Letter from GAO on how Congress can fix FISMA.  And oh yeah, the press coverage on it.

Now supposedly this was in response to an inquiry from Congress about “Please comment on the need for improved cyber security relating to S.773, the proposed Cybersecurity Act of 2009.”  This is S.773.

GAO is mixing issues and has missed the mark on what Congress asked for.  S.773 is all about protecting critical infrastructure.  It only rarely mentions government internal IT issues.  S.773 has nothing at all to do with FISMA reform.  However, GAO doesn’t have much expertise in cybersecurity outside of the Federal Agencies (they have some, but I would never call it extensive), so they reported on what they know.

The GAO report used the often-cited metric of an increase in cybersecurity attacks against Government IT systems growing from “5,503 incidents reported in fiscal year 2006 to 16,843 incidents in fiscal year 2008″ as proof that the agencies are not doing anything to fix the problem.  I’ve questioned these figures before, it’s associated with the measurement problem and increased reporting requirements more than an increase in attacks.  Truth be told, nobody knows if the attacks are increasing and, if so, at what rate.  I would guess they’re increasing, but we don’t know, so quit citing some “whacked” metric as proof.

Reform photo by shevy.

GAO’s recommendations for FISMA Reform:

Clarify requirements for testing and evaluating security controls.  In other words, the auditing shall continue until the scores improve.  Hate to tell you this, but really all you can test at the national level is if the FISMA framework is in place, the execution of the framework (and by extension, if an agency is secure or not) is largely untestable using any kind of a framework.

Require agency heads to provide an assurance statement on the overall adequacy and effectiveness of the agency’s information security program.  This is harkening back to the accounting roots of GAO.  Basically what we’re talking here is for the agency head to attest that his agency has made the best effort that it can to protect their IT.  I like part of this because part of what’s missing is ”executive support” for IT security.  To be honest, though, most agency heads aren’t IT security dweebs, they would be signing an assurance statement based upon what their CIO/CISO put in the executive summary.

Enhance independent annual evaluations.  This has significant cost implications.  Besides, we’re getting more and more evaluations as time goes on with an increase in audit burden.  IE, in the Government IT security space, how much of your time is spent providing proof to auditors versus building security?  For some people, it’s their full-time job.

Strengthen annual reporting mechanisms.  More reporting.  I don’t think it needs to get strengthened, I think it needs to get “fixed”.  And by “fixed” I mean real metrics.  I’ve touched on this at least a hundred times, go check out some of it….

Strengthen OMB oversight of agency information security programs.  This one gives me brain-hurt.  OMB has exactly the amount of oversight that they need to do their job.  Just like more auditing, if you increase the oversight and the people doing the execution have the same amount of people and the same amount of funding and the same types of skills, do you really expect them to perform differently?

Rybolov’s synopsis:

When the only tool you have is a hammer, every problem looks like a nail, and I think that’s what GAO is doing here.  Since performance in IT security is obviously down, they suggest that more auditing and oversight will help.  But then again, at what point does the audit burden tip to the point where nobody is really doing any work at all except for answering to audit requests?

Going back to what Congress really asked for, We run up against a problem.  There isn’t a huge set of information about how the rest of the nation is doing with cybersecurity.  There’s the Verizon DBIR, the Data Loss DB, some surveys, and that’s about it.

So really, when you ask GAO to find out what the national cybersecurity situation is, all you’re going to get is a bunch of information about how government IT systems line up and maybe some anecdotes about critical infrastructure.

Coming to a blog near you (hopefully soon): Rybolov’s 5 steps to “fix” FISMA.

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Ack, Plans of Action and Milestones.  I love them and I hate them.

For those of you who “don’t habla Federali”, a POA&M is basically an IOU from the system owner to the accreditor that yes, we will fix something but for some reason we can’t do it right now.  Usually these are findings from Security Test and Evaluation (ST&E) or Certification and Accreditation (C&A).  In fact, some places I’ve worked, they won’t make new POA&Ms unless they’re traceable back to ST&E results.

