OIG 2014 Evaluation of the

Farm Credit Administration’s

Compliance with the

Federal Information Security 

Management Act

November 14, 2013

OFFICE OF Report of Evaluation

INSPECTOR GENERAL 

OIG 2014 Evaluation of the 

Farm Credit Administration’s 

Compliance with the 

Federal Information Security 

Management Act 

November 14, 2014 

E-14-01 

Tammy Rapp 

Auditor-in-Charge 

FARM CREDIT ADMINISTRATION
 
 

 

 

 

     

                       

             

   

       

  

                       

                             

                 

                            

                 

                             

                                 

                               

               

                              

                           

     

   

Memorandum	 Office of Inspector General 

1501 Farm Credit Drive 

McLean, Virginia 22102-5090 

November 14, 2014

The Honorable Jill Long Thompson, Board Chair and Chief Executive Officer

The Honorable Kenneth A. Spearman, Board Member

The Honorable Leland A. Strom, Board Member

Farm Credit Administration

1501 Farm Credit Drive

McLean, Virginia 22102‐5090

Dear Board Chair Long Thompson and FCA Board Members Spearman and Strom:

The Office of the Inspector General (OIG) completed the 2014 independent evaluation of the Farm

Credit Administration’s compliance with the Federal Information Security Management Act

(FISMA). The objectives of this evaluation were to perform an independent assessment of FCA’s

information security program and assess FCA’s compliance with FISMA.

The results of our evaluation revealed that FCA has an information security program that continues

to mature. Of the 11 areasthe Office of Management and Budget required OIGsto evaluate during

2014, FCA established a program in 10 of the areas. We identified 1 area, Continuous Monitoring,

where the Agency agreed to make improvements.

We appreciate the courtesies and professionalism extended to the evaluation staff. If you have any

questions about this evaluation, I would be pleased to meet with you at your convenience.

Respectfully, 

Elizabeth M. Dean

Inspector General
Office of InspectorGeneral (OIG) Evalua

FISMA 2014

Table of ContentsExecutive Summary..............................................................................................................................................

Introduction and Background..............................................................................................................................Areas Evaluated by the Office of Inspector General during Fiscal Year 2014: 

Continuous Monitoring Management ..............................................................................................................Configuration Management ..............................................................................................................................Identity and Access Management ....................................................................................................................

Incident Response and Reporting ...................................................................................................................Risk Management ..............................................................................................................................................Security Training ...............................................................................................................................................

Plans of Action & Milestones (POA&M) ..........................................................................................................

Remote Access Management ...........................................................................................................................Contingency Planning ......................................................................................................................................Contractor Systems ..........................................................................................................................................Security Capital Planning .................................................................................................................................

Appendix A: OIG Section Report in CyberScope Appendix B: Objectives, Scope, and Methodology 
Executive Summary

The Farm Credit Administration (FCA or Agency) has an information securitcontinues to mature and contains the following elements: 

 Information security policies and procedures  Risk based approach to information security  Continuous monitoring  Standard baseline configurations  Identity and access management program  Incident response program  Risk based security controls  Security authorization process  Security awareness and training program  Corrective action for significant information security weaknesses  Remote access controls  Continuity of operations plan and tests  Oversight of contractor systems  Capital planning and investment process that incorporates information secur

Farm Credit Administration Office of Inspector General (OIG)OIG Evaluation of the Farm Credit Administration’s Compliance with the Federal Information Security Management Act (F

Report #E‐14‐01
Executive Summary

 FCA’s Chief Information Officer (CIO) and experienced IT team are proa

approach to information security. 

 The IT team and system sponsors were responsive to suggestions mad

improvement during the FISMA evaluation and, in many cases, the IT stimmediate changes to strengthen the information security program. 

 Of the 11 areas Office of Management and Budget (OMB) required OIG

during 2014, FCA established a program in 10 of the areas that is consiNational Institute of Standards and Technology’s (NIST) and OMB’s guid

 We identified one area where improvements need to be made which res

agreed-upon action: 

1. Continuous monitoring (see pages 4-5) 

Farm Credit Administration Office of Inspector General (OIG)OIG Evaluation of the Farm Credit Administration’s Compliance with the Federal Information Security Management Act (F

Report #E‐14‐01
Introduction and Background

 The President signed into law the E-Government Act (Public Law 107-3

includes Title III, Information Security, on December 17, 2002. 

 Title III permanently reauthorized the Government Information Security Refo

and renamed it the Federal Information Security Management Act (FISMA) o

 The purpose of FISMA was to strengthen the security of the Federal governm

information systems and develop minimum standards for agency systems. 

 FISMA requires an agency’s CIO and OIG to conduct annual assessme

agency’s information security program.

