Federal Information Security Management Act of 2002

Enacted in 2002, the Federal Information Security Management Act (FISMA), was passed to support the E-Government Act of 2002. Without information security, it is impossible for government to deliver reliable services through electronic means. The advent of Internet delivery and cloud computing immensely complicates the security problem.

Nevertheless, there may well be solutions for these new environments, if proper perspective is kept. In any security context, there is acceptance of responsibility, as well as acceptance of risk. An approach to security purely in the network has long been endpoint security, leaving the network encrypted. When the servers are outsourced, it may be that endpoint encryption will remain under control of the owning agency, but audit is the main tool for checking on the server operator. Microsoft, for example, is proposing the "locking down" of desktops as one side of the security architecture; the other extreme was an uncontrolled desktop coming through active defenses, in the U.S. Department of Transportation response to Conficker

There must always be an owner for every function, but the granularity of ownership can legitimately vary for different security functions, and for different missions within a common computing utility.

Guidance for implementing FISMA comes from the Computer Security Resource Center, Computer Systems Division, National Institute of Standards and Technology. There are two phases in the startup, the first of which is complete:

1. Phase I: Standards and Guidelines Development (2003-2008)
2. Phase II: Organizational Credentialing Program (2007-2010)

In the second phase are the activities:

1. Training Initiative: This initiative will include development of training courses, NIST publication Quick Start Guides (QSG’s), and Frequently Asked Questions (FAQ’s) to establish a common understanding of the NIST standards and guidelines supporting the NIST Risk Management Framework.
2. Product and Services Assurance Assessment Initiative: This initiative will include defining criteria and guidelines for evaluating products and services used in the implementation of SP 800-53-based security controls.
3. Support Tools Initiative: This initiative will include identifying or developing common protocols, programs, reference materials, checklists, and technical guides supporting implementation and assessment of SP 800-53-based security controls in information systems.
4. Harmonization Initiative: Important for minimizing duplication of effort for organizations that must demonstrate compliance to both FISMA and ISO requirements, this initiative will include identifying common relationships and the mappings of FISMA standards, guidelines and requirements with:

• • ISO 27000 series information security management standards
  • ISO 9000 and 17000 series quality management, and laboratory testing and accreditation standards.

Framework

Technical definitions and framework are in Federal Information Processing Standard (FIPS) FIPS PUB 199, "Standards for the Security Categorization of Federal Information and Information Systems". While the detailed guidance is in additional guidance, FIPS 199 interprets FISMA as having three dimensions of security categorization:

• Confidentiality
• Integrity
• Availability

and matrixes these against potential impact characterized as low, medium and high:

Factor
	Low	Medium	High
Confidentiality	row 1, cell 2	row 1, cell 3
Integrity	row 2, cell 2	row 2, cell 3
Availability	row 2, cell 2	row 2, cell 3

Solution architecture

For designing FISMA implementations, the primary reference is NIST Special Publication 800-53, Revision 3, "Recommended Security Controls for Federal Information Systems and Organizations". This document identifies a number of security controls that may or may not be applicable to a particular information system.

Those of the Management class involve initial and continuing policy decisions. The Operational class addresses procedures and validation for daily operations, while the Technical class deals with tool selection and implementation.

IDENTIFIER	FAMILY	CLASS
AC	Access control	Technical
AT	Awareness and Training	Operational
AU	Audit and accountability	Technical
CA	Security assessment and authorization	Management
CM	Configuration management	Operational
CP	Contingency Planning	Operational
IA	Identification and authentication	Technical
IR	Incident response	Operational
MA	Maintenance	Operational
MP	Information systems media protection	Operational
PE	Information facility physical and environmental protection	Operational
PL	Planning	Management
PS	Personnel security	Operational
RA	Risk assessment	Management
SA	System and Services Acquisition	Management
SC	System and communications protection	Technical
SI	System and information integrity	Operational
PM	Program Management	Management

Criticism

In April 2009, Senator Thomas Carper (D-Delaware) introduced two pieces of legislation to force more actual compliance and less paper reporting of hypothetical compliance.