Functions that a POA&M fulfills:

• Issue tracking to resolution
• Serves as a “risk register”
• Used as the justification for budget
• Generate mitigation metrics
• Can be used for data-mining to find common vulnerabilities across systems

But today, we’re going to talk about POA&M abuse.  I’ve seen my fair share of this.

Conflicting Goals: The basic problem is that we want POA&Ms to satisfy too many conflicting functions.  IE, if we use the number of open POA&Ms as a metric to determine if our system owners are doing their job and closing out issues but we also turn around and report these at an enterprise level to OMB or at the department level, then it’s a conflict of interest to get these closed as fast as possible, even if it means losing your ability to track things at the system level or to spend the time doing things that solve long-term security problems–our vulnerability/weakness/risk management process forces us into creating small, easily-to-satisfy POA&Ms instead of long-term projects.

Near-Term v/s Long-Term:  If we set up POA&Ms with due dates of 30-60-90 (for high, moderate, and low risks) days, we don’t really have time at all to turn these POA&Ms into budget support.  Well, if we manage the budget up to 3 years in advance and we have 90 days for high-risk findings, then that means we’ll have exactly 0 input into the budget from any POA&M unless we can delay the bugger for 2 years or so, much too long for it to actually be fixable.

Bad POA&Ms:  Let’s face it, sometimes the one-for-one nature of ST&E, C&A, and risk assessment findings to POA&Ms means that you get POA&Ms that are “bad” and by that I mean that they can’t be satisfied or they’re not really something that you need to fix.

Some of the bad POA&Ms I’ve seen, these are paraphrased from the original:

• The solution uses {Microsoft|Sun|Oracle} products which has a history of vulnerabilities.
• The project team needs to tell the vendor to put IPV6 into their product roadmap
• The project team needs to implement X which is a common control provided at the enterprise level
• The System Owner and DAA have accepted this risk but we’re still turning it into a POA&M
• This is a common control that we really should handle at the enterprise level but we’re putting it on your POA&M list for a simple web application

Plan of Action for Refresh Philly photo by jonny goldstein.

Keys to POA&M Nirvana:  So over the years, I’ve observed some techniques for success in working with POA&Ms:

• Agree on the evidence/proof of POA&M closure when the POA&M is created
• Fix it before it becomes a POA&M
• Have a waiver or exception process that requires a cost-benefit-risk analysis
• Start with”high-level” POA&Ms and work down to more detailed POA&Ms as your security program matures
• POA&Ms are between the System Owner and the DAA, but the System Owner can turn around and negotiate a POA&M as a cedural with an outsourced IT provider

And then the keys to Building Good POA&Ms:

• Actionable–ie, they have something that you need to do
• Achievable–they can be accomplished
• Demonstrable–you can demonstrate that the POA&M has been satisfied
• Properly-Scoped–absorbed at the agency level, the common control level, or the system level
• They are SMART: Specific, Manageable, Attainable, Relevant, and within a specified Timeframe
• They are DUMB: Doable, Understandable, Manageable, and Beneficial

Yes, I stole the last 2 bullets from the picture above, but they make really good sense in a way that “know thyself” is awesome advice from the Oracle at Delphi.

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Rybolov’s comment: This is Ian’s response to the comments for his post on Cybersecurity Coming to a Boil.  It was such a good dialog that he wanted to make a large comment which as we all know, eventually transforms itself into a blog post.  =)

You are making some excellent points; putting the leadership of the Administration’s new Cyber security initiative directly in the White House might appear to be a temporary solution or a quick fix. From my point of view, it looks more like an honest approach. By that I mean that I think the Administration is acknowledging a few things:

• This is a significant problem
• There is no coherent approach across the government
• There is no clear leadership or authority to act on the issue across the government
• Because of the perception that a large budget commitment will have to be allocated to any effective solution, many Agencies are claiming leadership or competing for leadership to scoop up those resources
• The Administration does not know what the specific solution they are proposing is — YET

I think this last point is the most important and is driving the 60-day security assessment. I also think that assessment is much more complex than a simple review of FISMA scores for the past few years. I suspect that the 60-day review is also considering things like legal mandates and authorities for various aspects of Cyber security on a National level. If that is the case, I’m not familiar with a similar review ever having taken place.