 OMB issued Memorandum M-15-01 with reporting instructions for comp

FISMA’s annual reporting requirements and reporting on the agency’s pmanagement program. Results of the CIO and OIG assessments are reOMB through CyberScope. 

 Appendix A contains the IG Section Report as submitted to OMB throug

 Appendix B describes the objectives, scope, and methodology used for 

evaluation.

Farm Credit Administration Office of Inspector General (OIG)OIG Evaluation of the Farm Credit Administration’s Compliance with the Federal Information Security Management Act (F

Report #E‐14‐01
Continuous Monitoring Management

The Agency is in the process of developing an enterprise-wide continuous mprogram that assesses the security state of information systems that is consFISMA requirements, OMB policy, and applicable NIST guidelines. OMB M-15-01 and M-14-03 require agencies to develop and maintain an insecurity continuous monitoring (ISCM) strategy and establish an ISCM progFCA’s continuous monitoring program currently includes the following attribu

 Continuous monitoring of controls at identified monitoring frequencies define

infrastructure security plan 

 Malicious code protection  Vulnerability scanning  Log monitoring  Notification of unauthorized devices  Notification of changes or additions to sensitive accounts  Ongoing monitoring of security alerts and updates from vendors and approp Commitment to annual independent penetration test and resolving identified 

quickly as possible 

 Commitment to periodic security tests and evaluations of major systems 

Farm Credit Administration Office of Inspector General (OIG)OIG Evaluation of the Farm Credit Administration’s Compliance with the Federal Information Security Management Act (F

Report #E‐14‐01
However, FCA is in the process of developing an overarching enterprise-wid

its continuous monitoring program. The requirements and expectations for c

monitoring programs continue to evolve. FCA is monitoring progress in this to incorporate best practices implemented by other small agencies. Agreed-upon Action: 

1. The Office of Management Services (OMS) agreed to define, document, and imp

enterprise-wide information security continuous monitoring program consistent wand NIST guidelines. 

Farm Credit Administration Office of Inspector General (OIG)OIG Evaluation of the Farm Credit Administration’s Compliance with the Federal Information Security Management Act (F

Report #E‐14‐01
Configuration Management

The Agency established and maintains a configuration management prograconsistent with FISMA requirements, OMB policy, and applicable NIST guidFCA’s security configuration management program includes the following at

 Documented policies and procedures for configuration management  Standard baseline configuration for workstations and servers  Implementation of the United States Government Configuration Baseline (US

 Regular scanning of servers for vulnerabilities and compliance within the ba

configuration 

 Controls to prevent unauthorized software  Controls to prevent unauthorized devices  Timely remediation of identified vulnerabilities  Process for timely and secure installation of software patches  Monitoring and analysis of critical security alerts to determine potential impa

systems 

Farm Credit Administration Office of Inspector General (OIG)OIG Evaluation of the Farm Credit Administration’s Compliance with the Federal Information Security Management Act (F

Report #E‐14‐01
Identity andAccess Management

The Agency established and maintains an identity and access management is consistent with FISMA requirements, OMB policy, and applicable NIST guThe account and identity management program identifies users and networincludes the following attributes: 

 Documented policies and procedures for requesting, issuing, changing, and 

information system accounts 

 Identifies and authenticates information system users before allowing acces Detects unauthorized devices and disables connectivity  Dual-factor authentication  Strengthened controls over use of elevated privileges  Information system accounts created, managed, monitored, and disabled by 

personnel 

 Periodic review of information system accounts to ensure access permission

users are current and appropriate 

 Controls to prevent, detect, or notify authorized personnel of suspicious acco

devices 

OMS performed an annual review of permissions to a major application as a agreed-upon action in the 2013 FISMA evaluation. The purpose of the annuensure access is limited to authorized users. 

Farm Credit Administration Office of Inspector General (OIG)OIG Evaluation of the Farm Credit Administration’s Compliance with the Federal Information Security Management Act (F

Report #E‐14‐01
Incident Response and Reporting

The Agency established and maintains an incident response and reporting pconsistent with FISMA requirements, OMB policy, and applicable NIST guidThe incident response and reporting program includes the following attribute

 Documented policies and procedures  Security awareness training and articles  A 24 hour Helpline available to employees needing incident assistance  A requirement that agency staff report within one hour to the OMS Helpline a

equipment, personally identifiable information (PII), or sensitive information tto be missing, lost, or stolen 

 During FY 2014, FCA had the following types of incidents: 

▪ Malware on laptops ▪ Phishing email attempts ▪ Misplaced or lost HSPD12 cards and smart phones (some lost phones and cards ▪ A laptop that was lost during shipping and later recovered 

