Federal Information Security: Agencies and OMB Need to Strengthen Policies and Practices
Released: 2019-07-26T00:00:00


Highlights: section_title: Why GAO Did This Study
paragraphs: For 22 years, GAO has designated information security as a government-wide high-risk area. FISMA requires federal agencies to develop, document, and implement information security programs and have independent evaluations of those programs and practices. It also assigns government-wide responsibilities for information security to OMB, DHS, and NIST.

FISMA includes a provision for GAO to periodically report to Congress on agencies' implementation of the act. GAO's objectives in this report were to (1) describe the reported adequacy and effectiveness of selected federal agencies' information security policies and practices and (2) evaluate the extent to which OMB, DHS, and NIST have implemented their government-wide FISMA requirements. GAO categorized information security deficiencies as reported by 16 randomly selected agencies and their IGs according to the elements of an information security program; evaluated IG reports for 24 CFO Act agencies; examined OMB, DHS, and NIST documents; and interviewed agency officials.

section_title: What GAO Found
paragraphs: During fiscal year 2018, many federal agencies were often not adequately or effectively implementing their information security policies and practices. For example, most of the 16 agencies GAO selected for review had deficiencies related to implementing the eight elements of an agency-wide information security program required by the Federal Information Security Modernization Act of 2014 (FISMA) (see figure) . Further, inspectors general (IGs) reported that 18 of the 24 Chief Financial Officers (CFO) Act of 1990 agencies did not have effective agency-wide information security programs. GAO and IGs have previously made numerous recommendations to agencies to address such deficiencies, but many of these recommendations remain unimplemented.

With certain exceptions, the Office of Management and Budget (OMB), Department of Homeland Security (DHS), and National Institute of Standards and Technology (NIST) were generally implementing their government-wide FISMA requirements, including issuing guidance and implementing programs that are intended to improve agencies' information security. However, OMB has not submitted its required FISMA report to Congress for fiscal year 2018 and has reduced the number of agencies at which it holds CyberStat meetings from 24 in fiscal year 2016 to three in fiscal year 2018—thereby restricting key activities for overseeing agencies' implementation of information security. Also, OMB, in collaboration with the Council of Inspectors General for Integrity and Efficiency (CIGIE), did not include a metric for system security plans, one of the required information security program elements, in its guidance on FISMA reporting. As a result, oversight of agencies' information security programs was diminished.

section_title: What GAO Recommends
paragraphs: GAO is making three recommendations to OMB to (1) submit its FISMA report to Congress for fiscal year 2018, (2) expand its coordination of CyberStat meetings with agencies, and (3) collaborate with CIGIE to update the inspector general FISMA reporting metrics to include assessing system security plans. OMB generally agreed with GAO's recommendations.

section_title: Letter
paragraphs: Federal agencies are dependent on information technology (IT) systems  and electronic data to carry out operations and to process, maintain, and  report essential information. Virtually all federal operations are supported  by computer systems and electronic data, and agencies would find it  difficult, if not impossible, to carry out their missions and account for their  resources without these information assets. Hence, the security of these  systems and data is vital to public confidence and the nation’s safety,  prosperity, and well-being. Ineffective security controls to protect these  systems and data could have a significant impact on a broad array of  government operations and assets.

Safeguarding federal computer systems has been a longstanding  concern. This year marks the 22nd anniversary of GAO’s first designation  in 1997 of information security as a government-wide high-risk area. We  expanded this high-risk area to include safeguarding the systems  supporting our nation’s critical infrastructure in 2003, protecting the  privacy of personally identifiable information in 2015, and establishing a  comprehensive cybersecurity strategy and performing effective oversight  in 2018. Most recently, we continued to identify federal information  security as a government-wide high-risk area in our March 2019 high-risk  update.

Beginning in fiscal year 2015 through fiscal year 2018, GAO made  approximately 1,400 information security-related recommendations.  These recommendations identified actions for agencies to take to  strengthen their information security programs and technical controls over  their computer networks and systems. Nevertheless, many agencies  continue to be challenged in safeguarding their information systems and  information, in part, because they have not implemented many of these  recommendations. As of May 2019, approximately 500 of our prior  recommendations had not been implemented.

The Federal Information Security Modernization Act of 2014 (FISMA)  requires federal agencies in the executive branch to develop, document,  and implement an information security program to provide information  security for the information and information systems that support the  operations and assets for the agency. FISMA also established  government-wide responsibilities that direct the Office of Management  and Budget (OMB) to oversee agency information security policies and  practices and the Department of Homeland Security (DHS) to administer  the implementation of agency information security policies and practices  by developing, issuing, and overseeing implementation of binding  operational directives. In addition, FISMA 2002 directs the National  Institute of Standards and Technology (NIST) to develop standards and  guidelines that include minimum information security requirements.

Annually, the inspector general or independent external auditor for each  agency is to perform an independent evaluation to determine the  effectiveness of the information security policies, procedures, and  practices supporting their agency’s information security programs.  Agencies are to include the results of the evaluations in annual reports  that they are required to submit to OMB, certain congressional  committees, and the Comptroller General. Further, OMB is required to  summarize the results in annual reports to Congress.

FISMA also includes a provision for GAO to periodically report to  Congress on agencies’ implementation of the act. Our specific objectives  for this report were to (1) describe the reported adequacy and  effectiveness of selected federal agencies’ information security policies  and practices and (2) evaluate the extent to which OMB, DHS, and NIST  have implemented their government-wide FISMA requirements.

To address the first objective, we first reviewed information security- related reports issued by inspectors general and GAO to identify  information security deficiencies reported at 16 selected federal  agencies. We analyzed, categorized, and summarized the information  security deficiencies identified in these reports according to the (1) five  core security functions that make up the NIST Framework for Improving  Critical Infrastructure Cybersecurity and (2) eight elements of information  security programs required by FISMA.

To select the 16 agencies we reviewed, we first ranked the 23 civilian  Chief Financial Officers Act of 1990 (CFO Act) agencies by the number  of information security systems each agency reported operating in fiscal  year 2017. We then separated the agencies into large, medium, and  small categories, based on the number of systems they reported, and  randomly selected four agencies from each. We also sorted the 73 non- CFO Act agencies identified in OMB’s Fiscal Year 2017 Annual FISMA  Report to Congress in alphabetical order and randomly selected four non- CFO Act agencies. We chose this sampling strategy to assure a range in  agency type (CFO Act and non-CFO Act) and a range in the size (as  measured by number of information systems) within our selected  agencies. Although we randomly selected agencies and assured we had  CFO Act and non-CFO Act agencies, due to the small number of  agencies examined, results based on these agencies do not generalize  beyond the agencies reviewed.

The 16 selected agencies included 12 CFO Act and four non-CFO Act  agencies. The 12 CFO Act agencies were the Departments of Agriculture,  Commerce, Education, Housing and Urban Development, Justice, Labor,  State, and the Treasury; and the Environmental Protection Agency,  National Aeronautics and Space Administration, Small Business  Administration, and Social Security Administration. The four non-CFO Act  agencies were the Federal Communications Commission, Federal  Retirement Thrift Investment Board, Merit Systems Protection Board, and  Presidio Trust.

In addition, as part of our first objective, we analyzed fiscal year 2018  financial statement audit and FISMA reports issued by the inspectors  general for the 24 CFO Act agencies to identify and summarize  information security deficiencies described in those reports. Further, for  the 23 civilian CFO Act agencies, we analyzed and summarized the  FISMA data reported by the agencies’ CIOs for fiscal year 2018.

To gain insight into how agencies collect, report, and ensure the accuracy  and completeness of their FISMA data, we analyzed documentation  describing and supporting the processes at eight of the 16 selected  agencies. We also interviewed officials at the eight agencies to obtain  additional information on the controls that the agencies used to ensure  the quality of FISMA-related data reported to OMB and DHS. The eight  agencies selected were the Departments of Education, Justice, Labor,  and the Treasury; the Federal Communications Commission; National  Aeronautics and Space Administration; Presidio Trust; and the Small  Business Administration. Based on our assessment, we determined that  the data were sufficiently reliable for the purpose of our reporting  objectives.

To address the second objective, we analyzed the FISMA provisions to  identify government-wide responsibilities intended to improve the  information security of the federal government that have been assigned to  OMB, DHS, and NIST. We then evaluated documentation obtained from  these agencies and their websites against FISMA requirements. We also  interviewed OMB, DHS, and NIST officials to obtain information on any  actions they have planned or taken to improve the information security  posture of the federal government. For more details on our objectives,  scope, and methodology, see appendix I.

We conducted this performance audit from December 2018 to July 2019  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.
subsections: section_title: Background
paragraphs: IT systems supporting federal agencies are inherently at risk. These  systems are highly complex and dynamic, technologically diverse, and  often geographically dispersed. This complexity increases the difficulty in  identifying, managing, and protecting the numerous operating systems,  applications, and devices comprising federal systems and networks.  Compounding these risks, federal systems and networks are often  interconnected with other internal and external systems and networks,  including the internet, thereby increasing the number of avenues of attack  and expanding their potential attack surface.

Without proper safeguards, computer systems are vulnerable to  individuals and groups with malicious intent who can intrude and use their  access to obtain sensitive information, commit fraud and identity theft,  disrupt operations, or launch attacks against other computer systems and  networks. Cyber-based threats to information systems can come from  sources internal and external to the organization. Internal threats include  errors or mistakes, as well as fraudulent or malevolent acts by employees  or contractors working within the organization. External threats include  the ever-growing number of cyber-based attacks that can come from a  variety of sources such as individuals, groups, and countries that wish to  do harm to an organization’s systems.

