of the Interior's Office of
Information Resources Management contracted to acquire
professional services to support the Department with testing,
analysis, and vulnerability assessment of Departmentwide
information technology architecture.  Specifically, the
contractor was tasked with performing a comprehensive
vulnerability analysis (using Internet Security Systems scanning
software) of Departmental internet protocol address assignments,
which included OMM internet protocol addresses.  As a result, we
did not review the results of the analysis of OMM networks.

PRIOR AUDIT COVERAGE

During the past 5 years, neither the General Accounting Office
nor the Office of Inspector General has issued any reports
related to OMM's general and application controls over  TIMS.

RESULTS OF AUDIT

We concluded that overall, MMS's OMM had established adequate
general and application controls over TIMS.  However, we believe
that the general controls of OMM need improvements in four areas:
security program; continuity of operations in the event of a
disaster or a system failure; controls over access to TIMS; and
software development and change management.  Office of Management
and Budget Circular A-130, "Management of Federal Information
Resources," and National Institute of Standards and Technology
publications and guidelines require agencies to establish and
implement computer security and management and internal controls
to improve the protection of sensitive[3] information in the
computer systems of executive branch agencies.  Additionally, the
Congress enacted laws, such as the Privacy Act of 1974 (5 U.S.C.
* 552a) and the Computer Security Act of 1987 (40 U.S.C. * 759),
to improve the security and privacy of sensitive information in
computer systems by requiring executive branch agencies to ensure
that the level of computer security and controls over sensitive
information is adequate.  Further, the Department of the Interior
and MMS have issued policies and procedures to implement general
and application controls to protect sensitive data in automated
information systems.  Weaknesses existed in the general controls
over TIMS because OMM management had not developed an adequate
security program and had not ensured that policies and procedures
were followed.  The lack of adequate controls may increase the
risk of (1) unauthorized access and modifications to and
disclosure of sensitive TIMS data, (2) theft or destruction of
OMM software and sensitive information, (3) loss of TIMS systems
and functions in the event of a disaster or a system failure, and
(4) TIMS not performing as intended.  

In the four areas that needed improvements in the controls, we
identified 8 weaknesses and made 15 recommendations for improving
the controls over TIMS.  The weaknesses are summarized in the
paragraphs that follow, and details of the weaknesses and our
respective recommendations to correct these weaknesses are in
Appendix 1.

Security Program

OMM management did not have a security plan for TIMS and did not
ensure that computer security awareness training was provided.
As a result, there was an increased risk that sensitive data
could be impaired or compromised and that data could be
inadvertently disclosed or destroyed or erroneously modified.  We
made three recommendations to correct these weaknesses.

Service Continuity

OMM's contingency planning, backup, and disaster recovery
procedures did not provide reasonable assurance that the TIMS
processing environment could be recovered in the event of a
disaster or a system failure.  Specifically, the Continuity of
Operations Plan had not been tested, critical personnel had not
been trained to effectively implement the Plan, a copy of the
Plan was not kept at the off-site storage facility, and TIMS data
and applications were not routinely transferred to the off-site
storage facility.  As a result, there was an increased risk that
the mission-critical TIMS could not be recovered in the event of
a disaster or a system failure.  We made five recommendations to
address these weaknesses.  

Access Controls

OMM management did not limit the numbers of log-in attempts
allowed for access to TIMS, did not control password settings,
did not remove in a timely manner access for employees who
terminated their employment, and did not control access to TIMS
databases.  As a result, there was an increased risk that
sensitive data maintained on TIMS were vulnerable to unauthorized
access, manipulation, and disclosure.  We made four
recommendations to address these weaknesses.  

Software Development and Change Management

OMM management did not implement controls to ensure that TIMS
application software changes were authorized, approved, and
tested before being moved into production.  As a result, there
was an increased risk that TIMS applications may not perform as
intended.  We made three recommendations to address these
weaknesses.

MMS Response and Office of Inspector General Reply

In the July 19, 2000 response (Appendix 3) to the draft report
from the Director of MMS, MMS concurred with all of the 15
recommendations.  Based on the response, we consider
Recommendations C.1, C.3, C.4, D.1, D.2, E.1, F.1, and G.1
resolved and implemented and Recommendations A.1, B.1, B.2, C.2,
C.5, G.2, and H.1 resolved but not implemented.  Accordingly, the
unimplemented recommendations will be forwarded to the Assistant
Secretary for Policy, Management and Budget for tracking of
implementation.  

Although MMS concurred with Recommendation H.1, it disagreed with
the "analysis that drew the auditors to the recommendation."  MMS
stated that although the TIMS Maintenance Methodology required
test plans, the test plans were not required for "routine and/or
minor changes," such as reports, system administration functions,
database triggers, software packages, and menu changes.  We
believe that testing is a critical component of software
maintenance because testing ensures that applications meet user
and management needs, produce reliable data, and operate in
accordance with laws, regulations, and management policies and
procedures.  Test plans should define the expected output and
include tests for valid, invalid, expected, and unexpected
results. The TIMS Maintenance Methodology does not allow for
exceptions from change management procedures such as testing for
system administration, database triggers, software packages, and
menu changes.  Further, the TIMS Maintenance Methodology does not
allow for exceptions to exclude the quality assurance group and
user group from testing changes prior to the changes being moved
into production.  The Methodology states that "every TIMS work
product must pass quality assurance tests before made available
for testing by the Customer User Acceptance Team."