 Analysis was performed for each incident before responding appropriately a

minimize further damage 

 A log was maintained of security incidents, and appropriate officials were no

on the nature of the incident 

Farm Credit Administration Office of Inspector General (OIG)OIG Evaluation of the Farm Credit Administration’s Compliance with the Federal Information Security Management Act (F

Report #E‐14‐01
Risk Management

FCA established and maintains a risk management program that is consisterequirements, OMB policy, and applicable NIST guidelines. The risk management program includes the following attributes: 

 Addresses risk from organization, mission, business, and information system  Information systems categorized based on Federal Information Processing S

Publications 199 and Special Publications (SP) 800-60 

 Security plans based on risk that identify minimum baseline controls selecte

and implemented 

 Periodic assessments of controls through a combination of continuous moni

assessments, independent penetration tests, and independent security tests 

 Authorizing official considers risk of items identified during the certification p

signing the “Authorization to Operate” 

 Regular communications with senior management 

Farm Credit Administration Office of Inspector General (OIG)OIG Evaluation of the Farm Credit Administration’s Compliance with the Federal Information Security Management Act (F

Report #E‐14‐01
SecurityTraining

The Agency established and maintains a security training program that is coFISMA requirements, OMB policy, and applicable NIST guidelines. The security training program includes the following attributes: 

 Mandatory annual security awareness training for employees and contractor

group sessions: 

▪ Cyber security and how it affects FCA ▪ Protecting PII and sensitive information ▪ Use of the internet, e-mail, and FCA network ▪ Signs your computer has been compromised and steps to take ▪ Standardized hardware and software 

 Security training meeting with new employees  New employees and contractors required to certify they have read and unde

computer security policies and responsibilities after briefing by the IT Securit

 Ongoing awareness program that includes e-mails and news alerts with sec

notices of new threats 

 Specialized training required for users with significant security responsibilitie

 Identification and tracking of mandatory security training 

Farm Credit Administration Office of Inspector General (OIG)OIG Evaluation of the Farm Credit Administration’s Compliance with the Federal Information Security Management Act (F

Report #E‐14‐01
Plans ofAction & Milestones (POA&M)

The Agency established and maintains a POA&M program that is consistenrequirements, OMB policy, and applicable NIST guidelines. The POA&M program tracks and monitors known information security weakincludes the following attributes: 

 Policy for developing plans of action and milestones  Process for developing plans of corrective action for significant information s

weaknesses and tracking their implementation 

 Compensating controls until outstanding items are remediated 

Farm Credit Administration Office of Inspector General (OIG)OIG Evaluation of the Farm Credit Administration’s Compliance with the Federal Information Security Management Act (F

Report #E‐14‐01
RemoteAccess Management

The Agency established and maintains a remote access program that is conFISMA requirements, OMB policy, and applicable NIST guidelines. The remote access program includes the following attributes: 

 Policies and procedures for authorizing, monitoring, and controlling all metho

access 

 Protection against unauthorized connections  Virtual private network (VPN) for secure encrypted transmission of data outs

Agency’s network 

 Encryption on local hard drives and USB drives to protect sensitive data and  Forced encryption when creating CDs and DVDs  Security policy and device management for Agency smart phones and autho

devices 

 Remote contractor access for diagnostic purposes tightly controlled and clos

by IT staff 

Farm Credit Administration Office of Inspector General (OIG)OIG Evaluation of the Farm Credit Administration’s Compliance with the Federal Information Security Management Act (F

Report #E‐14‐01
Contingency Planning

The Agency established and maintains an enterprise-wide business continurecovery program that is consistent with FISMA requirements, OMB policy, NIST guidelines. The contingency planning program includes the following attributes: 

 Business continuity plan and disaster recovery plan periodically updated to s

restoration of essential operations and systems after a disruption or failure 

 Alternative processing site with essential systems successfully activated dur

government wide test 

 Backup strategy includes daily and weekly backups of data and systems  Off-site storage and encryption for backups  Disaster recovery documentation maintained offsite that contains critical soft

procedures needed to recreate systems 

 Employee notification system used to alert employees of office closings and 

Farm Credit Administration Office of Inspector General (OIG)OIG Evaluation of the Farm Credit Administration’s Compliance with the Federal Information Security Management Act (F

Report #E‐14‐01
Contractor Systems

The Agency established and maintains a program to oversee systems operabehalf by contractors or other entities, including Agency systems and servicthe cloud external to the Agency. The contractor system oversight program includes the following attributes: 

 Written agreements for contractor systems and interconnections  Updated inventory of contractor systems and interconnections  Security plans for contractor systems reviewed and updated annually  Due diligence reviews performed and security controls monitored for the out

financial, payroll, and personnel systems 

 Site visits to review security documentation and verify financial system provi

adequate security measures to protect data, applications, and services 

 User accounts and privileges periodically reviewed for outsourced financial, 

personnel systems 

OMS strengthened its oversight of an outsourced personnel system as a reagreed-upon action in the 2013 FISMA evaluation. 