Yet, IT systems are often riddled with security vulnerabilities—both known  and unknown. These vulnerabilities can facilitate security incidents and  cyberattacks that disrupt critical operations; lead to inappropriate access  to and disclosure, modification, or destruction of sensitive information;  and threaten national security, economic well-being, and public health  and safety.
subsections: section_title: Federal Agencies Continue to Report Large Numbers of Incidents
paragraphs: Until fiscal year 2016, the number of information security incidents  reported by federal agencies to DHS’s United States Computer  Emergency Readiness Team (US-CERT) had steadily increased each  year. From fiscal year 2009 through fiscal year 2015, reported incidents  increased from 29,999 to 77,183, an increase of 157 percent. Changes to  federal incident reporting guidelines for 2016 contributed to the decrease  in reported incidents in fiscal year 2016. Specifically, updated incident  reporting guidelines that became effective in fiscal year 2016 no longer  required agencies to report non-cyber incidents or incidents categorized  as scans, probes, and attempted access.

More recently, agencies reported 35,277 incidents in fiscal year 2017 and  31,107 incidents in fiscal year 2018, as reflected in figure 1.

According to US-CERT incident report data, the incidents reported in  fiscal year 2018 involved several threat vectors. These threat vectors  include web-based attacks, phishing attacks, and the loss or theft of  computer equipment, among others. Figure 2 provides a breakdown of  information security incidents by threat vector in fiscal year 2018.

These incidents and others like them can pose a serious challenge to  national security, economic well-being, and public health and safety, as  shown by two incidents reported in fiscal year 2018:  In March 2018, the Department of Justice reported that it had indicted  nine Iranians for conducting a massive cybersecurity theft campaign  on behalf of the Islamic Revolutionary Guard Corps. According to the  department, the Iranians allegedly stole more than 31 terabytes of  documents and data from more than 140 American universities, 30  U.S. companies, and five federal government agencies, among other  entities.

In March 2018, a joint alert from DHS and the Federal Bureau of  Investigation stated that, since at least March 2016, Russian  government actors had targeted U.S. government entities and critical  infrastructure sectors, including the energy, nuclear, water, aviation,  and critical manufacturing sectors.

section_title: FISMA Sets Requirements for Effectively Securing Federal Systems and Information
paragraphs: Congress enacted FISMA 2014 to provide a comprehensive framework  for ensuring the effectiveness of information security controls over  information resources that support federal operations and assets and to  clarify government-wide responsibilities. The act addresses the increasing  sophistication of cybersecurity attacks, promotes the use of automated  security tools with the ability to continuously monitor and diagnose the  security posture of federal agencies, and provides for improved oversight  of federal agencies’ information security programs.

FISMA requires agencies to develop, document, and implement an  agency-wide information security program to secure federal information  systems. These information security programs are to provide risk-based  protections for the information and information systems that support the  operations and assets of the agency. FISMA requires agencies to comply  with OMB policies and procedures, DHS binding operational directives,  and NIST federal information standards and guidelines. In addition,  FISMA assigns to agency inspectors general responsibility for annually  assessing the effectiveness of the information security policies,  procedures, and practices of the agency.

FISMA directs OMB to oversee agencies’ information security policies  and practices. Among other things, FISMA requires OMB to develop and  oversee the implementation of policies, principles, standards, and  guidelines on information security in federal agencies, except with regard  to national security systems. The law also assigns OMB the responsibility  of requiring agencies to identify and provide information security  protections commensurate with assessments of risk to their information  and information systems.

In addition, FISMA 2014 clarified and expanded DHS’s responsibilities for  government-wide information security. Specifically, the act requires DHS,  in consultation with OMB, to administer the implementation of agency  information security policies and practices for non-national security  information systems by: (1) assisting OMB with carrying out its oversight  responsibilities; (2) developing, issuing, and overseeing implementation of  binding operational directives; and (3) providing operational and technical  assistance.

Further, FISMA 2002 assigned to NIST the responsibility for developing  standards and guidelines that include minimum information security  requirements.

FISMA also includes reporting requirements. Specifically, OMB is to  report annually, in consultation with DHS, on the effectiveness of agency  information security policies and practices, including a summary of major  agency information security incidents and an assessment of agency  compliance with NIST standards. Further, the law requires agencies to  report annually to OMB, DHS, certain congressional committees, and the  Comptroller General on the adequacy and effectiveness of their  information security policies, procedures, and practices, including a  description of each major security incident.

section_title: Federal Agencies Are Required to Use the Cybersecurity Framework to Manage Risk and to Report on FISMA Implementation
paragraphs: In May 2017, the President signed Executive Order 13800, which sets  policy for managing cybersecurity risk as an executive branch  enterprise. Specifically, the order outlines actions to be taken by federal  agencies and critical infrastructure sectors to improve the nation’s  cybersecurity posture and capabilities. To this end, the order states that  the President will hold executive agency heads accountable for managing  agency-wide cybersecurity risk and directs each executive branch agency  to use the NIST cybersecurity framework to manage those risks. In  addition to requirements set in the executive order, OMB’s reporting  metrics that were developed to facilitate agencies’ compliance with  FISMA’s reporting requirement are aligned to the core functions outlined  in the cybersecurity framework. Consequently, agencies are required to  report on the effectiveness of their information security policies and  practices according to the cybersecurity framework’s core functions.
subsections: section_title: NIST Framework’s Five Core Functions Are Aimed at Managing Cybersecurity Risk
paragraphs: The NIST cybersecurity framework is based on five core security  functions:  Identify: Develop an understanding of the organization’s ability to  manage cybersecurity risk to systems, people, assets, data, and  capabilities.

Protect: Develop and implement appropriate safeguards to ensure  delivery of critical services.

Detect: Develop and implement appropriate activities to identify the  occurrence of a cybersecurity event.

Respond: Develop and implement appropriate activities to take action  regarding a detected cybersecurity incident.

Recover: Develop and implement appropriate activities to maintain  plans for resilience and to restore capabilities or services that were  impaired due to a cybersecurity incident.

According to NIST, these five functions should be performed concurrently  and continuously to address cybersecurity risk. In addition, when  considered together, they provide a high-level, strategic view of the life  cycle of an organization’s management of cybersecurity risk. Within the  five functions, NIST identifies 23 categories and 108 subcategories of  activities and controls for achieving the intent of each function. Appendix  II provides a description of the cybersecurity framework categories and  subcategories of activities and controls.

section_title: Inspectors General Are to Measure the Effectiveness of Agencies’ Information Security Programs Using the Cybersecurity Framework Core Functions
paragraphs: The Council of Inspectors General for Integrity and Efficiency (CIGIE), in  collaboration with OMB, DHS, and other stakeholders, developed a  capability maturity model for agency inspectors general to assess and  report on the effectiveness of their agencies’ information security  programs. As described in table 1, the model identifies five maturity levels  with each succeeding level representing a more advanced level of  implementation.

Using the five-level maturity model described above, the inspectors  general are to assign a maturity-level rating for each of the five core  security functions based on an assessment of their agencies’  implementation of the activities and controls associated with each  function using metrics that CIGIE developed in collaboration with OMB.  The inspectors general then consider the maturity level ratings of the core  security functions to evaluate the overall effectiveness of their agency’s  information security program.

OMB instructs inspectors general to rate their agency’s information  security program as effective or not effective by applying a rule of simple  majority. Specifically, if three or more of the five core security functions  are rated effective, the overall information security program is considered  to be effective. According to this maturity model, Level 4 (managed and  measurable) is the lowest level to represent an effective level of  security. Therefore, if an inspector general rates three or more of the  agency’s core security functions at Level 4 or Level 5, then the inspector  general can consider that agency to have an effective information security  program. However, the inspector general has the discretion to have a  different conclusion on program effectiveness if he or she deems it  appropriate to do so.

section_title: CIOs Are Required to Assess Agencies’ Progress in Implementing Capabilities Related to the Administration’s Cybersecurity-related Cross- Agency Priority Goal
paragraphs: Similar to the inspector general FISMA reporting metrics, OMB and DHS  worked with interagency partners to develop the CIO FISMA metrics,  which are intended to be used by the agencies, OMB, and DHS to track  agencies’ progress in implementing cybersecurity capabilities. The CIO  FISMA reporting metrics are organized around the five core security  functions outlined in NIST’s cybersecurity framework.

In addition, certain CIO FISMA reporting metrics represent key milestones  of the administration’s IT Modernization Cross-Agency Priority (CAP)  goal, which includes a cybersecurity initiative. As a result, the CIO  reporting metrics allow agency CIOs, OMB and DHS to monitor progress  toward meeting key milestones and targets for the CAP goal.

