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United States General Accounting Office: 


Before the Subcommittee on Government Efficiency, Financial Management 
and Intergovernmental Relations and the Subcommittee on Technology and 
Procurement Policy, Committee on Government Reform, House of 

For Release on Delivery: 
Expected at 10 am. EDT: 
Thursday, May 2, 2002: 

Information Security: 

Comments on the Proposed Federal Information Security Management Act 
of 2002: 

Statement of Robert F. Dacey: 
Director, Information Security Issues: 


Messrs. Chairmen and Members of the Subcommittees: 

I am pleased to be here today to discuss H.R. 3844, the Federal 
Information Security Management Act of 2002. This bill seeks to 
strengthen federal government information security by reauthorizing 
and expanding the information security, evaluation, and reporting 
requirements enacted into law as the Government Information Security 
Reform provisions (commonly referred to as "GISRA") in the National 
Defense Authorization Act for Fiscal Year 2001.[Footnote 1] Concerned 
with reports that continuing, pervasive information security 
weaknesses place federal operations at significant risk of disruption, 
tampering, fraud, and inappropriate disclosures of sensitive 
information, the Congress enacted GISRA to reduce these risks and 
provide more effective oversight of federal information security. 

As I stated in my March 6, 2002, testimony before the Government 
Efficiency, Financial Management and Intergovernmental Relations 
Subcommittee, first-year implementation of GISRA represented a 
significant step in improving federal agencies' information security 
programs and addressing their serious, pervasive information security 
weaknesses.[Footnote 2] However, first-year implementation indicated 
areas in which GISRA could be strengthened and clarified to further 
improve federal information security and congressional oversight 
Furthermore, GISRA will expire on November 29, 2002, less than a year 

In my testimony today, I will first discuss the need to continue 
authorization of government information security legislation in view 
of the major information security risks that are facing federal 
agencies. Next, I will discuss major changes proposed in H.R. 3844, 
such as requiring annual agency reporting to the Office of Management 
and Budget (OMB) and the comptroller general, and establishing 
mandatory minimum security controls. Finally, I will highlight other 
changes in H.R. 3844 intended to clarify and streamline GISRA 

Messrs. Chairmen, this testimony is based on our analysis of the 
proposed language of H.R. 3844 that you introduced in the House of 
Representatives on March 5, 2002. It is also based on the results of 
our review of first-year 

GISRA implementation as presented in my March 2002 testimony and in 
our report, which is being released today entitled, Information 
Security: Additional Actions Needed to Fully Implement Reform 
Legislation.[Footnote 3] We performed our work during March and April 
2002 in accordance with generally accepted government auditing 

Results In Brief: 

H.R. 3844 would permanently authorize and strengthen the information 
security program, evaluation, and reporting requirements established 
by GISRA, which is to expire on November 29, 2002. As demonstrated by 
first-year implementation, GISRA proved to be a significant step in 
improving federal agencies' information security programs and 
addressing their serious, pervasive information security weaknesses. 
Agencies have noted benefits from GISRA, such as increased management 
attention to and accountability for information security. In addition, 
the administration has taken important actions to address information 
security, such as plans to integrate information security into the 
President's Management Agenda Scorecard. We believe that continued 
authorization of such important information security legislation is 
essential to sustaining agency efforts to identify and correct 
significant weaknesses. Further, this authorization would reinforce 
the federal government's commitment to establishing information 
security as an integral part of its operations and help ensure that 
the administration and the Congress continue to receive the 
information they need to effectively manage and oversee federal 
information security. 

H.R. 3844 also proposes a number of changes and clarifications to 
strengthen information security, some of which address issues noted in 
the first-year implementation of GISRA. In particular, the bill 
requires the development, promulgation, and compliance with minimum 
mandatory management controls for securing information and information 
systems; creates a requirement for annual agency reporting to both OMB 
and the comptroller general; and clarifies the definition of and 
evaluation responsibilities for national security systems. In 
addition, the bill proposes other changes that would require federal 
agencies to strengthen their information security programs, update the 
information security responsibilities of the National Institute of 
Standards and Technology (NIST), and clarify or otherwise streamline 
definitions and legislative language. 

In addition to reauthorizing information security legislation, there 
are a number of important steps that the administration and the 
agencies should take to ensure that information security receives 
appropriate attention and resources and that known deficiencies are 
addressed. These include delineating the roles and responsibilities of 
the numerous entities involved in federal information security and 
related aspects of critical infrastructure protection; obtaining 
adequate technical expertise to select, implement, and maintain 
controls to protect information systems; and allocating sufficient 
agency resources for information security. 


