Introduction
In its FY 2024 Federal Information Security Modernization Act (FISMA) review, the Office of Inspector General (OIG) once again deemed the U.S. Department of Health and Human Services (HHS) ineffective in managing its information security program. The audit revealed that HHS struggled to meet maturity levels across all five core functions of the National Institute of Standards and Technology (NIST) cybersecurity framework: Identify, Protect, Detect, Respond, and Recover.
Despite previous recommendations and ongoing efforts, HHS continues to face challenges in detecting, responding to, and recovering from cybersecurity threats, raising concerns about the security of its systems and the sensitive data it manages.
Key Findings of the OIG Report
Core Metrics and Maturity Issues
The OIG assessed HHS against its core and supplemental metrics, finding the agency fell short in meeting maturity levels for:
- Identifying security risks.
- Protecting sensitive information.
- Detecting cybersecurity threats.
- Responding to incidents effectively.
- Recovering from security breaches efficiently.
These gaps highlight systemic weaknesses that compromise the agency’s ability to safeguard critical data and operations.
Specific Areas of Concern
- Cloud System Vulnerabilities: HHS failed to accurately inventory its cloud systems and implement adequate security controls.
- Inconsistent Policies: The agency lacked comprehensive policies for supply chain risk management and privileged user monitoring.
- Operational Oversight: Background investigations and continuous monitoring of users with system access were inadequate.
Recommendations to Improve HHS’ Information Security Program
To address these deficiencies, the OIG outlined six key recommendations:
1. Updated System and Asset Inventories
HHS must update its enterprise architecture to include active information systems and components. This ensures a complete understanding of its network assets and reduces blind spots.
2. Cybersecurity Risk Management Strategy
The agency should implement a comprehensive strategy to:
- Assess and respond to identified risks.
- Monitor emerging threats.
- Verify the consistent application of risk mitigation measures across all divisions.
3. Security Impact Analyses for Changes
Operating divisions should evaluate the security impacts of significant system changes before implementation, ensuring changes align with organizational security and architecture goals.
4. Supply Chain Risk Management
HHS needs to develop and enforce a robust supply chain risk management program to mitigate vulnerabilities arising from third-party systems and software.
5. Background Investigations and Continuous Monitoring
The agency must strengthen oversight of background checks for employees and contractors with system access and continuously monitor these users to identify potential threats.
6. Automated Privileged User Monitoring
HHS should implement automated tools to log and review privileged user activity, ensuring compliance with security policies and reducing the risk of insider threats.
The Broader Implications of FISMA Reviews
Federal Agency Challenges in Meeting Requirements
HHS is not alone in its struggles. Many federal agencies face similar challenges in implementing effective information security programs. A Government Accountability Office (GAO) report found that:
- 17 of 23 civilian agencies failed to meet their cybersecurity targets.
- 16 agencies reported ineffective programs in their annual audits.
These findings suggest a systemic issue across federal institutions in achieving FISMA compliance.
Comparison with Other Agencies’ Performance
While HHS aligns its cybersecurity goals with healthcare sector-specific frameworks, it continues to lag in execution compared to other agencies. This highlights the need for stronger oversight and resource allocation to bridge the gap.
Future Directions for HHS Cybersecurity
HHS has an opportunity to turn its shortcomings into progress by:
- Fully adopting the 2024-2030 Federal Health IT Strategy, which emphasizes cybersecurity as a foundational element.
- Aligning its practices with the Healthcare Sector Cybersecurity Concept Paper and the Cybersecurity Performance Goals issued in 2023.
- Investing in advanced security technologies and workforce training to enhance its defenses against evolving threats.
By implementing these changes, HHS can strengthen its information security posture and better protect the sensitive data of millions of Americans.
Conclusion
The OIG’s FY 2024 report highlights persistent gaps in HHS’ information security program, emphasizing the need for a strategic overhaul. By addressing recommendations such as updating system inventories, implementing a robust risk management strategy, and strengthening user monitoring, HHS can enhance its cybersecurity posture and protect sensitive data more effectively.
As cyber threats grow more sophisticated, it is imperative for HHS and other federal agencies to prioritize information security, ensuring they can identify, protect, detect, respond to, and recover from threats in a timely and efficient manner. The stakes are high, but with the right focus and resources, HHS can achieve meaningful progress in safeguarding its systems and data.
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FAQs
1: What is the OIG’s role in evaluating HHS’ information security?
Ans: The OIG conducts annual audits of HHS’ information security program as required by the Federal Information Security Modernization Act (FISMA) to ensure compliance and effectiveness.
2: Why was HHS’ information security program deemed ineffective?
Ans: HHS failed to meet maturity levels across all five NIST cybersecurity framework functions and lacked adequate policies for asset management, risk assessment, and user monitoring.
3: What are the risks of an ineffective information security program?
Ans: Ineffective security programs increase vulnerability to cyberattacks, data breaches, and operational disruptions, jeopardizing sensitive data and public trust.
4: What steps can HHS take to improve?
Ans: HHS should update its asset inventories, implement a cybersecurity risk management strategy, strengthen user monitoring, and enforce supply chain risk management standards.
5: How do HHS’ challenges compare to other federal agencies?
Ans: HHS faces similar issues as other agencies, with many struggling to meet FISMA requirements and maintain effective cybersecurity programs.