The cybersecurity initiative within the IT Modernization CAP goal is  designed to reduce cybersecurity risks to the federal government’s  information systems by mitigating the impact of risks to federal data,  systems, and networks. The initiative consists of three strategies that  contain 10 milestones that relate to key areas within the CIO FISMA  metrics—information security continuous monitoring; identity, credential,  and access management; and advanced network and data protections. In  addition, each of the 10 milestones has an expected level of performance,  or target, for implementation, as described later in this report.

section_title: Reported Information Security Spending Varies Among the 23 Civilian CFO Act Agencies
paragraphs: Each year, OMB requires agencies to report how much they spend on  information security. In fiscal year 2018, the 23 civilian agencies covered  by the CFO Act reported spending between $9 million and almost $1.9  billion on cybersecurity- or IT security-related activities. For these 23  agencies, their total reported security spending accounted for about 14  percent of their IT spending, with percentages for individual agencies  ranging from 5 percent to 208 percent, as seen in table 2.

section_title: Security Control Deficiencies Reported at Selected Agencies Indicate Ineffective Information Security Policies and Practices
paragraphs: Information security reports issued by GAO, inspectors general, and CIOs  indicate that information security policies and practices of the agencies  we reviewed are ineffective. Specifically, information security evaluation  reports that we and agency inspectors general issued during fiscal year  2018 showed that most of the 16 selected agencies did not consistently  or effectively implement policies or practices related to the core security  functions of the cybersecurity framework. In addition, most of these  selected agencies had deficiencies in implementing the eight elements of  an information security program, as defined by FISMA. Also, inspectors  general reported that most of the 24 CFO Act agencies did not have  effective information security programs and were not effectively  implementing security controls over financial systems during fiscal year  2018. Further, agency CIOs reported that most of the 23 civilian CFO Act  agencies had not met targets for implementing cyber capabilities to  reduce risk.
subsections: section_title: Most of the 16 Selected Agencies Exhibited Deficiencies in All Cybersecurity Framework Core Security Functions
paragraphs: FISMA requires agencies and their inspectors general to report on the  adequacy and effectiveness of information security policies, procedures,  and practices. To facilitate meeting this reporting requirement, CIGIE, in  collaboration with OMB and DHS, developed metrics that agency  inspectors general are to use to report on eight security domains that  align with the five core security functions—Identify, Protect, Detect,  Respond, and Recover—of the NIST cybersecurity framework. Table 3  illustrates how the inspector general reporting domains are related to the  core security functions.

Most of the 16 agencies that we reviewed had deficiencies in  implementing policies and practices related to the cybersecurity  framework core security functions and related domains during fiscal year  2018. Figure 3 shows the number of agencies with reported deficiencies  in each of the framework’s core security functions.

The Identify core security function includes the key process of risk  management. NIST defines risk management as the process of  identifying and assessing risk, and taking steps to reduce those risks to  an acceptable level. NIST guidance specifies activities that agencies  should implement to effectively identify and manage cybersecurity risks,  including: establishing a risk management strategy that includes a determination  identifying assets that require protection; assessing risk; and documenting plans of action and milestones (POA&Ms) to mitigate  known deficiencies.

Fifteen of the 16 selected agencies had deficiencies in activities  associated with identifying risks. Figure 4 illustrates the number of  selected agencies that had deficiencies in each of the activities.

Establishment of a Risk Management Strategy  Risk management strategies include strategic-level decisions and  considerations for how senior leaders and executives are to manage risk  to organizational operations and assets, individuals, other organizations,  and the nation. GAO and inspectors general reports identified that 10 of  the 16 selected agencies had deficiencies in developing, documenting, or  implementing a risk management strategy. Specifically, nine of the 10  agencies had not developed or documented an enterprise-wide risk  management strategy or process. Another agency had developed an  enterprise risk management strategy but had not implemented it  consistently across the agency.

Without developing or documenting a risk management strategy,  agencies lack clear guidance to help them make informed decisions for  managing risk. Further, if agencies do not consistently implement a risk  management strategy, they can potentially hinder their efforts to  effectively identify and manage risk.

FISMA requires agencies to develop and maintain an inventory of major  information systems operated by or under the control of the agency to  support risk management activities. Further, NIST Special Publication  800-53 states that centralized inventories of hardware, software, and  firmware assets should be maintained to ensure proper accountability of  those assets. These inventories also should be current, complete, and  accurate to ensure proper accountability.

Twelve of the 16 selected agencies did not fully identify or account for  their major information systems or information technology assets. One  agency did not maintain a comprehensive and accurate inventory of  information systems and two other agencies did not maintain a current  inventory of hardware and software assets. Nine additional agencies  maintained neither a comprehensive and accurate inventory of  information systems nor a current inventory of software and hardware  assets. If agencies do not maintain comprehensive, accurate, or up-to- date inventories of information systems or hardware and software assets,  agencies cannot ensure the protection of all assets within their networks.

FISMA requires agencies to develop, document, and implement an  agency-wide information security program that includes periodic risk  assessments. According to NIST, these assessments are to address  potential adverse impacts resulting from the operation and use of  information systems and the information those systems process, store  and transmit.

Eight of the 16 selected agencies exhibited deficiencies in conducting risk  assessments. Of the eight agencies that had deficiencies, four did not  consistently perform risk assessments of their information systems; three  did not fully update risk assessments subsequent to system changes; and  one did not conduct a risk assessment supporting the agency’s decision  to allocate resources to support mission and business processes. Without  a sufficient process for conducting periodic risk assessments, agencies  cannot determine, or appropriately respond to, risks to the information  systems supporting the organization.

Documentation of Plans of Action and Milestones  FISMA requires agency information security programs to include a  process for planning, implementing, evaluating, and documenting  remedial action to address deficiencies in information system policies,  procedures, and practices. In addition, NIST’s risk management  framework states that agencies should implement a consistent process  for developing POA&Ms using a prioritized approach to risk mitigation that  is guided by a risk assessment. Further, documentation of POA&Ms  should also be updated to reflect the current status of the deficiencies  and, after remedial actions have been completed, agencies should test  the actions to determine if they effectively addressed the deficiencies.

Thirteen of the 16 selected agencies had deficiencies in their POA&M  processes. Specifically, five agencies did not have an effective process  for remediating vulnerabilities in a timely manner; seven other agencies  did not adequately document or track the status of POA&Ms; and another  agency did not assess the root cause of identified deficiencies to prioritize  corrective actions based on the highest areas of risks. Additionally, one of  the agencies that did not adequately document POA&Ms also did not  have sufficient evidence to conclude that deficiencies were corrected  even though the agency validated the remediation of the deficiency  through its closure verification process.

Without sufficiently documenting POA&Ms, agencies may not sufficiently  remediate information security deficiencies in a timely manner, exposing  their systems to increased risks that nefarious actors will exploit the  deficiencies to gain unauthorized access to information resources.
subsections: section_title: All Selected Agencies Had Deficiencies in Developing and Implementing Appropriate Safeguards to Protect Cyber Assets
paragraphs: Agencies are to implement appropriate safeguards associated with the  following four security domains that align with the Protect core security  function:  identity and access management; data protection and privacy; and  security training.

Each of the 16 selected agencies was deficient in developing and  implementing appropriate safeguards to protect agency systems and  networks. As shown in figure 5, most of the selected agencies had  deficiencies in each of the four domains.

NIST guidelines specify that agencies are to develop, implement, and  maintain a baseline configuration; control changes to system  configurations; and securely configure information systems. However,  14 of the selected 16 agencies reported weaknesses in one or more of  these configuration management activities.

Of the 14 agencies, nine had weaknesses in developing, maintaining, and  implementing a baseline configuration for their information systems. For  example, four agencies did not develop a baseline configuration for all  systems or network devices. In addition, two agencies did not review or  approve their baseline configurations. Further, three agencies did not  consistently implement their baseline configurations. If agencies do not  develop, maintain, or implement a current and comprehensive baseline of  information systems and network devices, agencies cannot validate  configuration information for accuracy, thereby hindering them from  controlling changes made to a system.

Eleven agencies did not effectively or consistently control changes to the  configuration of their information systems. Properly controlling system  changes can help agencies to ensure that changes are formally identified,  proposed, reviewed, analyzed for security impact, tested, and approved  prior to implementation. However, six of the 11 agencies did not properly  approve or test changes before they were implemented; four other  agencies did not consistently implement change control activities across  their organization or their information systems; and one other agency did  not consistently ensure accountability and responsibility for individuals  performing configuration management activities.

In addition, 12 agencies did not securely configure their information  systems. NIST specifies that agencies should apply software patches in a  timely manner, use vendor-supported software, apply secure  configuration settings, and limit system functionality to least level needed  to meet organizational requirements. However, of the 12 agencies that  had deficiencies in implementing secure configurations, nine did not  implement patches to address vulnerabilities or use up-to-date software  that was supported by a vendor. Ten agencies also did not apply secure  configuration settings to effectively enable security and facilitate the  management of risk, while two agencies did not implement controls for  limiting system functionality. As a result, these agencies cannot validate  configuration information for their information systems and assets, detect  or prevent unauthorized changes to information system resources, or  provide a reasonable assurance that systems are configured and  operating securely and as intended.

Access controls are intended to limit or detect inappropriate access to  computer resources to protect them from unauthorized modification, loss,  and disclosure. Such controls include logical controls that require users to  validate their identity and limit the files and other resources that those  validated users can access and the actions they can execute.

All 16 agencies that we reviewed had deficiencies in effectively  implementing one or more controls associated with the identity and  access management domain during fiscal year 2018. Fifteen of the 16  selected agencies did not adequately control user’s access to information  systems and the information residing on them. For example, seven  agencies did not appropriately authorize or approve system access  before access was granted, and eight agencies did not perform user  access reviews to ensure that they complied with account management  policy.

Additionally, 11 of the 16 agencies did not properly identify and validate  information system users, which involve enforcing strong passwords and  requiring passwords to be changed periodically. In addition, 11 of the 16  agencies had deficiencies in implementing access management to ensure  separation of duties, or segregating work responsibilities so that one  individual does not control all critical stages of a process. Without  adequate access controls, unauthorized individuals, including outside  intruders and former employees, can surreptitiously read and copy  sensitive data and make undetected changes or deletions for malicious  purposes or personal gain.