Since the report's recommendations are considered resolved, no
further response to the Office of Inspector General is required
(see Appendix 4).    

Section 5(a) of the Inspector General Act (5 U.S.C. app. 3),
requires the Office of Inspector General to list this report in
its semiannual report to the Congress.  In addition, the Office
of Inspector General provides audit reports to the Congress.


**FOOTNOTES**

[1]:A three-tier client/server environment is defined as one in
which "the user interface is stored in the client, the bulk of
the business application logic is stored in one or more servers,
and the data are stored in a database server."  (The Computer
Language Company, Inc., Computer Desktop Encyclopedia, 1981-1999)

[2]:TIMS is divided into major groupings or components that
correspond to the different activities overseen by OMM.

[3]:"Sensitive data" is defined in 40 U.S.C. * 759 as "any
information, the loss, misuse, or unauthorized access to or
modification of which could adversely affect the national
interest or the conduct of Federal programs, or the privacy to
which individuals are entitled under section 552a of Title 5,
United States Code (the Privacy Act)."


APPENDIX 1
Page 1 of 11

DETAILS OF WEAKNESSES AND RECOMMENDATIONS
SECURITY PROGRAM

A.  Computer Security Plan

Condition:Offshore Minerals Management (OMM) had not developed a
security plan for the Technical Information Management System
(TIMS), which has been identified by the Minerals Management
Service (MMS) as a sensitive and mission-critical system.

Criteria: Security plans are required by 40 U.S.C. * 759 and
Appendix III, "Security of Federal Automated Information
Resources," of Office of Management and Budget Circular A-130,
"Management of Federal Information Resources," to be developed
for all sensitive computer systems.  A computer security plan is
designed to assist agencies in addressing the protection of
general support systems and major applications that contain
sensitive information to help ensure the system's integrity,
availability, and confidentiality.  In addition, National
Institute of Standards and Technology's (NIST) Special
Publication 800-18, "Guide for Developing Security Plans for
Information Technology Systems," provides guidance on developing,
implementing, and monitoring security plans for automated
information systems.  Also, Appendix III of Circular A-130
requires that a summary of the security plan be incorporated into
the agency's Strategic Information Resources Management Plan.
Additionally, Appendix III of Circular A-130 states that the lack
of a security plan for a major application should be considered a
deficiency pursuant to Office of Management Budget Circular
A-123, "Management Accountability and Control," and the Federal
Managers' Financial Integrity Act (31 U.S.C. * 1105, 1113, and
3512).  

Cause:  OMM information technology officials did not ensure that
a computer security plan for TIMS was prepared in accordance with
40 U.S.C. * 759, Office of Management and Budget requirements,
and NIST guidelines.  According to OMM officials, a draft TIMS
Y2K (Year 2000) contingency plan was prepared that addressed
degradation or failure of activities and remedies should any
event threaten or disable the system.  However, this plan did not
meet the requirements for a security plan because it did not
include the rules of the system, such as rules of behavior
concerning use of, security in, and acceptable level of risk for
the system; training of all individuals on their security
responsibilities; personnel controls; incident response
capability; continuity of support; technical security; and
identification of connections to other systems.

Effect:  Without this plan, OMM did not have adequate assurance
that data in its TIMS were adequately protected.

Recommendation

We recommend that the Director of MMS ensure that a computer
security plan for TIMS is developed, implemented, and monitored
in accordance with the United States Code, Office of Management
and Budget Circular A-130, and NIST guidelines.


SECURITY PROGRAM

B.  Computer Security Training

Condition:  Mandatory computer security awareness training had
not been provided to OMM employees and contractor personnel.
Specifically, at least 220 Gulf of Mexico Regional Office and
district personnel and Information Technology Division personnel
had not received annual computer security awareness training
since 1992.

Criteria:  Mandatory periodic training in computer security
awareness and accepted computer security practices is required by
40 U.S.C. * 759 for employees who are involved in managing,
using, or operating each Federal computer system within or under
the supervision of that agency.  In addition, the Department of
the Interior's "Automated Information Systems Security Handbook"
requires that computer security training be provided on an
ongoing basis and that refresher training be provided at least
annually.  

Cause:  OMM information technology officials had not established
policies and procedures to ensure that annual computer security
awareness training was completed in accordance with applicable
computer security guidelines.

Effect:  Without annual training in computer security awareness
and accepted computer security practices of employees who are
involved in managing, using, or operating sensitive OMM computer
systems, including TIMS, there is an increased risk of
unauthorized disclosure of sensitive and propriety data.