Dramatic increases in computer interconnectivity, especially in the 
use of the Internet, continue to revolutionize the way our government, 
our nation, and much of the world communicate and conduct business. 
However, this widespread interconnectivity also poses significant 
risks to our computer systems and, more important, to the critical 
operations and infrastructures they support, such as 
telecommunications, power distribution, public health, national 
defense (including the military's warfighting capability), law 
enforcement, government, and emergency services. Likewise, the speed 
and accessibility that create the enormous benefits of the computer 
age, if not properly controlled, allow individuals and organizations 
to inexpensively eavesdrop on or interfere with these operations from 
remote locations for mischievous or malicious purposes, including 
fraud or sabotage. 

As greater amounts of money are transferred through computer systems, 
as more sensitive economic and commercial information is exchanged 
electronically, and as the nation's defense and intelligence 
communities increasingly rely on commercially available information 
technology, the likelihood increases that information attacks will 
threaten vital national interests. Further, the events of September 
11, 2001, underscored the need to protect America's cyberspace against 
potentially disastrous cyber attacks—attacks that could also be 
coordinated to coincide with physical terrorist attacks to maximize 
the impact of both. 

Since September 1996, we have reported that poor information security 
is a widespread federal problem with potentially devastating 
consequences.[Footnote 4] Although agencies have taken steps to 
redesign and strengthen their information system security programs, 
our analyses of information security at major federal agencies have 
shown that federal systems were not being adequately protected from 
computer-based threats, even though these systems process, store, and 
transmit enormous amounts of sensitive data and are indispensable to 
many federal agency operations. In addition, in both 1998 and 2000, we 
analyzed audit results for 24 of the largest federal agencies and 
found that all 24 had significant information security weaknesses. 
[Footnote 5] As a result of these analyses, we have identified 
information security as a governmentwide high-risk issue in reports to 
the Congress since 1997—most recently in January 2001.[Footnote 6] 

These weaknesses continue as indicated by our most recent analyses for 
these 24 large federal agencies that considered the results of 
inspector general (IG) and GAO audit reports published from July 2000 
through September 2001, including the results of the IGs' independent 
evaluations of these agencies' information security programs performed 
as required by GISRA.[Footnote 7] These analyses showed significant 
information security weaknesses in all major areas of the agencies' 
general controls, that is, the policies, procedures, and technical 
controls that apply to all or a large segment of an entity's 
information systems and help ensure their proper operation. Figure 1 
illustrates the distribution of weaknesses across the 24 agencies for 
the following six general control areas: (1) security program 
management, which provides the framework for ensuring that risks are 
understood and that effective controls are selected and properly 
implemented; (2) access controls, which ensure that only authorized 
individuals can read, alter, or delete data; (3) software development 
and change controls, which ensure that only authorized software 
programs are implemented; (4) segregation of duties, which reduces the 
risk that one individual can independently perform inappropriate 
actions without detection; (5) operating systems controls, which 
protect sensitive programs that support multiple applications from 
tampering and misuse; and (6) service continuity, which ensures that 
computer-dependent operations experience no significant disruptions. 

Figure 1: Information Security Weaknesses at 24 Major Agencies: 

[Refer to PDF for image: stacked vertical bar graph] 

Program management: 
Significant weaknesses: 24 agencies; 
Area not reviewed: 0 agencies; 
No significant weaknesses identified: 0 agencies. 

Significant weaknesses: 24 agencies; 
Area not reviewed: 0 agencies; 
No significant weaknesses identified: 0 agencies. 

Software change: 
Significant weaknesses: 17 agencies; 
Area not reviewed: 3 agencies; 
No significant weaknesses identified: 4 agencies. 

Segregation of duties: 
Significant weaknesses: 15 agencies; 
Area not reviewed: 3 agencies; 
No significant weaknesses identified: 6 agencies. 

Operating system: 
Significant weaknesses: 17 agencies; 
Area not reviewed: 2 agencies; 
No significant weaknesses identified: 5 agencies. 

Service continuity: 
Significant weaknesses: 19 agencies; 
Area not reviewed: 0 agencies; 
No significant weaknesses identified: 5 agencies. 

Source: Audit reports issued July 2000 through September 2001. 

[End of table] 

Our analyses showed that weaknesses were most often identified for 
security program management and access controls. For security program 
management, we found weaknesses for all 24 agencies in 2001 as 
compared to 21 agencies (88 percent) in a similar analysis in 2000. 
[Footnote 8] For access controls, we also found weaknesses for all 24 
agencies in 2001—the same condition we found in 2000. 