According to NIST guidance on security and privacy controls, agencies  should protect data at rest and in transit on their network through  implementation of cryptography and other technologies to achieve  confidentiality and integrity protections over that data. In addition,  NIST’s guidance states that agencies should implement contingency  strategies, such as conducting backups of information systems and  having alternate processing and storage sites to protect data from loss  during an interruption and to resume activities after an interruption.  Further, NIST guidance states that agencies should develop privacy  policies, procedures, and guidance for safeguarding the collection,  access, use, dissemination, and storage of personally identifiable  information that supports a privacy program.

However, 15 of the 16 selected agencies did not effectively implement  controls to protect data and ensure its privacy during fiscal year 2018.  Specifically, eight of the 16 agencies did not adequately implement  controls for protecting information at rest and four agencies did not  adequately implement controls for ensuring the integrity and  confidentiality of data in transit. In addition, five of the 16 agencies did not  conduct backups of information systems and five agencies did not use  alternate processing sites to retrieve backups or resume essential  mission/business functions. Further, the inspectors general for 14 of the  16 agencies reported that their respective agency did not effectively  document or implement policies and procedures supporting the agency’s  privacy program. If agencies do not effectively implement controls to  protect data and ensure its privacy, agencies may be hindered in limiting  or containing the impact of a potential cybersecurity event.

FISMA requires agency information security programs to include security  awareness training to inform personnel of information security risks  associated with their activities and responsibilities in complying with  agency policies and procedures intended to reduce risk. In addition,  FISMA requires agencies to provide role-based training to personnel with  significant responsibilities for information security. Further, NIST guidance  on building an IT security awareness and training program states that an  awareness and training program is the means to communicate  information that users need to support the mission of the organization,  and security requirements across the agency.

Most of the selected agencies exhibited deficiencies in implementing a  security training program during fiscal year 2018. Only three of the 16  selected agencies effectively implemented elements of a security training  program. Of the 13 agencies that had deficiencies, 12 did not ensure that  personnel received security awareness training and 10 did not ensure  that personnel with significant responsibilities for information security  received role-based training, including nine agencies that were deficient  in providing both types of training. As a result, these agencies risk having  employees or contractors that are ill-prepared to protect systems, and risk  inadvertently or intentionally compromising security.

section_title: Most of the Selected Agencies Had Not Effectively Developed or Implemented Controls to Detect Cyber Events and Vulnerabilities
paragraphs: Agencies are to develop and implement controls to Detect cyber events  and vulnerabilities. FISMA requires agencies to develop, document, and  implement an agency-wide information security program that includes  periodic testing and evaluation of effectiveness and procedures for  detecting security incidents. NIST guidelines define these and other  activities as part of information security continuous monitoring,  including: defining an information security continuous monitoring strategy and  implementing an information security continuous monitoring program  in accordance with that strategy; assessing and reporting on the effectiveness of all implemented  collecting, correlating, and analyzing security related information  obtained through information system auditing.

However, as shown in figure 6, agencies exhibited deficiencies in  activities associated with information security continuous monitoring.

Continuous Monitoring Strategy and Program  NIST’s guidance on information security continuous monitoring states that  defining an information security continuous monitoring strategy and  developing an information security continuous monitoring program are the  first two steps in creating, implementing, and maintaining information  security continuous monitoring. In addition, agencies should implement  the information security continuous monitoring program in accordance  with the defined strategy.

However, half of the 16 selected agencies did not develop an information  security continuous monitoring strategy or program, or implement the  information security continuous monitoring program. Specifically, five of  the agencies did not fully develop an information security continuous  monitoring strategy or program. In addition, while three agencies had  developed, or made organizational changes to create a foundation for, an  information security continuous monitoring strategy, those agencies did  not consistently or effectively implement the strategy. Without a well- designed and implemented information security continuous monitoring  strategy, agencies could be hindered in assuring ongoing situational  awareness of information security, vulnerabilities, and threats.

As stated above, FISMA requires agencies to include periodic testing and  evaluation of information security policies, procedures, and practices in  agency-wide information security programs. Security control assessments  determine the extent to which controls are implemented correctly,  operating as intended, and producing the desired outcome with respect to  meeting the system requirements.

Most agencies assessed the controls implemented on their systems.  However, seven agencies did not consistently perform system control  assessments to ensure that the controls were operating effectively, or as  intended. Further, seven agencies had not completed or implemented  other activities in their security assessment and authorization process that  assists agencies with ensuring that appropriate controls are implemented  on an information system and that the system is authorized to operate. If  agencies do not perform consistent testing of information security  controls, they cannot determine that implemented controls are  appropriately designed or operating effectively.

Audit Review, Analysis, and Reporting  According to NIST guidance on log management, routine log analysis is  beneficial to identifying security incidents, policy violations, fraudulent  activity, and operational problems. As a result, log analysis supports  information security continuous monitoring capabilities.

However, more than half of the 16 selected agencies did not review,  analyze, and report auditable events from audit logs. For example, nine  agencies did not implement audit log review capabilities on their  information systems. Without reviewing, analyzing, and reporting audit  logs, agencies limit their ability to identify unauthorized, unusual, or  sensitive access activity on their networks.

section_title: Most of the Selected Agencies Exhibited Deficiencies in Developing and Implementing Controls to Respond to Detected Cyber Intrusions
paragraphs: Agencies should have policies and practices in place to Respond to  detected incidents. FISMA requires agency information security programs  to include procedures for responding to security incidents in order to  mitigate risks associated with such incidents before substantial damage is  done. According to NIST, incident response involves rapidly detecting  incidents, minimizing loss and destruction, mitigating the weaknesses that  were exploited, and restoring IT services. An effective incident response  process includes, for example: an incident handling capability that incorporates lessons learned from  ongoing incident handling activities;  the monitoring of incidents through documentation that includes  pertinent information necessary for forensics, evaluating incident  details, trends, and handling;  the timely reporting of incidents with sufficient detail to allow analysis;  and an incident response plan.

Most of the 16 selected agencies had deficiencies in at least one of the  activities associated with incident response processes, as shown in figure  7.

According to NIST, agencies should have the ability to detect and analyze  security incidents in order to minimize loss and destruction and mitigate  the weaknesses that were exploited. In addition, agencies should  incorporate lessons learned from an incident to improve existing security  controls and practices.

Most of the selected agencies did not report deficiencies associated with  their incident handling capability, including the ability to analyze and  respond to security incidents and incorporate lessons learned. However,  seven agencies did not adequately implement capabilities to analyze and  respond to security incidents. In addition, one of the seven agencies did  not use lessons learned from prior incidents to improve incident handling.  Without an effective incident handling capability, agencies have limited  ability to detect and analyze security incidents to minimize destruction  and mitigate exploited vulnerabilities.

According to NIST, agencies should monitor and document security  incidents with sufficient detail in order to effectively respond to and  mitigate the risks associated with the incident. Doing so enables  agencies to analyze security incidents, understand the impact of the  incident, and perform analysis to identify trends and indicators of attack.

Inspectors general for 12 of the 16 selected agencies did not identify  deficiencies related to monitoring detected incidents. However, four  agencies did not effectively monitor incidents. For example, one agency  did not consistently document incidents detected and another agency had  not implemented an automated enterprise tool for monitoring incidents. If  agencies do not effectively implement incident monitoring processes, they  hinder their ability to adequately analyze and respond to security  incidents.

FISMA requires agencies to develop, document, and implement an  agency-wide information security program that includes procedures for  reporting security incidents to US-CERT. In addition, NIST guidance  states that agencies should have specific incident reporting requirements  for reporting suspected security incidents to an internal incident reporting  organization.

However, 10 agencies had deficiencies in their implementation of incident  reporting. While only two agencies did not clearly define incident reporting  requirements, eight agencies did not effectively implement those  requirements. For example, these agencies did not consistently  categorize incidents or ensure timely reporting of incidents to US-CERT  and internal reporting organizations. If agencies do not consistently  categorize or report incidents in an accurate and timely manner, they  cannot effectively respond to incidents because they may lack effective  situational awareness in order to appropriately respond to incidents.

Incident response plans are an important element to ensuring that  incident response is performed effectively, efficiently, and consistently  throughout the agency. Among other things, NIST guidance states that  incident response plans should provide a roadmap for implementing an  incident response capability, describe metrics for measuring the incident  response capability, and be approved.

Inspectors general for nine of the selected agencies did not report  deficiencies related to incident response plans. However, seven agencies  did not fully develop or monitor the effectiveness of their incident  response plans. Specifically, five agencies had incident response plans  that did not fully define requirements for implementing their incident  response capability or were not approved. In addition, the other two  agencies did not use performance metrics to verify the effectiveness of  their incident response plan. Without an effective and comprehensive  incident response plan, agencies cannot implement a coordinated  approach to incident response.

section_title: More Than Half of the Selected Agencies Had Not Adequately Developed or Implemented Practices to Recover from Cyber Events
paragraphs: Agencies should be able to Recover from cyber events. FISMA requires  agencies to develop, document, and implement an agency-wide  information security program that includes plans and procedures to  ensure continuity of operations for information systems that support the  operations and assets of the agency. NIST defines contingency planning  as a coordinated strategy involving plans, procedures, and technical  measures that enable the recovery of information systems, operations,  and data after a disruption. Contingency planning is significant to  protecting electronically maintained data and an agency’s ability to  process and retrieve data during and after a cyber intrusion. According to  NIST, agencies should develop and document a comprehensive  contingency plan or suite of related plans for restoring capabilities during  and after a cyber event. The suite of related plans should include a  disaster recovery plan and business impact analysis.