Farm Credit Administration Office of Inspector General (OIG)OIG Evaluation of the Farm Credit Administration’s Compliance with the Federal Information Security Management Act (F

Report #E‐14‐01
Security Capital Planning

The Agency established and maintains a security program that is integrated information technology capital planning and investment program. The program includes the following attributes: 

 Policies and procedures that stress importance of information security and p

sensitive information 

 Capital planning and investment process that incorporates information secur

 Enterprise architecture that ensures IT investments support core business fu

provides security standards 

 Information security resources are available as planned 

Farm Credit Administration Office of Inspector General (OIG)OIG Evaluation of the Farm Credit Administration’s Compliance with the Federal Information Security Management Act (F

Report #E‐14‐01
AppendixA: OIG Section Report in Cybe
Inspector General 2014

Annual FISMA

Section Report Report

Farm Credit Administration

Farm Credit Administration Office of Inspector General (OIG) 

Report #E-14-01 Appendix A 
Section 1: Continuous Monitoring Management

1.1 Has the organization established an enterprise-wide continuous monitoring program that assesses the security state of information systems 

that is consistent with FISMA requirements, OMB policy, and applicable NIST guidelines? Besides the improvement opportunities that may 

have been identified by the OIG, does the program include the following attributes?

No

Comments: The Agency is in the process of developing an enterprise-wide continuous monitoring program that assesses the security state of 

information systems that is consistent with FISMA requirements, OMB policy, and applicable NIST guidelines. The requirements and 

expectations for continuous monitoring programs continue to evolve. FCA is monitoring progress in this area and plans to incorporate 

best practices implemented by other small agencies.

1.1.1 Documented policies and procedures for continuous monitoring (NIST SP 800-53: CA-7).

Yes

1.1.2 Documented strategy for information security continuous monitoring (ISCM).

No

1.1.3 Implemented ISCM for information technology assets.

No

1.1.4 Evaluate risk assessments used to develop their ISCM strategy.

No

1.1.5 Conduct and report on ISCM results in accordance with their ISCM strategy.

No

1.1.6 Ongoing assessments of security controls (system-specific, hybrid, and common) that have been performed based on the approved 

continuous monitoring plans (NIST SP 800-53, 800-53A).

No

1.1.7 Provides authorizing officials and other key system officials with security status reports covering updates to security plans and security 

assessment reports, as well as a common and consistent POA&M program that is updated with the frequency defined in the strategy 

and/or plans (NIST SP 800-53, 800-53A).

Yes

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Report #E-14-01 Appendix A 
Section 1: Continuous Monitoring Management

.2 Please provide any additional information on the effectiveness of the organization’s Continuous Monitoring Management Program that was 

not noted in the questions above.

n/a

ection 2: Configuration Management

.1 Has the organization established a security configuration management program that is consistent with FISMA requirements, OMB policy, and 

applicable NIST guidelines? Besides the improvement opportunities that may have been identified by the OIG, does the program include the 

following attributes?

Yes

2.1.1 Documented policies and procedures for configuration management.

Yes

2.1.2 Defined standard baseline configurations.

Yes

2.1.3 Assessments of compliance with baseline configurations.

Yes

2.1.4 Process for timely (as specified in organization policy or standards) remediation of scan result deviations.

Yes

2.1.5 For Windows-based components, USGCB secure configuration settings are fully implemented, and any deviations from USGCB 

baseline settings are fully documented.

Yes

2.1.6 Documented proposed or actual changes to hardware and software configurations.

Yes

2.1.7 Process for timely and secure installation of software patches.

Yes

1

S

2

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Report #E-14-01 Appendix A 
Section 2: Configuration Management

2.1.8 Software assessing (scanning) capabilities are fully implemented (NIST SP 800-53: RA-5, SI-2).

No

Comments: Servers and network devices are periodically scanned for compliance with the baseline configuration. However, a risk based 

decision was made to not implement routine scanning of workstations and printers for compliance with FCA's baseline 

configuration. A cost benefit analysis with consideration of compensating controls was an integral part of the decision.

2.1.9 Configuration-related vulnerabilities, including scan findings, have been remediated in a timely manner, as specified in organization 

policy or standards. (NIST SP 800-53: CM-4, CM-6, RA-5, SI-2)

Yes

2.1.10 Patch management process is fully developed, as specified in organization policy or standards. (NIST SP 800-53: CM-3, SI-2).

Yes

Please provide any additional information on the effectiveness of the organization’s Configuration Management Program that was not noted in 

the questions above.

n/a

Does the organization have an enterprise deviation handling process and is it integrated with the automated capability.