Recommendations

We recommend that the Director of MMS:

1.  Implement policies and procedures to ensure that OMM
employees and contractor personnel who are involved with
sensitive component systems receive annual computer security
awareness training.

2.  Ensure that training is documented in the employee human
resource files.


CONTINGENCY PLANNING, BACKUP, AND DISASTER RECOVERY

C.  Service Continuity

Condition:  OMM did not have an effective means of recovering or
continuing critical TIMS functions and operations in the event of
a system failure or a disaster.  Specifically, we found that:

- The Gulf of Mexico Region's April 1996 Continuity of Operations
Plan had not been tested to ensure that the planned procedures
for recovering TIMS and other business functions were feasible.

- Although Gulf of Mexico regional management had developed a
draft plan, dated September 1999, neither the draft plan nor the
April 1996 plan included recovering critical TIMS development and
maintenance functions of OMM's Information Technology Division.

- Regional personnel responsible for continuing critical
functions in the event of a disaster or an emergency were not
trained in their roles and responsibilities described in the
Continuity of Operations Plan.  

- A copy of the Plan was not available at the designated off-site
storage facility.

- Neither regional nor Information Technology Division personnel
ensured that backup tapes of critical TIMS data and applications
were routinely transferred to the off-site storage facility.  

Criteria:  Appendix III of Circular A-130 requires agencies to
establish controls to safeguard all information processed,
transmitted, or stored in Federal automated information systems.
Further, the Circular requires agencies to establish a
contingency plan and periodically test the plan for the
capability to perform the agency function supported by the
application in the event of failure of its automated support.  In
addition, NIST Special Publication 800-12, "An Introduction to
Computer Security:  The NIST Handbook," recognizes that the
success of recovering all information systems operations and data
is largely dependent upon the adequacy of contingency planning,
including backup and recovery procedures and testing of the
plans; requires that personnel be trained in their
contingency-related duties; and requires that contingency plans
be stored in a safe place.  The Department of the Interior's
"Automated Information Systems Security Handbook" and the MMS
Manual mandate routine cyclical off-site storage for all
automated information systems data and applications providing
critical support to the organization's mission.

Cause:  OMM information technology officials did not ensure that
adequate service continuity controls were in place for critical
TIMS functions and operations to continue without undue
interruption if unexpected events occurred, such as a system
failure.  In addition, OMM management did not ensure that
critical and sensitive TIMS application components and data were
protected by being stored off-site on a routine cyclical basis.

Effect:  In the event of a disaster or a system failure, OMM was
at risk of not being  sufficiently prepared to recover critical
TIMS functions and continue critical operations.

Recommendations

We recommend that the Director of MMS:

1.  Develop a Continuity of Operations Plan for the Offshore
Minerals Management Information Technology Division, which
includes procedures for recovery of the Division's critical TIMS
functions.

2.  Periodically test the Continuity of Operations Plan and
update the Plan based on the test results.

3.  Ensure that copies of the Continuity of Operations Plan are
maintained at the off-site facility.

4.  Ensure that backup copies of TIMS applications, components,
and data are stored at the off-site storage facility on a routine
cyclical basis.  

5.  Provide training to OMM personnel who are responsible for the
recovery of critical TIMS business functions and operations about
their roles and responsibilities related to the Continuity of
Operations Plan.


SYSTEM ACCESS CONTROLS

D.  User Access

Condition:  OMM did not adequately control access to TIMS
databases.  Specifically, employees who were no longer employed
by MMS still had access to TIMS.  For example, we found that 28
percent of employees who had terminated their employment still
had access to the TIMS Gulf of Mexico regional production
database; 6 percent of departed employees, including the prior
Database Administrator, had access to the TIMS development
database; and 13 percent of departed employees had access to the
TIMS Customer User Acceptance Team, the testing database.  In
addition, 798 users had access to the Customer User Acceptance
Team's database when there were only 79 team members who were
authorized to access the database.

Criteria:  NIST's Special Publication 800-14, "Generally Accepted
Principles and Practices for Securing Information Technology
Systems," states:

It is necessary to periodically review user account management on
a system.  Reviews should examine the levels of access each
individual has, conformity with the concept of least privilege,
whether all accounts are still active, [and] whether management
authorizations are up-to-date.

Cause:  OMM Gulf of Mexico regional and Information Technology
Division officials did not ensure that controls were in place to
delete employee access to TIMS when employees departed the
organization.

Effect:  As a result, the risk was significantly increased that
unauthorized users could gain access to sensitive and
mission-critical TIMS data and applications.

Recommendations

We recommend that the Director of MMS:

1.  Implement controls to ensure that access to TIMS for
employees who have terminated employment is removed in a timely
manner.

2.  Ensure that access to the Customer User Acceptance Team
database is limited to authorized users.


E.  Number of Log-In Attempts

Condition:  OMM's number of unsuccessful log-in attempts to
access TIMS exceeded the standard established by the Department
of the Interior.  Specifically, TIMS users were allowed six
unsuccessful log-in attempts before the user was locked out of
the system.