However, 11 of the 16 selected agencies did not sufficiently plan for  recovering system operations after an interruption. Specifically, these 11  agencies did not consistently develop contingency plans, to include  disaster recovery plans, or other associated documentation, such as  business impact analyses for all of their information systems. In addition,  one agency did not define how the agency is to process and retrieve data  during and after an interruption. Without an effective contingency planning  process, agencies are exposed to the risk of interruptions to information  system operations and disruption to their mission and business  processes.

section_title: Most of the 16 Selected Agencies Exhibited Deficiencies in Implementing Elements of an Information Security Program
paragraphs: Controls associated with the five core security functions are related to  elements of agencies’ information security programs. FISMA requires  each agency to develop, document, and implement an information  security program that includes the following eight elements:  1.  periodic assessments of the risk;  2.  cost-effective policies and procedures that reduce risk to an  acceptable level, ensure that information security is addressed  throughout the life cycle of each system, and ensure compliance with  applicable requirements;  3.  subordinate plans for providing adequate information security for  networks, facilities, and systems or groups of information systems, as  appropriate;  4.  security awareness training and training for personnel with significant  responsibilities for information security;  5.  periodic testing and evaluation of the effectiveness of security  policies, procedures, and practices;  6.  a process for planning, implementing, evaluating, and documenting  remedial actions to address information security deficiencies;  7.  procedures for detecting, reporting, and responding to security  8.  plans and procedures to ensure continuity of operations for  information systems.

As discussed earlier in this report, most of the 16 selected agencies had  deficiencies related to implementing the eight elements of an agency- wide information security program. Figure 8 shows the number of  selected agencies with deficiencies in implementing the eight elements of  an agency-wide information security program.

For example, of the 16 selected agencies:

Eight agencies did not effectively assess risk;

11 agencies did not have policies to ensure that CIOs carried out their  role as it relates to information security;

Four agencies developed incomplete system security plans;

13 agencies did not ensure that personnel received security  awareness training, or that personnel with security responsibilities  received role-based security training;

Seven agencies did not consistently perform control assessments to  ensure that the controls were operating effectively, or as intended;

13 agencies did not effectively implement their POA&M process to  address information security deficiencies;

13 agencies did not adequately detect or respond to incidents; and

11 agencies did not comprehensively develop plans to ensure the  continuity of its operations.

We and inspectors general have made numerous recommendations  aimed at improving information security programs and practices over the  years. Until these agencies take action to address deficiencies in  implementing the eight elements of an agency-wide information security  program, they lack assurance that their information systems and networks  are protected from inadvertent or malicious activity.

section_title: Inspectors General Determined That the 24 CFO Act Agencies Generally Did Not Have Effective Information Security Policies and Practices
paragraphs: Inspectors general determined that few agencies covered by the CFO Act  of 1990 had effective agency-wide information security programs during  fiscal year 2018. Further, in agency financial statement audit reports for  fiscal year 2018, inspectors general reported that they continued to  identify significant deficiencies in information security controls over  financial systems. As a result, inspectors general reported material  weaknesses or significant deficiencies in internal control over financial  reporting for fiscal year 2018.
subsections: section_title: Inspectors General Indicate That Few CFO Act Agencies had Effective Information Security Programs
paragraphs: FISMA requires inspectors general to determine the effectiveness of their  respective agencies’ information security programs. To do so, OMB  instructed inspectors general to provide a maturity rating for agency  information security policies, procedures, and practices related to the five  core security functions established in the NIST cybersecurity framework,  as well as for the agency-wide information security program.

For fiscal year 2018, the inspectors general for only six of the 24 CFO Act  agencies reported that their agencies had an effective agency-wide  information security program. However, the remaining 18 agencies were  reported as having ineffective information security programs. When  considering each of the five core security functions, most inspectors  general reported that their agency was at Level 3 (consistently  implemented) for the Identify, Protect, and Recover functions; at Level 2  (defined) for the Detect function; and at Level 4 (managed and  measurable) for the Respond function, as shown in figure 9.

Agency inspectors general report on the effectiveness of agencies’  information security controls as part of the annual audits of the agencies’  financial statements. The reports resulting from these audits include a  description of information security control deficiencies related to the five  major control categories defined by the Federal Information System  Controls Audit Manual (FISCAM)—security management, access  controls, configuration management, segregation of duties, and  contingency planning.

For fiscal year 2018, inspectors general identified information security  control deficiencies related to most of the FISCAM general control  categories for most of the 24 CFO Act agencies as shown in figure 10.

Overall, inspectors general for the 24 CFO Act agencies continued to  report deficiencies in agencies information security practices for fiscal  year 2018. Specifically, during that time, 18 inspectors general  designated information security as either a material weakness (6) or  significant deficiency (12) in internal control over financial reporting  systems for their agency. Further, inspectors general at 21 of the 24  agencies cited information security as a major management challenge for  their agency for fiscal year 2018.

section_title: Most of the 23 Civilian CFO Act Agencies Reported Not Fully Meeting Targets for Implementing Cyber Capabilities to Mitigate Risks
paragraphs: OMB, in its fiscal year CIO reporting metrics, directed CIOs to assess  their agencies’ progress toward achieving outcomes that strengthen  federal cybersecurity. To do this, CIOs evaluated their agency’s  performance in reaching targets for meeting key milestones of the current  administration’s IT Modernization Cross-Agency Priority (CAP) goal. This  CAP goal includes a cybersecurity initiative to mitigate the impact of risks  to federal agencies’ data, systems, and networks by implementing cutting  edge cybersecurity capabilities.

The CAP goal’s cybersecurity initiative has three strategies that include  key milestones with specific implementation targets, most of which are  expected to be met by the end of fiscal year 2020. Table 4 shows the key  milestones and targets related to the three strategies of the IT  Modernization CAP goal’s cybersecurity initiative, as well as how many  agencies were meeting the targets for each of the milestones.

Overall, only two of the civilian 23 CFO Act agencies met all 10 targets for  the cybersecurity initiative of the IT Modernization CAP goal, during fiscal  year 2018. Whereas, 10 agencies met seven to nine of the targets and  the remaining 11 agencies met six or fewer targets. More specifically, by  strategy area,

Seven agencies met all four targets for the manage asset security  strategy.

Eight agencies met all three targets for the limit personnel security  strategy.

Seven agencies met all three targets for the protect networks and  data strategy.

section_title: OMB, DHS, and NIST Acted to Fulfill Their FISMA-defined Roles, but Shortcomings Exist in Government- wide Efforts Intended to Improve Federal Information Security
paragraphs: OMB, DHS, and NIST have ongoing and planned initiatives to support  FISMA’s implementation across the federal government. Specifically,  OMB developed and oversaw the implementation of information security  policies, procedures, and guidelines over the past 2 years. In addition,  DHS oversaw and assisted government efforts that were intended to  provide adequate, risk-based, cost-effective cybersecurity. Further, NIST  continued to provide guidance to federal agencies to improve information  security across the government.

However, beyond fiscal year 2016, OMB held CyberStat meetings at  significantly fewer agencies. These meetings are intended to help ensure  effective implementation of information security policies and practices. In  addition, OMB’s guidance to agencies for preparing their fiscal year 2018  FISMA report does not sufficiently address FISMA’s requirement for  developing subordinate plans for providing adequate information security  for networks, facilities, and information systems.
subsections: section_title: OMB Provided Guidance for Federal Information Security, but Missed a Reporting Deadline and Its Reporting Guidance to Agencies Did Not Sufficiently Address a FISMA Element
paragraphs: FISMA requires that OMB submit a report to Congress no later than  March 1 of each year on the effectiveness of agencies’ information  security policies and practices during the preceding year. This report is to  include: a summary of incidents described in the agencies’ annual reports; a description of the threshold for reporting major information security a summary of results from the annual IG evaluations of each agency’s  information security program and practices; an assessment of each agency’s compliance with NIST information an assessment of agency compliance with OMB data breach  notification policies and procedures.

As of June 2019, OMB had not issued its annual FISMA report to  Congress for fiscal year 2018. OMB officials stated that the lapse in  appropriations during the start of 2019 caused a delay in the report’s  development and release. The officials declined to provide a time frame  for when they expected to issue the report.
subsections: section_title: OMB Provided Numerous Guidance Documents to Agencies and Monitored Agencies’ Implementation of Them
paragraphs: FISMA requires OMB to develop and oversee the implementation of  policies, principles, standards, and guidelines on information security.  Since the start of fiscal year 2018, OMB has developed or proposed  policies and generally monitored their implementation. Specifically:  In May 2019, OMB issued policy to address federal agencies’  implementation of identity, credential, and access management  (ICAM). Among other things, the policy requires agencies to (1)  implement identity, credential, and access management guidelines,  standards, and directives issued by NIST, DHS, and the Office of  Personnel Management; and (2) harmonize their enterprise-wide  approach to ICAM governance, architecture, and acquisition through  activities such as designating an integrated agency-wide ICAM  governance structure and establishing solutions for ICAM services  that are flexible and scalable.