No

2.2

2.3

Comments: Servers and network devices are periodically scanned for compliance with the baseline configuration. However, a risk based decision 

was made to not implement routine scanning of workstations and printers for compliance with FCA's baseline configuration. A cost 

benefit analysis with consideration of compensating controls was an integral part of the decision.

2.3.1 Is there a process for mitigating the risk introduced by those deviations?

Yes

Section 3: Identity and Access Management

3.1 Has the organization established an identity and access management program that is consistent with FISMA requirements, OMB policy, and 

applicable NIST guidelines and identifies users and network devices? Besides the improvement opportunities that have been identified by the 

OIG, does the program include the following attributes?

Yes

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Report #E-14-01 Appendix A 
Section 3: Identity and Access Management

3.1.1 Documented policies and procedures for account and identity management (NIST SP 800-53: AC-1).

Yes

3.1.2 Identifies all users, including Federal employees, contractors, and others who access organization systems (NIST SP 800-53, AC-2).

Yes

3.1.3 Identifies when special access requirements (e.g., multi-factor authentication) are necessary.

Yes

3.1.4 If multi-factor authentication is in use, it is linked to the organization's PIV program where appropriate (NIST SP 800-53, IA-2).

Yes

3.1.5 Organization has planned for implementation of PIV for logical access in accordance with government policies (HSPD 12, FIPS 201, 

OMB M-05-24, OMB M-07-06, OMB M-08-01, OMB M-11-11).

Yes

3.1.6 Organization has adequately planned for implementation of PIV for physical access in accordance with government policies (HSPD 12, 

FIPS 201, OMB M-05-24, OMB M-07-06, OMB M-08-01, OMB M-11-11).

Yes

3.1.7 Ensures that the users are granted access based on needs and separation-of-duties principles.

Yes

3.1.8 Identifies devices with IP addresses that are attached to the network and distinguishes these devices from users (For example: IP 

phones, faxes, and printers are examples of devices attached to the network that are distinguishable from desktops, laptops, or 

servers that have user accounts).

Yes

3.1.9 Identifies all user and non-user accounts. (Refers to user accounts that are on a system. Data user accounts are created to pull generic 

information from a database or a guest/anonymous account for generic login purposes. They are not associated with a single user or a 

specific group of users.)

Yes

3.1.10 Ensures that accounts are terminated or deactivated once access is no longer required.

Yes

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Section 3: Identity and Access Management

3.1.11 Identifies and controls use of shared accounts.

Yes

3.2 Please provide any additional information on the effectiveness of the organization’s Identity and Access Management Program that was not 

noted in the questions above.

n/a

Section 4: Incident Response and Reporting

4.1 Has the organization established an incident response and reporting program that is consistent with FISMA requirements, OMB policy, and 

applicable NIST guidelines? Besides the improvement opportunities that may have been identified by the OIG, does the program include the 

following attributes?

Yes

4.1.1 Documented policies and procedures for detecting, responding to, and reporting incidents (NIST SP 800-53: IR-1).

Yes

4.1.2 Comprehensive analysis, validation and documentation of incidents.

Yes

4.1.3 When applicable, reports to US-CERT within established timeframes (NIST SP 800-53, 800-61, and OMB M-07-16, M-06-19).

Yes

4.1.4 When applicable, reports to law enforcement within established timeframes (NIST SP 800-61).

Yes

4.1.5 Responds to and resolves incidents in a timely manner, as specified in organization policy or standards, to minimize further damage 

(NIST SP 800-53, 800-61, and OMB M-07-16, M-06-19).

Yes

4.1.6 Is capable of tracking and managing risks in a virtual/cloud environment, if applicable.

Yes

4.1.7 Is capable of correlating incidents.

Yes

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Section 4: Incident Response and Reporting

4.1.8 Has sufficient incident monitoring and detection coverage in accordance with government policies (NIST SP 800-53, 800-61; OMB 

M-07-16, M-06-19).

Yes

4.2 Please provide any additional information on the effectiveness of the organization’s Incident Management Program that was not noted in the 

questions above.

n/a

Section 5: Risk Management

5.1 Has the organization established a risk management program that is consistent with FISMA requirements, OMB policy, and applicable NIST 

guidelines? Besides the improvement opportunities that may have been identified by the OIG, does the program include the following 

attributes?

Yes

5.1.1 Documented policies and procedures for risk management, including descriptions of the roles and responsibilities of participants in this 

process.

Yes

5.1.2 Addresses risk from an organization perspective with the development of a comprehensive governance structure and organization-wide 

risk management strategy as described in NIST SP 800-37, Rev.1.

Yes

5.1.3 Addresses risk from a mission and business process perspective and is guided by the risk decisions from an organizational 

perspective, as described in NIST SP 800-37, Rev. 1.