Criteria:  The Department's "Automated Information Systems
Security Handbook" specifies three as the number of unsuccessful
log-in attempts.

Cause:  OMM information technology officials did not ensure that
the number of allowed unsuccessful log-in attempts was
established in accordance with Departmental standards.  OMM
information officials stated that log-in attempt policies were
set using the default settings recommended by the software vendor
and the defaults set by the Royalty Management Program.  However,
security management officials of the Royalty Management Program
had requested and were granted a waiver to deviate from the
Departmental standard by the Department's Office of Information
Resources Management.  

Effect:  As a result, the increased number of invalid attempts
reduced the effectiveness of the password as an access control.
In addition, the risk was increased for unauthorized access to
sensitive TIMS data.

Recommendation

We recommend that the Director of MMS evaluate the risk involved
in deviating from the Department of the Interior standard for the
number of unsuccessful log-in attempts. If the Director
determines that the number of invalid attempts should remain at
six, OMM management should request a waiver from the Department
to deviate from the standard of three attempts.


F.  Password Management

Condition:  The password controls established by OMM in the
Windows NT operating system allowed all system users to retain
passwords indefinitely, even though the system required users to
change their passwords after 90 days.  The controls did not
require that a password history be maintained, and the controls
allowed users to change their passwords consecutively until the
original password could be reused.  

Criteria:  The security of a password system is dependent upon
keeping passwords secret.  NIST Federal Information Processing
Standards Publication 112, "Password Usage," states that
passwords "should be changed periodically with a maximum interval
selected by the Security Officer."  The Publication further
states that the system "should check that the new password is not
the same as the previous password" or any number of previous
passwords and maintain a history of the passwords of each user.

Cause:  OMM information technology officials did not change
Windows NT password default settings to ensure that passwords
were not reused or cycled through quickly.

Effect:  As a result, the risk was increased that a password
could be discovered and used to obtain improper access to TIMS.

Recommendation

We recommend that the Director of MMS implement controls to
ensure that system software settings are established to prevent
users from reusing passwords or cycling through passwords
quickly.


SOFTWARE DEVELOPMENT AND CHANGE MANAGEMENT

G.  Software Change Request and Approval Process

Condition:  At the Gulf of Mexico Region, formal software change
control procedures had been developed and implemented for the
ongoing support and maintenance of TIMS.  However, we found that
OMM Information Technology Division personnel did not ensure that
change requests were received from authorized users; that the
changes were coordinated among all the OMM regions; and that all
changes were reviewed, approved, and prioritized by the OMM
Maintenance Change Board.  During October 1998 through June 1999,
there were 1,157 change requests for TIMS, of which we
statistically selected 132 changes[1] to determine the adequacy
of the change management process. We found that of the 132
sampled change requests, 24 change requests (19 percent) were not
submitted by an authorized user representative and 130 change
requests (98 percent) were not coordinated with user
representatives in the other three OMM regions.  We also found no
documentation to support that the changes had been reviewed and
prioritized by the Maintenance Change Board.   

Criteria:  NIST Federal Information Processing Standards
Publication 106, "Guideline on Software Maintenance," prescribes
guidelines for maintaining software.  According to the
Publication, the primary purpose of change control (or change
management) is to ensure smooth operational continuity and
orderly evolution of the system.  Effective change controls are
needed to ensure that all software installations are performed in
a structured and controlled manner and provide management with a
chronological history of all software modifications.  Key change
management control points ensure that all changes to hardware and
software are formally requested, approved, and documented.  In
addition, the Publication states that "there should be a
centralized approval point for all software maintenance
projects."  Also, the "TIMS Methodology Handbook" states that
Customer User Acceptance Team "leaders in the regions [should]
coordinate program changes and issues among themselves before
submitting a written request to the Information Technology
Division."  In addition, the Handbook requires the Maintenance
Change Board to review and prioritize software change requests.

Cause:  Division personnel did not enforce OMM policies and
procedures that required change requests to be accepted from
Customer User Acceptance Team leaders only, to be coordinated
among the OMM regions, and to be reviewed and prioritized. 

Effect:  As a result, the risk is increased that operational
problems will be introduced into the TIMS production environment.
Because change requests result in changes to the TIMS production
environment and implemented in all OMM regions, the lack of
controlling and coordinating change requests among the Customer
User Acceptance Team leaders could result in changes being made
for one region that affect another region's ability to access and
process transactions efficiently and effectively. Further, the
resultant errors and production problems could be time-consuming
and difficult to diagnose and correct. Additionally, without
reviews and prioritization of change requests, there is little
assurance that the most critical changes will be implemented
first.

Recommendations

We recommend that the Director of MMS:

1.  Enforce TIMS change control policies and procedures to ensure
that all modifications are properly coordinated, authorized,
approved, reviewed, and prioritized.

2.  Evaluate the current policy for submitting changes to TIMS
and determine whether the number of authorized persons who submit
software changes can be reduced.