In December 2018, OMB issued a memorandum on the high-value  asset (HVA) program that (1) outlined agency expectations for  establishing agency governance; (2) required agencies to take action  to improve the identification of HVAs; and (3) defined agency  reporting, assessment, and remediation requirements for HVAs. In  March 2018, OMB reported that agencies’ continued to have  challenges in mitigating security vulnerabilities identified across the  federal HVA landscape in its fiscal year 2017 FISMA report to  Congress. In addition, OMB required agencies to report on the  implementation of security controls to protect HVAs during fiscal year  2018.

In October 2018, OMB issued new federal information security and  privacy management guidance that required agencies to (1) report on  the adequacy and effectiveness of their information security  programs, (2) submit a current and prioritized list of HVAs through the  Homeland Security Information Network, and (3) report major  incidents to DHS, OMB, Congress and their agency inspectors  general. In addition, the guidance required agencies to ensure that  DHS has authorization and the information necessary to monitor and  provide technical assistance related to vulnerability scanning.

section_title: OMB Assessed and Reported on Agencies’ Implementation of Federal Information Security Requirements, but the Number of Agencies Scheduled to Participate in CyberStat Meetings Has Declined over the Last 3 Years
paragraphs: In addition to developing and monitoring the implementation of  information security policies, FISMA directs OMB to oversee agencies’  compliance with the act’s requirements to provide information security  protections commensurate with the risk and magnitude of the harm  resulting from unauthorized access, use, disclosure, modification, or  destruction of information or information systems. During fiscal year 2018,  OMB issued four reports summarizing government-wide implementation  of the information security requirements, as described below:  In September 2018, OMB issued an assessment of intrusion detection  and prevention capabilities across the federal enterprise. In its  assessment, OMB briefly described federal agencies’ implementation  of intrusion detection and prevention capabilities through DHS’s  EINSTEIN sensor suite.

In May 2018, OMB issued its Federal Cybersecurity Risk  Determination Report and Action Plan. For this report, OMB  evaluated risk management assessment reports for 96 agencies and  described actions that it and agencies plan to take to address  government-wide cybersecurity gaps. Two major actions discussed in  the report are: (1) federal agencies must consolidate their security  operations center capabilities and processes, or migrate the security  operations center as a service; and (2) OMB, DHS, and other federal  agencies are to assist with implementing the cyber threat framework  developed by the Office of the Director of National Intelligence.

In March 2018, OMB issued its annual FISMA report to Congress for  fiscal year 2017, which summarized the performance of 97 agencies  in implementing effective information security programs and managing  risk, among other things.

In December 2017, OMB released its Report to the President on  Federal IT Modernization, which outlined a vision and  recommendations for the federal government to build a more modern  and secure architecture for federal systems. For example, OMB  described government-wide initiatives intended to improve the  security of federal networks that emphasized perimeter network- based security protections, but had gaps in the application and data- level protections needed to provide complete security. To address  these deficiencies, OMB recommended a layered defensive strategy  in government-wide programs to provide greater defense-in-depth  capabilities that are intended to prevent malicious actors from moving  laterally across linked networks to access valuable information.

Number of Agencies Scheduled for CyberStat Meetings Significantly  Declined Since Fiscal Year 2016  OMB, in coordination with DHS, is responsible for coordinating CyberStat  review meetings. As mentioned previously, FISMA requires OMB to  oversee agency compliance with requirements to provide information  security protections on information and information systems. One means  of fulfilling this oversight responsibility is through CyberStat engagements.  For these engagements, OMB, in coordination with DHS, intends to  engage agency leadership on Administration priorities and perform  outreach to ensure that agencies are taking the appropriate actions to  strengthen their cybersecurity posture.

However, since our September 2017 report on fiscal year 2016 FISMA  implementation, the number of agencies that have participated in a  CyberStat engagement has significantly declined. In fiscal year 2016,  OMB scheduled these engagements with 24 agencies to help develop  action items that address information security risk, identify areas for  targeted assistance, and track performance at the agencies throughout  the year. The number of agencies scheduled to participate in an  engagement decreased to five during fiscal year 2017, and decreased  further to three during fiscal year 2018. As of May 2019, OMB staff in the  Office of the Federal CIO informed us that the agency had not scheduled  any agencies to participate in a CyberStat engagement during fiscal year  2019.

According to OMB officials in the Office of the Federal CIO, updates to  the CyberStat process resulted in extended engagements between DHS,  OMB, and the agencies that lasted 4 to 6 weeks or more. Beginning in  fiscal year 2017, according to DHS’s CyberStat concept of operations,  OMB and DHS took a collaborative approach with the CyberStat process.  Specifically, officials from the participating agencies, OMB’s Cyber and  National Security Unit, and DHS’s Federal Network Resilience (FNR)  division collaborated through these CyberStat engagements to reach a  desired performance outcome at the participating agencies.

DHS’s CyberStat concept of operations states that the department  focuses on agency performance in key federal information security  reporting, including agency FISMA reporting, DHS reports of agency  compliance with binding operational directives, and reports issued by  GAO and agency inspectors general. A DHS official from the  department’s FNR division informed us that it uses these information  security reports to make recommendations to OMB, who then decides  which agencies will be scheduled to participate in a CyberStat  engagement. According to OMB, the three agencies that participated in a  CyberStat engagement initiated during fiscal year 2018 volunteered to do  so after discussing their cybersecurity implementation issues with OMB.

However, as discussed earlier in this report, deficiencies reported in  agency fiscal year 2018 FISMA reports and information security  evaluation reports issued by GAO and inspectors general for fiscal year  2018 indicate that several agencies are in need of OMB and DHS  assistance to improve their information security posture. In addition, the  three agencies that participated in CyberStat engagements scheduled  during fiscal year 2018 saw value in changes resulting from the updated  engagement process. For example, officials from the Office of the CIO  (OCIO) at one of the three agencies stated that the updated process was  more constructive and valuable than the prior CyberStat process that was  based more on a compliance checklist. In addition, OCIO officials at all  three agencies stated that the process helped improve their agencies’  information security posture and that their collaboration with OMB and  DHS was beneficial to assisting with FISMA implementation.

By conducting fewer CyberStat engagements with agencies, OMB loses  an opportunity to assist agencies with improving their information security  posture. Additionally, OMB will limit its ability to oversee specific agency  efforts to provide information security protections for federal information  and information systems.

section_title: Inspector General Reporting Metrics Did Not Sufficiently Cover System Security Plans
paragraphs: FISMA includes reporting requirements for OMB, agency CIOs and  inspectors general. According to OMB’s FISMA reporting guidance, OMB  and DHS collaborate with interagency and inspector general partners to  develop the CIO and inspector general metrics, which are intended to  facilitate agencies’ compliance with FISMA-related reporting  requirements. These entities created separate sets of reporting metrics  for agency CIOs and agency inspectors general.

However, the inspector general reporting metrics did not specifically  address the development and maintenance of system security plans,  although subordinate plans, such as system security plans, are a key  element of an agency-wide information security program required by  FISMA.

OMB officials in the Office of the Federal CIO informed us that, while they  work in coordination with CIGIE to establish the reporting metrics, CIGIE  is ultimately responsible for developing the metrics. According to both the  published metrics and OMB’s guidance memorandum, OMB collaborates  with DHS and inspector general partners to develop the IG FISMA  metrics. According to representatives from CIGIE, the existence of  system security plans is addressed in multiple questions within the  reporting metrics, which is in alignment with OMB’s focus toward ongoing  assessments and authorizations.

Nevertheless, our review of the reporting metrics and supplemental  evaluation guide did not identify any reference to the development and  maintenance of system security plans. The lack of a defined reporting  metric for addressing agency system security plans could lead to  inconsistent reporting by inspectors general. Until such a metric is  developed and reported on, OMB will not have reasonable assurance that  inspectors general evaluations appropriately address each of the required  elements of an information security program.

section_title: DHS Continued to Issue Cybersecurity-related Directives and Assist Agencies by Providing Common Security Capabilities
paragraphs: Under FISMA, DHS, in consultation with OMB, is responsible for carrying  out various activities, including developing and overseeing the  implementation of binding operational directives and providing operational  and technical assistance to agencies.

Over the last 2 years, DHS had developed four binding operational  directives as of April 2019, as required by FISMA. These directives  instructed agencies to:  remove and discontinue use of all present and future Kaspersky-  branded products; enhance email security by adopting domain-based message  authentication, reporting and conformance (DMARC) to prevent  email spoofing and web security by ensuring all publicly accessible  federal websites provides services through a secure connection;  submit a current and prioritized high-value asset list to DHS and if  selected, participate in risk and vulnerability assessments; and  review and remediate critical and high vulnerabilities on internet- facing systems within 15 and 30 calendar days of initial detection,  respectively.

We have ongoing work evaluating DHS’s process to develop and oversee  the implementation of binding operational directives as part of another  engagement. We will report on the results of this evaluation in a separate  report.

DHS also provided operational and technical assistance to agencies  through its Continuous Diagnostics and Mitigation (CDM) and National  Cybersecurity Protection System (NCPS) programs. DHS is taking steps  to deploy the CDM and NCPS capabilities to all participating federal  agencies to enhance detection of cyber vulnerabilities and protection from  cyber threats.

Continuous Diagnostics and Mitigation program (CDM). The program  is to provide federal departments and agencies with commercial off-the- shelf capabilities and tools that identify cybersecurity risks on an ongoing  basis, prioritize these risks based upon potential impacts, and enable  cybersecurity personnel to mitigate the most significant problems first. In  December 2018, we reported that the department was in the process of  enhancing the capabilities of federal agencies to automate network  monitoring for malicious activity through its CDM program.