Yes

5.1.4 Addresses risk from an information system perspective and is guided by the risk decisions from an organizational perspective and the 

mission and business perspective, as described in NIST SP 800-37, Rev. 1.

Yes

5.1.5 Has an up-to-date system inventory.

Yes

5.1.6 Categorizes information systems in accordance with government policies.

Yes

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Section 5: Risk Management

5.1.7 Selects an appropriately tailored set of baseline security controls.

Yes

5.1.8 Implements the tailored set of baseline security controls and describes how the controls are employed within the information system 

and its environment of operation.

Yes

5.1.9 Assesses the security controls using appropriate assessment procedures to determine the extent to which the controls are 

implemented correctly, operating as intended, and producing the desired outcome with respect to meeting the security requirements for 

the system.

Yes

5.1.10 Authorizes information system operation based on a determination of the risk to organizational operations and assets, individuals, 

other organizations, and the Nation resulting from the operation of the information system and the decision that this risk is acceptable.

Yes

5.1.11 Ensures information security controls are monitored on an ongoing basis, including assessing control effectiveness, documenting 

changes to the system or its environment of operation, conducting security impact analyses of the associated changes, and reporting 

the security state of the system to designated organizational officials.

Yes

5.1.12 Information-system-specific risks (tactical), mission/business-specific risks, and organizational-level (strategic) risks are 

communicated to appropriate levels of the organization.

Yes

5.1.13 Senior officials are briefed on threat activity on a regular basis by appropriate personnel (e.g., CISO).

Yes

5.1.14 Prescribes the active involvement of information system owners and common control providers, chief information officers, senior 

information security officers, authorizing officials, and other roles as applicable in the ongoing management of 

information-system-related security risks.

Yes

5.1.15 Security authorization package contains system security plan, security assessment report, and POA&M in accordance with 

government policies. (NIST SP 800-18, SP 800-37).

Yes

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Report #E-14-01 Appendix A 
Section 5: Risk Management

5.1.16 Security authorization package contains accreditation boundaries, defined in accordance with government policies, for organization 

information systems.

Yes

5.2 Please provide any additional information on the effectiveness of the organization’s Risk Management Program that was not noted in the 

questions above.

n/a

Section 6: Security Training

6.1 Has the organization established a security training program that is consistent with FISMA requirements, OMB policy, and applicable NIST 

guidelines? Besides the improvement opportunities that may have been identified by the OIG, does the program include the following 

attributes?

Yes

6.1.1 Documented policies and procedures for security awareness training (NIST SP 800-53: AT-1).

Yes

6.1.2 Documented policies and procedures for specialized training for users with significant information security responsibilities.

Yes

6.1.3 Security training content based on the organization and roles, as specified in organization policy or standards.

Yes

6.1.4 Identification and tracking of the status of security awareness training for all personnel (including employees, contractors, and other 

organization users) with access privileges that require security awareness training.

Yes

6.1.5 Identification and tracking of the status of specialized training for all personnel (including employees, contractors, and other 

organization users) with significant information security responsibilities that require specialized training.

Yes

6.1.6 Training material for security awareness training contains appropriate content for the organization (NIST SP 800-50,800-53).

Yes

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Report #E-14-01 Appendix A 
Section 6: Security Training

6.2 Please provide any additional information on the effectiveness of the organization’s Security Training Program that was not noted in the 

questions above.

n/a

Section 7: Plan Of Action & Milestones (POA&M)

7.1 Has the organization established a POA&M program that is consistent with FISMA requirements, OMB policy, and applicable NIST 

guidelines and tracks and monitors known information security weaknesses? Besides the improvement opportunities that may have been 

identified by the OIG, does the program include the following attributes?

Yes

7.1.1 Documented policies and procedures for managing IT security weaknesses discovered during security control assessments and that 

require remediation.

Yes

7.1.2 Tracks, prioritizes, and remediates weaknesses.

Yes

7.1.3 Ensures remediation plans are effective for correcting weaknesses.

Yes

7.1.4 Establishes and adheres to milestone remediation dates.

Yes

7.1.5 Ensures resources and ownership are provided for correcting weaknesses.

Yes

7.1.6 POA&Ms include security weaknesses discovered during assessments of security controls and that require remediation (do not need 

to include security weakness due to a risk-based decision to not implement a security control) (OMB M-04-25).

Yes

7.1.7 Costs associated with remediating weaknesses are identified (NIST SP 800-53, Rev. 3, Control PM-3 and OMB M-04-25).

Yes

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Report #E-14-01 Appendix A 
Section 7: Plan Of Action & Milestones (POA&M)

7.1.8 Program officials report progress on remediation to CIO on a regular basis, at least quarterly, and the CIO centrally tracks, maintains, 

and independently reviews/validates the POA&M activities at least quarterly (NIST SP 800-53, Rev. 3, Control CA-5; OMB 

M-04-25).