**FOOTNOTES**

[1]:Although we selected 132 change requests for review, we did
not review all of the requests for specific attributes because
some of the requests selected were canceled or were not completed
at the time of our review.


SOFTWARE DEVELOPMENT AND CHANGE MANAGEMENT

H.  Testing

Condition:  Testing and documentation of software changes to TIMS
were not adequate.  Specifically, we found that, of the108
changes tested, 62 changes (57 percent) did not have test plans.
In addition, 24 (24 percent) of 100 changes were not tested by
either the quality assurance group or the user group (see
footnote 1 in Finding G). 

Criteria:  Publication 106 states that testing standards and
procedures "should define the degree and depth of testing to be
performed and the disposition of test materials upon successful
completion of the testing."  Also, the Publication states that
testing is a critical component of software maintenance and that
test plans should define the expected output of a test and test
for valid, invalid, expected, and unexpected cases.  In addition,
the "TIMS Methodology Handbook" states that test plans are to be
developed and kept current for each of the TIMS components.  Test
plans also became required documentation in 1998.

Cause:  Although OMM had policies and procedures for software
development and change management, OMM management did not ensure
that the software change policies and procedures were complied
with.

Effect:  As a result, the risk was increased that processing
irregularities or malicious codes could be introduced, sensitive
data could lack integrity, and TIMS applications may not function
to meet user requirements.

Recommendation

We recommend that the Director of MMS enforce its policies and
procedures for developing test plans, testing software changes,
and documenting test results for all changes made to TIMS.



APPENDIX 2 

COMPONENTS OF TECHNICAL
INFORMATION MANAGEMENT SYSTEM

Adjudication Tracking System (ATS)
Block and Boundary
Supplemental Bonding
Certs
Civil Penalty
Company and Bonding
Element Data Dictionary
Environmental: Coris
Environmental: Physical
Environmental: Social
Events
Form Navigation
Geologic
Inspections
Lease Administration
Lease Status
Lease Suspensions
Meters
Oil Spill Financial Responsibility
Performance review
Pipelines
Plans
Platforms
Post Sale
Presale
Production
Public Information
Rate Control
Reserves
Rigs
Royalty Relief
Sale
Sampling
Security
Seismic
TIMS Methodology
TIMS Shared
TIMS Support library
Tract Evaluation
Units
Wells



APPENDIX 3
Page 1 of 8

United States Department of the Interior	
		MINERALS MANAGEMENT SERVICE
        	Washington, DC 20240	

JUL 19 2000

Memorandum

To:       Assistant Inspector General for Audits

Through:  Sylvia V. Baca
          Assistant Secretary, Land and Minerals Management

From:     Walt Rosenbusch 
	      Director, Minerals Management Service

Subject:  Office of Inspector General Draft Audit Report,
          "General and Application Controls Over the Technical
          Information Management System, Offshore Minerals
          Management, Minerals Management Service"
          [A-IN-MMS-001-99-R]

Thank you for the opportunity to respond to the draft audit
report on our Technical Information Management System. We are
providing to you our general comments on the audit findings and
specific ones on the recommendations. We agree with all 15
recommendations and are in the process of implementing them.

Please contact Bettine Montgomery at (202) 208-3976 if you have
any further questions.

Attachment



Page 2 of 8

Minerals Service Response to Draft Audit Report
"General and Application Controls System"

Audit Agency:  Office of Inspector General

Report Number:  A-IN-MMS-001-99-R (May 2000)

GENERAL COMMENTS

We appreciate the opportunity to review and comment on the Of
lice of Inspector General's draft audit report referenced here.
Overall, we believe this was a fair evaluation of the Technical
Information Management System in our New Orleans Office.. We
concur with all the recommendations provided in the report. We
will respond to each of the eight weaknesses identified by
providing (1) how we have already addressed improving the
controls over TIMS, (2) how we plan to address improving the
controls that are not currently in place, or (3) information in
support of the controls we have in place, and therefore challenge
the findings of the GIG.

COMMENTS ON WEAKNESSES AND RECOMMENDATIONS

A. Computer Security Plan: MMS had not developed a security plan
for TIMS, which has been identified by MMS as a sensitive and
mission critical system.

Recommendation A1. We recommend that the Director of MMS ensure
that a computer security plan for TIMS is developed, implemented,
and monitored in accordance with the United States Code, Of flee
of Management and Budget Circular Aï¿½130, and National Institute
of Standards and Technology guidelines.

Response: AGREE - MMS has identified TIMS as a sensitive and
mission critical system. Because of this designation, the
Offshore Minerals Management Program had a drain security plan
that was provided to the GIG Auditor. This plan was in addition
to the TIMS Y2K document addressed in the Report. We agree that
our plan did not meet the statutory requirements for a security
plan. During the audit, OMM began the development of a plan to
meet the requirements addressed in OMB Circular A-130, Appendix
m, and NIST Specia Publication 800-18.