Status

On May 19, 2009, the House took testimony at the required 60-day reporting interval after start of FISMA implementation. Vivek Kundra, the Federal Chief Information Officer, summarized the overall status: "recent successful breaches at the Federal Aviation Administration and at the vendor that hosts USAjobs.gov demonstrate that the current state of information security at Federal agencies is not what the American people have the right to expect. The Federal Information Security Management Act (FISMA) has been in place for 7 years. It has raised the level of awareness in the agencies and in the country at large, but we are not where we need to be." OMB identified the following key issues:

• The performance information currently collected under FISMA does not fully reflect the security posture of Federal agencies;
• The processes used to collect the information are cumbersome, labor‐intensive, and take time away from meaningful analysis, and;
• The Federal community is focused on compliance, not outcomes

Department of Homeland Security

At the same hearing, Margaret Graves, CIO of the U.S. Department of Homeland Security, spoke more specifically about implementation in a real agency. DHS is both a user and a provider of FISMA-regulated cloud computing.

It provides the services through "OneNet", which not only collapsed a set of wide area networks into one, but needed to reconcile policy differences among the legacy network owners, without either limiting information sharing or dropping to the lowest common level of security. To do this, within the transmission infrastructure are mission-unique Trust Zones through the implementation of a series of Policy Enforcement Points (PEPs).

PEPs are comprised of hardware and software packages positioned throughout the network, as well as appropriate management functions at the SOC. Specifically, each PEP will include an enterprise-managed firewall to resolve policy differences, and sophisticated monitoring capabilities that will allow the operations center to track threats.

The major threat is phishing. "Security controls for email must be strengthened, and we are adding some email specific features to the Trusted Internet Connections that will allow us to further improve our ability to detect and respond to malicious emails."

• Additionally, each data center now houses one of the two Trusted Internet Connections that have been designed with sophisticated threats in mind. Further, the Department’s new data centers deliver utility computing and Infrastructure as a Service, allowing DHS to realize the benefits of cloud computing while also providing the security so necessary for the threats we face today.

Systems integrator perspective

Also testifying was Samuel Chun, director of the cyber security practice of EDS' Public Sector, now a division of Hewlett-Packard. Chun described the deficiencies his organization has encountered in implementing FISMA:

• "There is too much emphasis on the generation of paper reports for compliance, certification and accreditation, and auditing."
• The correlation between compliance and operating performance is unclear. We’ve observed that some of the most well defended agencies consistently receive poor report cards. In addition, a single grade assigned to a large and diverse agency with many components only generalizes the picture and may not, in fact, provide proper warning of a material vulnerability to mission performance to the agency’s mission owners. A more granular approach to reporting that highlights operating performance -- in addition to compliance -- will likely provide more clarity. (OMB guidance on granularity)
• Accountability for good and poor compliance is unclear...it is not transparent how that "report cards" are used for the purposes of budgeting, rewards, and assigning accountability. "For system integrators, however, there is a clear process for receiving and maintaining the authority to operate through the certification and accreditation process that impact us directly. There should be equally transparent accountability for poor performance. We reiterate our support for the appointment of a new cyber official who can address these concerns."
• "Compliance to FISMA measures how well an agency has accounted for, and applied risk and security management standards, processes, and plans for, information systems. The inference is that as long as the standards, processes and plans are sound, the operational security of an agency is thereby effective." He believes that direct mesures may be superior to the indirect measures. Direct measures, would be more rigorous, such as:

number of attacks defended against

the mean time to patch a vulnerability

number of incidents to which an agency has responded

percent of applications tested would provide more

• Rapidly emerging threats may be outpacing compliance efforts; EDS recommends US-CERT and the NSA rather than NIST

Department of Transportation

There is also experience from the U.S. Department of Transportation. They do not, for example, "scan personal computers used for telework at a detailed level, [they] ensure that minimum security requirements are met...Conficker was managed by connecting "through the DOT secure remote access (SRA) and virtual private network (VPN) systems had active local firewalls installed, and an active antivirus solution."

Reporting and reporting tools

In apparent agreement with the concern about paper reporting, OMB will require an automated reporting tool. The memorandum dictating the tool also gives guidance on reporting.

Paper dependence

FISMA has been criticized, by legislators and legislative agencies, for being too dependent on manual paper procedures and not enough on specific enforcement technologies and procedures.

Granularity

OMB FAQ #6 addresses granularity of reporting: "Agencies must provide an overall agency view of their security and privacy program but most of the topic areas also require specific responses for each of the major components (e.g., bureaus or operating divisions). Thus, the agencies’ and OMB’s report can distinguish good performing components from poor performers and more accurately reflect the overall agency performance.