Yes

7.2 Please provide any additional information on the effectiveness of the organization’s POA&M Program that was not noted in the questions 

above.

n/a

Section 8: Remote Access Management

8.1 Has the organization established a remote access program that is consistent with FISMA requirements, OMB policy, and applicable NIST 

guidelines? Besides the improvement opportunities that may have been identified by the OIG, does the program include the following 

attributes?

Yes

8.1.1 Documented policies and procedures for authorizing, monitoring, and controlling all methods of remote access (NIST 800-53: AC-1, 

AC-17).

Yes

8.1.2 Protects against unauthorized connections or subversion of authorized connections.

Yes

8.1.3 Users are uniquely identified and authenticated for all access (NIST SP 800-46, Section 4.2, Section 5.1).

Yes

8.1.4 Telecommuting policy is fully developed (NIST SP 800-46, Section 5.1).

Yes

8.1.5 If applicable, multi-factor authentication is required for remote access (NIST SP 800-46, Section 2.2, Section 3.3).

Yes

8.1.6 Authentication mechanisms meet NIST SP 800-63 guidance on remote electronic authentication, including strength mechanisms.

Yes

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Report #E-14-01 Appendix A 
Section 8: Remote Access Management

8.1.7 Defines and implements encryption requirements for information transmitted across public networks.

Yes

8.1.8 Remote access sessions, in accordance with OMB M-07-16, are timed-out after 30 minutes of inactivity, after which re-authentication 

is required.

Yes

8.1.9 Lost or stolen devices are disabled and appropriately reported (NIST SP 800-46, Section 4.3, US-CERT Incident Reporting 

Guidelines).

Yes

8.1.10 Remote access rules of behavior are adequate in accordance with government policies (NIST SP 800-53, PL-4).

Yes

8.1.11 Remote access user agreements are adequate in accordance with government policies (NIST SP 800-46, Section 5.1, NIST SP 800-53, 

PS-6).

Yes

8.2 Please provide any additional information on the effectiveness of the organization’s Remote Access Management that was not noted in the 

questions above.

n/a

8.3 Does the organization have a policy to detect and remove unauthorized (rogue) connections?

Yes

Section 9: Contingency Planning

9.1 Has the organization established an enterprise-wide business continuity/disaster recovery program that is consistent with FISMA 

requirements, OMB policy, and applicable NIST guidelines? Besides the improvement opportunities that may have been identified by the 

OIG, does the program include the following attributes?

Yes

9.1.1 Documented business continuity and disaster recovery policy providing the authority and guidance necessary to reduce the impact of a 

disruptive event or disaster (NIST SP 800-53: CP-1).

Yes

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Report #E-14-01 Appendix A 
Section 9: Contingency Planning

9.1.2 The organization has incorporated the results of its system’s Business Impact Analysis (BIA) into the analysis and strategy 

development efforts for the organization’s Continuity of Operations Plan (COOP), Business Continuity Plan (BCP), and Disaster 

Recovery Plan (DRP) (NIST SP 800-34).

Yes

9.1.3 Development and documentation of division, component, and IT infrastructure recovery strategies, plans and procedures (NIST SP 

800-34).

Yes

9.1.4 Testing of system specific contingency plans.

Yes

9.1.5 The documented BCP and DRP are in place and can be implemented when necessary (FCD1, NIST SP 800-34).

Yes

9.1.6 Development of test, training, and exercise (TT&E) programs (FCD1, NIST SP 800-34, NIST SP 800-53).

Yes

9.1.7 Testing or exercising of BCP and DRP to determine effectiveness and to maintain current plans.

Yes

9.1.8 After-action report that addresses issues identified during contingency/disaster recovery exercises (FCD1, NIST SP 800-34).

Yes

9.1.9 Systems that have alternate processing sites (FCD1, NIST SP 800-34, NIST SP 800-53).

Yes

9.1.10 Alternate processing sites are not subject to the same risks as primary sites (FCD1, NIST SP 800-34, NIST SP 800-53).

Yes

9.1.11 Backups of information that are performed in a timely manner (FCD1, NIST SP 800-34, NIST SP 800-53).

Yes

9.1.12 Contingency planning that considers supply chain threats.

Yes

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Report #E-14-01 Appendix A 
Section 9: Contingency Planning

9.2 Please provide any additional information on the effectiveness of the organization’s Contingency Planning Program that was not noted in the 

questions above.

n/a

Section 10: Contractor Systems

10.1 Has the organization established a program to oversee systems operated on its behalf by contractors or other entities, including organization 

systems and services residing in the cloud external to the organization? Besides the improvement opportunities that may have been identified 

by the OIG, does the program includes the following attributes?