The responsible official is the Chief, Information Technology
Division

Target Date: We plan to have a draft document prepared for review
by the end of October 2000 and a final computer security plan
completed by no later than March 2001. By the time the security
plan for TIMS is completed, all OMM users will have been trained
on their security responsibilities in the use of the system.

B. Computer Security Training: Mandatory computer security
awareness training had not been provided to OMM employees and
contractor personnel.

Page 3 of 8

Recommendation B1.Implement policies and procedures to ensure
that OMM employees and contractor personnel who are involved with
sensitive component systems receive annual computer security
awareness training.

Response: AGREE - OMM has not held periodic training as required
by the Computer Security Act of 1987 (P.L.100-235) for "all
employees [and contractors] who are involved with the management,
use, or operation of each Federal computer system within or under
the supervision of that agency." We are in the process of
developing and implementing policies and procedures to ensure
that employees and contractor personnel receive periodic computer
security awareness training. Nowhere in the laws and regulations
did we find that the training is mandatory on an annual basis.
OMM will provide security awareness training for new employees
and contractors within 60 days of working on the OMM systems. All
new employees and contractors must complete a Computer Services
Access Request form prior to receiving an account on the MMS
computer system. This request form includes five security
statements that require the user's signature before the account
is assigned.

OMM has appointed a new security officer and recently hired a
security specialist to develop, implement, and monitor security
policy. These individuals also are charged with the development
and implementation of a computer security awareness training
program for users, systems administrators, and management within
OMM. All OMM employees and contractors will participate in a
security awarenessï¿½training program before the end of Calendar
Year 2000. All employees will have, at a minimum, computer
awareness training every even numbered calendar year. Periodic
security alerts will be sent to all employees on an as needed
basis, or as conditions warrant an update.

Recommendation B2. Ensure that training is documented in the
employee human resources files.

Response: AGREE - OMM will ensure that the computer security
awareness training is documented in the employee's human
resources file.

The responsible official is the Deputy Associate Director for
Offshore Minerals Management.

Target date: We will train all OMM employees and contractors in
computer security awareness by December 2000.

C. Service Continuity: OMM did not have an effective means of
recovering or continuing critical TIMS functions and operations
in the event of a system failure or a disaster. The Gulf of
Mexico Region's April 1996 Continuity of Operations Plan has not
been tested. The Plan did not include recovering critical TIMS
development and maintenance functions. The Regional personnel
responsible for the Plan had not been trained in their roles and
responsibilities. The Plan was not available at the designated
offsite storage facility. The backup tapes of critical TIMS data
and applications were not routinely transferred to the offsite
storage facility.

Page 4 of 8

Recommendation C1. Develop a Continuity of Operations Plan for
the Offshore Minerals Management Information Technology Division,
which includes procedures for recovery of the Division's critical
TIMS functions.

Response: AGREE - Since the audit was conducted, OMM has
reorganized various functions within the New Orleans Office. We
have moved all TIMS server hardware, development, and Gulf of
Mexico Region production under one management structure. A new
Continuity of Operations Plan has been finalized for the New
Orleans computer center that includes all hardware operations at
that location. The Plan also includes procedures for the recovery
of critical TIMS functions.

Recommendation C2.Periodically test the Continuity of Operations
Plan and update the Plan based on the test results.

Response: AGREE - We plan to test the New Orleans Continuity of
Operations Plan prior to the end of Calendar Year 2000 and on a
regular basis in the future.

Recommendation C3. Ensure that copies of the Continuity of
Operations Plan are maintained at the offsite facility.

Response: AGREE - An updated copy of the Continuity of Operations
Plan can be found in the Headquarters office of the Information
Technology Division and also at a new offsite storage facility in
the New Orleans area.

Recommendation C4. Ensure that backup copies of TIMS
applications, components, and data are stored at the offsite
storage facility on a routine cyclical basis.

Response: AGREE - We have established and implemented new backup
procedures. We also store backup copies of the TIMS applications,
components, and data at the new of[site storage facility in the
New Orleans area. These items are rotated on a routine basis as
defined in the Continuity of Operations Plan. All boxes are
clearly labeled for quick recovery.

Recommendation C5. Provide training to OMM personnel who are
responsible for the recovery of critical TIMS business functions
and operations about their roles and responsibilities related to
the Continuity of Operations Plan.

Response: AGREE = We will train OMM personnel concerning their
roles and responsibilities for the recovery of critical TIMS
business functions and operations.

The responsible official is the Regional Director, Gulf of Mexico
Region.

Target date: Test New Orleans Continuity of Operations Plan by
December 2000.

D. User Access: OMM did not adequately control access to the TIMS
databases. Specifically, employees who were no longer employed by
MMS still had access to the TIMS.

Page 5 of 8

Recommendation D1. Implement controls to ensure that access to
TIMS for employees who have terminated employment is removed in a
timely maimer.

Response: AGREE -When an employee leaves the Bureau, a procedure
is in place to terminate all access to the DIMS and TIMS systems.

Recommendation D2. Ensure that access to the Customer User
Acceptance Team database is limited to authorized users.