2004 World Cyber Games photo by jurvetson.  Contrary to what the LiquidMatrix Security folks might think, the purpose of this post isn’t to jam “cyber” into every 5th word.  =)

So, where does this take us? Well, I think we will see the Cyber Security Czar, propose a unified policy, a unified approach and probably some basic enabling legislation. I suspect that this will mean that the Czar will have direct control over existing programs and resources. I think the Cyber Security Czar taking control of Cyber Security-related research programs will be one of the most visible first steps toward establishing central control.

From this we will see new organizational and reporting authorities that will span existing Agencies. I think we can also anticipate that we will see new policies put in place and a new set of guidelines of minimum level of security capabilities mandated for all Agency networks (raising bottom-line security). This last point will probably prove to be the most trying or contentious effort within the existing Agency structure. It is not clear how existing Agencies that are clearly underfunding or under supporting Cyber Security will be assessed. It is even less clear where remedial funding or personnel positions will come from. And the stickiest point of all is…. how do you reform the leadership and policy in those Agencies to positively change their security culture? I noticed that someone used the C-word in response to my initial comments. This goes way beyond compliance. In the case of some Federal Agencies and perhaps some industries we may be talking about a complete change sea-change with respect to the emphasis and priority given to Cyber Security.

These are all difficult issues. And I believe the Administration will address them one step at a time.
In the long-term it is less clear how Cyber Security will be managed. The so-called war on drugs has been managed by central authority directly from the White House for decades. And to be sure, to put a working national system together that protects our Government and critical national infrastructure from Cyber attack will probably take a similar level of effort and perhaps require a similar long-term commitment. Let’s just hope that it is better thought-out and more effective than the so-called war on drugs.

Vlad’s point concerning Intelligence Community taking the lead with respect to Cyber Security is an interesting one, I think the Intelligence Community will be important players in this new initiative. To be frank, between the Defense and Intelligence Communities there is considerable technical expertise that will be sorely needed. However, for legal reasons, there are real limits as to what the Intelligence and Defense Communities can do in many situations. This is a parallel problem to the Cyber Security as a Law Enforcement problem. The “solution” will clearly involve a variety of players each with their own expertise and authorities. And while I am not anticipating that Tom Clancy will be appointed the Cyber Security Czar any time soon. I do expect that a long-term approach will require the stand-up of either a new organization empowered to act across current legal boundaries (that will require new legislation), or a new coordinating organization like the Counter Terrorism Center, that will allow all of the current players bring their individual strengths and authorities to focus on a situation on a case by case basis as they are needed (that may require new legislation).

If you press me, I think a joint coordinating body will be the preferred choice of the Administration. Everyone likes the idea of everyone working and playing well together. And, that option also sounds a lot less expensive. And that is important in today’s economic climate.

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We’ve got another good US Government Security Certification and Accreditation (C&A) Seminar/Workshop coming up at the end of March with Potomac Forum.

Graydon McKee (Ascension Risk Management and associated blog) and Dan Philpott (Fismapedia Mastermind and Guerilla-CISO Contributor) are going to the core of the instruction, with a couple others thrown in to round it all out.  I might stop by if I have the time.

What we promise:

• An opportunity to hear NIST’s version of events and what they’re trying to accomplish
• An opportunity to ask as many questions as you possibly can in 2 days
• Good materials put together
• An update on some of the recent security initiatives
• An opportunity to commiserate with security folks from other agencies and contractors
• No sales pitches and no products

See you all there!

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