Yes

10.1.1 Documented policies and procedures for information security oversight of systems operated on the organization’s behalf by 

contractors or other entities, including organization systems and services residing in a public cloud.

Yes

10.1.2 The organization obtains sufficient assurance that security controls of such systems and services are effectively implemented and 

comply with Federal and organization guidelines (NIST SP 800-53: CA-2).(Base)

Yes

10.1.3 A complete inventory of systems operated on the organization’s behalf by contractors or other entities, including organization systems 

and services residing in a public cloud.

Yes

10.1.4 The inventory identifies interfaces between these systems and organization-operated systems (NIST SP 800-53: PM-5).

Yes

10.1.5 The organization requires appropriate agreements (e.g., MOUs, Interconnection Security Agreements, contracts, etc.) for interfaces 

between these systems and those that it owns and operates.

Yes

10.1.6 The inventory of contractor systems is updated at least annually.

Yes

10.1.7 Systems that are owned or operated by contractors or entities, including organization systems and services residing in a public cloud, 

are compliant with FISMA requirements, OMB policy, and applicable NIST guidelines.

Yes

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Report #E-14-01 Appendix A 
Section 10: Contractor Systems

10.2 Please provide any additional information on the effectiveness of the organization’s Contractor Systems Program that was not noted in the 

questions above.

n/a

Section 11: Security Capital Planning

11.1 Has the organization established a security capital planning and investment program for information security? Besides the improvement 

opportunities that may have been identified by the OIG, does the program include the following attributes?

Yes

11.1.1 Documented policies and procedures to address information security in the capital planning and investment control (CPIC) process.

Yes

11.1.2 Includes information security requirements as part of the capital planning and investment process.

Yes

11.1.3 Establishes a discrete line item for information security in organizational programming and documentation (NIST SP 800-53: SA-2).

Yes

11.1.4 Employs a business case/Exhibit 300/Exhibit 53 to record the information security resources required (NIST SP 800-53: PM-3).

Yes

11.1.5 Ensures that information security resources are available for expenditure as planned.

Yes

11.2 Please provide any additional information on the effectiveness of the organization’s Security Capital Planning Program that was not noted in 

the questions above.

n/a

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Report #E-14-01 Appendix A 
Appendix B: Objectives, Scope, and Method

 The objectives of this evaluation were to perform an independent asses

FCA’s information security program and assess FCA’s compliance with 

 The scope of this evaluation covered FCA’s Agency-owned and contrac

information systems of record as of September 30, 2014. FCA is a singAgency with nine mission critical systems and major applications. 

 The evaluation covered the eleven areas identified by Department of Ho

Security (DHS) for OIGs to evaluate.

 Key criteria used to evaluate FCA’s information security program and co

FISMA included OMB guidance, NIST SPs, and FIPS. 

 In performing this evaluation, we performed the following steps: 

 Identified and reviewed Agency policies and procedures related to informatio

 Examined documentation relating to the Agency’s information security progr

compared to NIST standards and FCA policy; 

 Conducted interviews with the CIO, Information Technology Security Specia

Team Leader, Applications Team Leader, and several IT Specialists; 

 Built on our understanding from past FISMA evaluations;  Observed security related activities performed by Agency personnel; and 

 Performed tests for a subset of controls. 

Farm Credit Administration Office of Inspector General (OIG)OIG Evaluation of the Farm Credit Administration’s Compliance with the Federal Information Security Management Act (F

Report #E‐14‐01
Appendix B: Objectives, Scope, and Method

 This evaluation represents the status of the information security program 

September 30, 2014, and did not include a test of all information securit

 The evaluation was performed at FCA Headquarters in McLean, Virginia

September 2014 through November 2014.

 Observations and results were shared with key IT personnel throughout 

evaluation. 

 On November 12, 2014, the Information Technology Security Specialist 

shared and discussed drafts of their respective FISMA section reports. 

 An exit conference was conducted with management officials on Novem

 This evaluation was performed in accordance with the Council of the Ins

General on Integrity and Efficiency’s Quality Standards for Inspection an

Farm Credit Administration Office of Inspector General (OIG)OIG Evaluation of the Farm Credit Administration’s Compliance with the Federal Information Security Management Act (F

Report #E‐14‐01
Fraud | Waste | Abuse | Mismanagement

FARM CREDIT ADMINISTRATION

OFFICE OF INSPECTOR GENERAL

Phone: Toll Free (800) 437‐7322; (703) 883‐4316

Fax: (703) 883‐4059

E‐mail: fca‐ig‐hotline@rcn.com

Mail: Farm Credit Administration

Office of Inspector General

1501 Farm Credit Drive

McLean, VA 22102‐5090

REPORT