Response: AGREE: - We have implemented new procedures to ensure
that access is available only to those who have a need to know
the TIMS information. Procedures have also been put in place to
provide access to only those who have completed a user access
form. The Office of Responsibility must also grant permission
prior to the user having access to the TIMS data. We have
established a database to track user access to the TIMS system.
The same procedures will be followed for all employees requiring
access to the Customer User Acceptance Team database.

The responsible official is the Deputy Associate Director,
Offshore Minerals Management.

Target date: Task Completed.

E. Number of Log-In Attempts: OMM's number of unsuccessful log-in
attempts to access TIMS exceeded the standard established by the
Department of the Interior. Specifically, TIMS users were allowed
six unsuccessful log-in attempts before the user was locked out
of the system.

Recommendation E1. MMS should evaluate the risk involved in
deviating from the Department of the Interior standard for the
number of unsuccessful log-in attempts. If the Director
determines that the number of invalid attempts should remain at
six, OMM management should request a waiver from the Department
to deviate from the standard of three attempts.

Response: AGREE - The number of unsuccessful log-in attempts has
been established at three unsuccessful log-in attempts before the
user is locked out of the system.

The responsible official is the Deputy Associate Director,
Offshore Minerals Management.

Target Date: Task Completed.

F. Password Management: The password controls established by OMM
in the Windows NT operating system allows all system users to
retain passwords indefinitely, even though the system required
users to change their passwords after 90 days. The controls did
not require that a password history be maintained, and the
controls allowed users to change their passwords consecutively
until the original password could be reused.

Page 6 of 8

Recommendation. MMS should implement controls to ensure that
system software settings are established to prevent users from
reusing passwords or cycling through passwords quickly.

Response: AGREE - All NT servers that are supported by OMM and
MMS have the password setting to prevent the reuse or quick
recycling of passwords. These passwords must be changed every 90
days. The Council of Information Management Officials established
this policy on behalf of the Bureau.

The responsible officials are members of the Council of
Information Management Of finials.

Target Date: Task Completed.

G. Software Change Request and Approval Process: At the Gulf of
Mexico Region, formal software change control procedures had been
developed and implemented for the ongoing support and maintenance
of TIMS. However, we found that OMM Information Technology
Division personnel did not ensure that change requests were
received from authorized users; that the changes were coordinated
among all the OMM regions; and that all changes were reviewed,
approved, and prioritized by the OMM Maintenance Change Board. We
also found no documentation to support that the changes had been
reviewed and prioritized by the Maintenance Change Board.

Recommendation G1. Enforce TIMS change control policies and
procedures to ensure that all modifications are properly
coordinated, authorized, approved, reviewed, and prioritized.

Response: AGREE: - The Information Technology Division has not
been in the position to reject the TIMS maintenance and/or
enhancement change requests submitted by the program of rice. In
the early development of TIMS, OMM established the Component User
Acceptance Team leader concept for each major subject area of
TIMS to be the focal point for ongoing program changes. The Teams
are responsible for the program view and coordination of their
respective components. The Information Technology Division
implemented the change requests as submitted.

To deal with the large number of change requests, the TIMS
Project Office established a Change Control Group (called
Maintenance Change Board in the Report). The Information
Technology analyst who knew the design and was responsible for
the maintenance of the TIMS components was a member of this
Group. The TIMS Maintenance Methodology states that all requests
will be reviewed and prioritized, and deadlines will be set for
implementation. All change requests are entered into the tracking
system called Defect Control System. The Change Control Group
reviewed all outstanding work requests in the Defect Control
System and made assignments to the staff, weekly. The tracking of
the request in the Defect Control System was the documentation.

The OMM Information Technology Division staff did not track nor
collect information in reference to the Component User Acceptance
Team coordinating change requests with peers in other regions.
That is the responsibility of the Team leader. Upon completion of
a work

Page 7 of 8

request of the Information Technology Division staff, all
Component User Acceptance Teams for that component were notified
by the Information Technology Division that the work request was
completed. The module was then ready for testing prior to final
deployment to all OMM sites.

In October 1999, the Information Management Committee determined
that it needed to better manage the change control policies and
procedures. The Committee authorized the creation of a new TIMS
Change Control Board. The Board is comprised of representatives
from the OMM program of rices and Chaired by the Deputy Regional
Director of the Gulf of Mexico Region. The purpose of the Change
Control Board is to review, monitor, evaluate, approve/
disapprove, and prioritize all enhancement and maintenance
requests (submitted by the TIMS users) for current TIMS
components. The Board will also review usage of the TIMS forms
and reports and eliminate unused or underutilized and
nonï¿½critical forms and reports.

With the development of this Board, all programmatic changes,
corrections, amendments, reforms, improvements, enhancements, or
upgrades made to the TIMS components are reviewed,
approved/disapproved, and prioritized. This review also entails
an evaluation of the potential costs and benefits of proposed
changes.

Recommendation G2. Evaluate the current policy for submitting
changes to TIMS and determine whether the number of authorized
persons who submit software changes can be reduced.