In our December report, we also recommended that DHS coordinate  further with federal agencies to identify training and guidance needs for  implementing CDM. DHS plans to complete implementation of our  recommendation this fiscal year. In addition, we have an ongoing review  to evaluate the extent to which selected agencies have effectively  implemented CDM and to identify practices for effective and efficient  implementation of the program. We will report on the results of this review  separately.

National Cybersecurity Protection System (NCPS). The program is  one of the tools to aid federal agencies in mitigating information security  threats. The system is intended to provide DHS with the capability to  provide four cyber-related services to federal agencies: intrusion  detection, intrusion prevention, analytics, and information sharing.

In January 2016, we made nine recommendations to further improve  NCPS capabilities by, among other things, developing metrics that clearly  measure the effectiveness of NCPS’s efforts, including the quality,  efficiency, and accuracy of actions related to detecting and preventing  intrusions, providing analytic services, and sharing cyber-related  information. As of June 2019, DHS had implemented six of our nine  recommendations and plans to implement the remainder by the end of  this fiscal year.

section_title: NIST Continues to Provide Information Security Guidance to Agencies
paragraphs: According to FISMA, NIST is to develop information security standards  and guidelines, in coordination with OMB and DHS. Specifically, NIST’s  Computer Security Division is responsible for developing cybersecurity  standards, guidelines, tests, and metrics for the protection of federal  information systems.

NIST has developed information security guidelines for federal agencies.  Specifically, in April 2018, NIST issued an update to its cybersecurity  framework that it originally issued in February 2014. Although the  cybersecurity framework was initially intended for critical infrastructure,  Executive Order 13800 requires federal agencies to use the cybersecurity  framework to also manage their cybersecurity risk. The revised  framework includes a new section on cybersecurity measurement; an  expanded explanation of using the framework for cyber supply chain risk  management; refinements to authentication, authorization, and identity  proofing policies within access controls; and a new section on using the  cybersecurity framework to understand and assess an organization’s  cybersecurity risk.

In May 2017, NIST published draft guidance for agencies to use in  implementing the cybersecurity framework. This publication is intended  to provide guidance on the use of the framework in conjunction with the  current and planned suite of NIST security and privacy risk management  publications, such as NIST Special Publication 800-53. According to NIST  officials in the agency’s Computer Security Division, the agency is in the  process of finalizing the implementation guidance and plans to publish the  final version by the end of fiscal year 2019.

Further, in December 2018, NIST released the revised Risk Management  Framework for Information Systems and Organizations (risk management  framework). According to NIST, the update provides an integrated,  robust, and flexible methodology to address security and privacy risk  management. Among the changes in the updated version is the  integration of privacy risk management into the existing information  security risk management processes. In addition, the risk management  framework includes direct references to the cybersecurity framework,  which demonstrates how organizations that implement the risk  management framework can also achieve the outcomes of the  cybersecurity framework.

In April 2019, NIST released revised guidance on vetting the security of  mobile applications. According to NIST, the revised publication provides  guidance for planning and implementing a mobile application vetting  process, developing security requirements for mobile applications,  identifying appropriate tools for testing mobile applications, and  determining if a mobile application is acceptable for deployment on an  organization’s mobile devices.

In addition, NIST is currently developing a privacy framework to help  improve agencies’ privacy risk management. In April 2019, NIST issued a  discussion draft for its privacy framework. According to the discussion  draft, NIST will use feedback received on the discussion draft to develop  a preliminary draft of the privacy framework, which is intended to assist  organizations in identifying, assessing, and responding to privacy risks.  Further, the framework is intended to foster the development of innovative  approaches to protecting individuals’ privacy and increase trust in  systems, products and services. According to NIST officials, the agency  continues to engage stakeholders, both nationally and internationally,  through roundtable meetings, webinars, and public workshops to solicit  stakeholder input to inform development of this framework. NIST’s  website states that the agency anticipates publishing the privacy  framework in October 2019.

section_title: Conclusions
paragraphs: Federal agencies continued to have deficiencies in implementing  information security programs and practices. Inspectors general reported  that 18 of 24 CFO Act agencies did not have effective agency-wide  information security programs in fiscal year 2018. In addition, most of the  selected agencies had deficiencies in the five core security functions. We  and the inspectors general have made thousands of recommendations  aimed at improving information security programs and practices over the  years. Implementation of these recommendations will assist agencies in  strengthening their information security policies and practices.

OMB, DHS, and NIST have issued directives and guidance and  implemented programs that, to some extent, have improved agencies’  security posture. However, OMB has not issued its report to Congress on  the effectiveness of agencies’ information security policies and practices  for fiscal year 2018, although the report was due several months ago.  Further, while agencies indicated that the collaborative CyberStat  engagements with DHS and OMB have aided with their FISMA  implementation, the number of these engagements has declined  significantly. In addition, the OMB-approved metrics that inspectors  general use to evaluate FISMA implementation do not include one of the  elements—system security plans—required by FISMA for information  security programs. By not including this element, oversight of agencies’  information security programs has been diminished.

section_title: Recommendations for Executive Action
paragraphs: We are making the following three recommendations to OMB:  The Director of OMB should submit the statutorily required report to  Congress on the effectiveness of agencies’ information security policies  and practices during the preceding year. (Recommendation 1)

The Director of OMB should expand its coordination of CyberStat review  meetings for those agencies with a demonstrated need for assistance in  implementing information security. (Recommendation 2)

The Director of OMB should collaborate with CIGIE to ensure that the  inspector general reporting metrics include the FISMA-required  information security program element for system security plans.  (Recommendation 3)

section_title: Agency Comments and Our Evaluation
paragraphs: We provided a draft of this report to OMB and the 28 selected agencies  for review and comment. In response, OMB provided comments orally  and via email in which the office, respectively, generally concurred with  our first two recommendations and concurred with a revised version of  our third recommendation.

Specifically, in oral comments, officials in the Office of the Federal Chief  Information Officer noted actions that they said OMB plans to take to  address our first two recommendations. According to these officials, the  office plans to issue its fiscal year 2018 report to Congress on the  effectiveness of agencies’ information security policies and practices in  the near future. In addition, the office plans to continue to collaborate with  DHS to identify information security gaps at agencies and work with  agencies to address those gaps in CyberStat meetings or by other  means.

With regard to our third recommendation, the officials expressed concern  with the wording of the recommendation in our draft report, which related  to OMB updating the IG metrics. They noted that CIGIE, rather than  OMB, is responsible for updating these metrics. Accordingly, we revised  the recommendation to emphasize the need for OMB to collaborate with  CIGIE.

In a subsequent email from our OMB liaison, the office concurred with the  revised recommendation. The office emphasized its plans to continue  working collaboratively with the inspector general community to assist  with improving and evolving the metrics to ensure that the metrics  address FISMA requirements.

OMB also provided technical comments, which we incorporated, as  appropriate.

In addition, five of the 28 selected agencies provided written responses  regarding the draft report:  In its response (reprinted in appendix III), the Department of Housing  and Urban Development stated that it had reviewed our draft report  and had no comments.

In its comments (reprinted in appendix IV), the Department of  Veterans Affairs stated that it remains committed to complying with  the requirements of FISMA and to safeguarding the department’s  systems and data, which support the delivery of care, benefits, and  services to veterans. The department also stated that it continues to  prioritize efforts to address our prior information security-related  recommendations to the department.

In its response (reprinted in appendix V), the Environmental  Protection Agency stated that it had reviewed our draft report and had  no comments.

In its comments (reprinted in appendix VI), the Social Security  Administration stated that it will continue to improve its cybersecurity  safeguards and looks forward to receiving additional guidance to  assist the agency with its efforts.

In its comments (reprinted in appendix VII), the U.S. Agency for  International Development stated that it has developed, documented,  and implemented an agency-wide program to provide security for its  information and systems, pointing out that its inspector general  reported that the agency had an effective program in fiscal year 2018.  The agency also cited its commitment to continuing compliance with  FISMA’s requirements and to safeguarding its information technology  services to facilitate its mission.

Further, four of the selected agencies—the Departments of Commerce,  Homeland Security, and Transportation, as well as the National Science  Foundation—also provided technical comments which we have  incorporated in the report, where appropriate.

The remaining 19 selected agencies provided emails stating that they had  no comments on the report. These agencies were the Departments of  Agriculture, Defense, Education, Energy, Health and Human Services,  the Interior, Justice, Labor, State, and the Treasury; and the Federal  Communications Commission; Federal Retirement Thrift Investment  Board; General Services Administration; Merit System Protection Board;  National Aeronautics and Space Administration; Nuclear Regulatory  Commission; Office of Personnel Management; Presidio Trust; and Small  Business Administration.

We are sending copies of this report to appropriate congressional  committees, the Director of OMB, the heads of the CFO Act agencies and  their inspectors general, the heads of four selected non-CFO Act  agencies, and other interested congressional parties. In addition, the  report is available at no charge on the GAO website at  http://www.gao.gov.

If you or your staff have any questions about this report, please contact  Gregory C. Wilshusen at (202) 512-6244 or wilshuseng@gao.gov.  Contact points for our Offices of Congressional Relations and Public  Affairs may be found on the last page of this report. GAO staff who made  key contributions to this report are listed in appendix VIII.

section_title: Appendix I: Objectives, Scope, and Methodology
paragraphs: Our objectives were to (1) describe the reported adequacy and  effectiveness of selected federal agencies’ information security policies  and practices and (2) evaluate the extent to which the Office of  Management and Budget (OMB), the Department of Homeland Security  (DHS), and the National Institute of Standards and Technology (NIST)  have implemented their government-wide Federal Information Security  Modernization Act of 2014 (FISMA) requirements.