Response: AGREE - The Change Control Board is not only
responsible for enforcing the change control policies and
procedures, but also controls the number of changes that can be
made to the system. The Information Technology Division is in the
final stage of implementing a replacement for the work request
tracking system known as Defect Control System. The new software
system is a commercial off-the-shelf solution called Visual
Interceptor. Interceptor is web based and will only allow
authorized Component User Acceptance Teams to forward approved
work requests to the Change Control Board for final review and
prioritization. This new web-based system will be in place by the
end of calendar year 2000.

The responsible official is the Deputy Associate Director for
Offshore Minerals Management.

Target Date: Policy to limit number of persons submitting changes
- Completed. Implementation of request tracking by December 2000.

H. Testing: Testing and documentation of software changes to TIMS
were not adequate. Specifically, we found that, of the 108
changes tested, 62 changes (57 percent) did not have test plans.
In addition, either the quality assurance group or the user group
did not test 24 of 100 (24 percent) changes.

Recommendation H1. MMS should enforce its policies and procedures
for developing test plans, testing software changes, and
documenting test results for all changes made to TIMS.

Page 8 of 8

Response: AGREE - We agree with the recommendation made in the
report that OMM should enforce the TIMS Maintenance Methodology
policies and procedures related to testing and its documentation.
We do not agree with the analysis that drew the auditors to their
recommendations. Based on our analysis of the full 132 sample
set, our findings are different from the auditor. Specifically,
of the 62 changes (57 percent) that did not have individual test
plans, OMM determined 59 changes to be exceptions that did not
require test plans. Although the TIMS Maintenance Methodology
requires test plans, there are certain changes that are
considered routine and/or minor and, therefore, would not require
individual test plans. These exceptions include reports (41); and
system administration functions, database triggers, packages, and
menu change requests (18). Therefore, OMM found that only 3 of
the 62 changes should have had test plans based on the TIMS
Maintenance Methodology. Reports are covered by a generic test
plan since they are fairly simple and do not require individual
test plans.

In addition, we concur that the quality assurance or the user
group did not test 24 of 100 changes. We determined that there
were 20 exceptions to these changes. These exceptions included
data dictionary, domain value, or menu changes. The Database
Administrator makes these changes and, upon completion, the
Component User Acceptance Team members or an analyst tests the
change. We conclude that there were only four changes that were
not tested before they were put on the production machine.
Therefore, the quality assurance group or the user group did not
test only 4 percent of the changes.

The Information Technology Division is converting to a new change
control tracking system, called Visual Interceptor, that will
better serve our customers with online web access to the status
of all change requests. We will properly identify all stages of
the life cycle of a change request. This new system should be
fully operational by the end of the calendar year 2000. A change
request can be submitted for many Information Technology
functions, not just a change to a TIMS program.

We recognize the need for test plans and for adequate testing of
the changes, and we plan to continue this process. We also have
tightened up and enforced the policies and procedures we have in
place. There are numerous exceptions and alternative test
procedures that accompany the change management. These exceptions
need to be further identified in our TIMS Maintenance
Methodology. We will continue our review of existing methodology
to expand testing and acceptance criteria to improve the process.
Documentation will occur through the implementation of the new
change control tracking system.

The responsible official is the Deputy Associate Director for
Offshore Minerals Management.

Target Date: Enforcement of required test plans and testing -
Completed. Implementation of request tracking by December 2000.



APPENDIX 4

STATUS OF AUDIT REPORT RECOMMENDATIONS

Finding/Recommendation
Reference              Status              Actions Required
A.1, B.1, B.2, C.2,
C.5, G.2, and H.1      Resolved; not 
                       implemented.
                                         No further response to 
                                         the Office of Inspector
                                         General is required. The
                                         recommendations will be
                                         forwarded to the
                                         Assistant Secretary for
                                         Policy, Management and
                                         Budget for tracking of
                                         implementation.


C.1, C.3, C.4, D.1, D.2,
E.1, F.1, and G.1
                        Implemented.      No further response is
                                          required.






ILLEGAL OR WASTEFUL ACTIVITIES

SHOULD BE REPORTED TO

THE OFFICE OF INSPECTOR GENERAL 


Internet/E-Mail Address
www.oig.doi.gov



Within the Continental United States

U.S. Department of the Interior
Office of Inspector General
1849 C Street, N.W.                  
Mail Stop 5341
Washington, D.C. 20240 


Our 24-hour
Telephone HOTLINE
1-800-424-5081 or
(202) 208-5300


TDD for hearing impaired
(202) 208-2420  



Outside the Continental United States


Caribbean Region

U.S. Department of the Interior 
Office of Inspector General
Eastern Division - Investigations
4040 Fairfax Drive
Suite 303
Arlington, Virginia 22203

(703) 235-9221



Pacific Region

U.S. Department of the Interior 
Office of Inspector General
Guam Field Office 
415 Chalan San Antonio
Baltej Pavilion, Suite 306
Tamuning, Guam 96911

(671) 647-6060