To describe the reported adequacy and effectiveness of federal agencies’  information security policies and practices, we analyzed our, agency, and  inspectors general information security-related reports for 16 selected  agencies. Our selection of 16 agencies included 12 Chief Financial  Officers (CFO) Act of 1990 agencies and four non-CFO Act agencies. To  select the 12 CFO Act agencies, we first ranked the 23 civilian CFO Act  agencies by the number of information security systems each agency  reported operating in fiscal year 2017. We then separated the agencies  into large, medium, and small categories based on the number of  systems they reported, and selected four agencies from each category  using a random number generator. To select the four non-CFO Act  agencies, we listed the 73 non-CFO Act agencies reported in OMB’s  annual FISMA report to Congress for fiscal year 2017 and then randomly  selected four agencies. Although we randomly selected agencies and  assured we had CFO Act and non-CFO Act agencies, due to the small  number of agencies examined, results based on these agencies do not  generalize beyond the agencies reviewed.

The 16 agencies were the Departments of the Agriculture, Commerce,  Education, Housing and Urban Development, Justice, Labor, State, and  the Treasury; the Environmental Protection Agency; Federal  Communications Commission; Federal Retirement Thrift Investment  Board; Merit Systems Protection Board; National Aeronautics and Space  Administration; Presidio Trust; Small Business Administration; and the  Social Security Administration. For these agencies, we analyzed,  categorized, and summarized weaknesses identified in inspector general  and GAO reports using the NIST Framework for Improving Critical  Infrastructure Cybersecurity (cybersecurity framework) core security  functions and the eight elements of information security programs  required by FISMA.

In addition, for the 24 agencies covered by the CFO Act, we summarized  (1) the inspector general ratings of agency-wide information security  programs and (2) the inspector general designation of information  security as a significant deficiency or a material weakness for financial  reporting systems as reported for fiscal year 2018. For the 23 civilian  agencies covered by the CFO Act, we summarized fiscal year 2018  agency Chief Information Officer (CIO) reports of their agency’s progress  in meeting targets for implementing cyber capabilities supporting the  Administration’s cybersecurity-related Cross-Agency Priority (CAP) goal.

To gain insight into how agencies collect, report, and ensure the accuracy  and completeness of the FISMA data they report, we analyzed  documentation describing and supporting the processes at eight of the 16  selected agencies to ensure the accuracy and completeness of those  data. We also interviewed officials at the eight agencies to obtain  additional information on the quality controls implemented on the system  used for FISMA reporting. The eight agencies selected were the  Departments of Education, Justice, Labor, and the Treasury; the Federal  Communications Commission; National Aeronautics and Space  Administration; Presidio Trust; and the Small Business Administration.  These agencies were randomly selected from the list of 16 agencies  described above. Based on our assessment, we determined that the data  were sufficiently reliable for the purpose of our reporting objectives.

To evaluate the extent to which OMB, DHS, and NIST have implemented  FISMA requirements, we analyzed the FISMA provisions to identify  federal responsibilities for OMB, DHS, and NIST. We evaluated  documentation of these agencies’ government-wide responsibilities to  determine if the agencies were meeting FISMA requirements, including  documentation obtained from their websites. Specifically, for OMB, we  collected and reviewed information security-related policies and guidance  that it issued since we last reported in September 2017. We also obtained  reports issued by OMB to determine the extent to which the agency had  overseen the policies and guidelines it issued, as well as other agency  efforts for improving information security. In addition, we analyzed fiscal  year 2018 inspector general and CIO FISMA reporting metrics to  determine if the metrics sufficiently addressed the agency-wide  information security program elements required by FISMA. We also  interviewed OMB officials to obtain information on any actions they have  planned or taken to improve the information security posture of the  federal government.

Further, we interviewed OMB and DHS officials to understand their  process for scheduling CyberStat engagements with senior agency  officials. We also interviewed officials at the three agencies that  participated in a CyberStat engagement initiated during fiscal year 2018  to understand the benefits and challenges of their collaboration with OMB  and DHS.

For DHS, we reviewed and summarized a recently issued GAO report  describing updates to the department’s Continuous Diagnostic and  Mitigation Program and National Cybersecurity Protection System. We  also collected and summarized the binding operational directives issued  by DHS over the last 2 years. Further, we interviewed DHS officials to  obtain information on any actions they have planned or taken to improve  the information security posture of the federal government.

For NIST, we collected and summarized the standards and guidance  issued or updated by the agency since the start of fiscal year 2018. We  also interviewed NIST officials and obtained information on draft  standards and guidance to describe NIST’s current and planned efforts to  help improve the information security posture of the federal government.

We conducted this performance audit from December 2018 to July 2019  in accordance with generally accepted government auditing standards.  Those standards require that we plan and perform the audit to obtain  sufficient, appropriate evidence to provide a reasonable basis for our  findings and conclusions based on our audit objectives. We believe that  the evidence obtained provides a reasonable basis for our findings and  conclusions based on our audit objectives.

section_title: Appendix II: Cybersecurity Framework
paragraphs: The National Institute of Standards and Technology established the  cybersecurity framework to provide guidance for cybersecurity activities  within the private sector and government agencies at all levels. The  cybersecurity framework consists of five core functions: identify, protect,  detect, respond, and recover. Within the five functions are 23 categories  and 108 subcategories that define discrete outcomes for each function,  as described in table 5.

section_title: Appendix III: Comments from the Department of Housing and Urban Development

section_title: Appendix IV: Comments from the Department of Veterans Affairs

section_title: Appendix V: Comments from the Environmental Protection Agency

section_title: Appendix VI: Comments from the Social Security Administration

section_title: Appendix VII: Comments from the U.S. Agency for International Development

section_title: Appendix VIII: GAO Contacts and Staff Acknowledgments
subsections: section_title: GAO Contact

section_title: Staff Acknowledgments
paragraphs: In addition to the individual named above, Jeffrey Knott (assistant  director), Di’Mond Spencer (analyst-in-charge), Andrew Ahn, Chris  Businsky, Fatima Jahan, and Priscilla Smith made key contributions to  this report.

Fast facts: A 2014 law requires federal agencies to have information security programs. The Office of Management and Budget oversees these efforts. We looked at how agencies and OMB have implemented the law and found:

Of our sample of 16 agencies, most had weaknesses in most security control areas

Inspectors General reported ineffective programs at 18 of 24 major agencies

OMB coordinated cybersecurity review meetings with 3 agencies in fiscal year 2018, compared to 24 in 2016

Our recommendations to OMB include holding those meetings at more agencies that need them. Federal information security has been a topic on our High Risk List since 1997.

Question-summary annotations: questions: question: What was the problem with federal agencies during fiscal year 2018 regarding their information security policies and practices?
answer: During fiscal year 2018, many federal agencies were often not adequately or effectively implementing their information security policies and practices.
child_questions: question: What did GAO find about federal agencies regarding their information security issue?
answer: For example, most of the 16 agencies GAO selected for review had deficiencies related to implementing the eight elements of an agency-wide information security program required by the Federal Information Security Modernization Act of 2014 (FISMA) (see figure) .

question: What did inspectors general (IGs) find about federal agencies regarding their information security issue?
answer: Further, inspectors general (IGs) reported that 18 of the 24 Chief Financial Officers (CFO) Act of 1990 agencies did not have effective agency-wide information security programs.

question: How did agencies respond to the recommendations from GAO and IGs?
answer: GAO and IGs have previously made numerous recommendations to agencies to address such deficiencies, but many of these recommendations remain unimplemented.

questions: question: What government-wide FISMA requirements did OMB, DHS and NIST implement?
answer: With certain exceptions, the Office of Management and Budget (OMB), Department of Homeland Security (DHS), and National Institute of Standards and Technology (NIST) were generally implementing their government-wide FISMA requirements, including issuing guidance and implementing programs that are intended to improve agencies' information security.

question: How did OMB fail to implement its government-wide FISMA requirements?
answer: However, OMB has not submitted its required FISMA report to Congress for fiscal year 2018 and has reduced the number of agencies at which it holds CyberStat meetings from 24 in fiscal year 2016 to three in fiscal year 2018—thereby restricting key activities for overseeing agencies' implementation of information security.
child_questions: question: Further, why was it problematic to not include a metric system?
answer: Also, OMB, in collaboration with the Council of Inspectors General for Integrity and Efficiency (CIGIE), did not include a metric for system security plans, one of the required information security program elements, in its guidance on FISMA reporting.

question: What was the result of the lack of a metric for system security plans in OMB's guidance on FISMA reporting?
answer: As a result, oversight of agencies' information security programs was diminished.

questions: question: What does GAO need to periodically report to Congress given the provision included in FISMA?
answer: FISMA includes a provision for GAO to periodically report to Congress on agencies' implementation of the act.
child_questions: question: What are GAO's objectives in this report?
answer: GAO's objectives in this report were to (1) describe the reported adequacy and effectiveness of selected federal agencies' information security policies and practices and (2) evaluate the extent to which OMB, DHS, and NIST have implemented their government-wide FISMA requirements.
child_questions: question: How did GAO fulfill its objectives in this report?
answer: GAO categorized information security deficiencies as reported by 16 randomly selected agencies and their IGs according to the elements of an information security program; evaluated IG reports for 24 CFO Act agencies; examined OMB, DHS, and NIST documents; and interviewed agency officials.