Concerned with accounts of attacks on commercial systems via the 
Internet and reports of significant weaknesses in federal computer 
systems that make them vulnerable to attack, on October 30, 2000, the 
Congress enacted GISRA, which became effective November 29, 2000, and 
is in effect for 2 years after this date. GISRA supplements 
information security requirements established in the Computer Security 
Act of 1987, the Paperwork Reduction Act of 1995, and the Clinger-
Cohen Act of 1996 and is consistent with existing information security 
guidance issued by OMB[Footnote 9] and NIST,[Footnote 10] as well as 
audit and best practice guidance issued by GAO.[Footnote 11] Most 
importantly, however, GISRA consolidates these separate requirements 
and guidance into an overall framework for managing information 
security and establishes new annual review, independent evaluation, 
and reporting requirements to help ensure agency implementation and 
both OMB and congressional oversight. 

The law assigned specific responsibilities to OMB, agency heads and 
chief information officers (CIOs), and the IGs. OMB is responsible for 
establishing and overseeing policies, standards, and guidelines for 
information security. This includes the authority to approve agency 
information security programs, but delegates OMB's responsibilities 
regarding national security systems to national security agencies. OMB 
is also required to submit an annual report to the Congress 
summarizing results of agencies' evaluations of their information 
security programs. GISRA does not specify a date for this report. 

Each agency, including national security agencies, is to establish an 
agencywide risk-based information security program to be overseen by 
the agency CIO and ensure that information security is practiced 
throughout the life cycle of each agency system. Specifically, this 
program is to include: 

* periodic risk assessments that consider internal and external 
threats to the integrity, confidentiality, and availability of 
systems, and to data supporting critical operations and assets; 

* the development and implementation of risk-based, cost-effective 
policies and procedures to provide security protections for 
information collected or maintained by or for the agency; 

* training on security responsibilities for information security 
personnel and on security awareness for agency personnel; 

* periodic management testing and evaluation of the effectiveness of 
policies, procedures, controls, and techniques; 

* a process for identifying and remediating any significant 

* procedures for detecting, reporting and responding to security 
incidents; and; 

* an annual program review by agency program officials. 

In addition to the responsibilities listed above, GISRA requires each 
agency to have an annual independent evaluation of its information 
security program and practices, including control testing and 
compliance assessment. The evaluations of non-national-security 
systems are to be performed by the agency IG or an independent 
evaluator, and the results of these evaluations are to be reported to 
OMB. For the evaluation of national security systems, special 
provisions include designation of evaluators by national security 
agencies, restricted reporting of evaluation results, and an audit of 
the independent evaluation performed by the IG or an independent 
evaluator. For national security systems, only the results of each 
audit of an evaluation are to be reported to OMB. 

Finally, GISRA also assigns additional responsibilities for 
information security policies, standards, guidance, training, and 
other functions to other agencies. These agencies are NIST, the 
Department of Defense, the intelligence community, the Attorney 
General (Department of Justice), the General Services Administration, 
and the Office of Personnel Management. 

H.R. 3844 Would Continue Benefits of Information Security Reform: 

With GISRA expiring on November 29, 2002, H.R. 3844 proposes to 
permanently authorize information security legislation that 
essentially retains the same purposes as GISRA, as well as many of 
GISRA's information security program, evaluation, and reporting 
requirements. It would also authorize funding to carry out its 
provisions for 5 years, thereby providing for periodic congressional 
oversight of the implementation and effectiveness of these 

We believe that continued authorization of information security 
legislation is essential to improving federal information security. As 
emphasized in our March 2002 testimony, the initial implementation of 
GISRA was a significant step for agencies, the administration, and the 
Congress in addressing the serious, pervasive weaknesses in the 
federal government's information security.[Footnote 12] GISRA 
consolidated security requirements that existed in law and policy 
before GISRA and put into law the following important additional 
requirements, which are continued in H.R. 3844. 

First, GISRA requires agency program managers and CIOs to implement a 
risk-based security management program covering all operations and 
assets of the agency, including those provided or managed for the 
agency by others. Instituting such an approach is important since many 
agencies had not effectively evaluated their information security 
risks and implemented appropriate controls. Our studies of public and 
private best practices have shown that effective security program 
management requires implementing a process that provides for a cycle 
of risk management activities as now included in GISRA.[Footnote 13] 
Moreover, other efforts to improve agency information security will 
not be fully effective and lasting unless they are supported by a 
strong agencywide security management program. 

Second, GISRA requires an annual independent evaluation of each 
agency's information security program. Individually, as well as 
collectively, these evaluations can provide much needed information 
for improved oversight by OMB and the Congress. Our years of auditing 
agency security programs have shown that independent tests and 
evaluations are essential to verifying the effectiveness of computer-
based controls. Audits can also evaluate an agency's implementation of 
management initiatives, thus promoting management accountability. 
Annual independent evaluations of agency information security programs 
will help drive reform because they will spotlight both the obstacles 
and progress toward improving information security and provide a means 
of measuring progress, much like the financial statement audits 
required by the Government Management Reform Act of 1994. Further, 
independent reviews proved to be an important mechanism for monitoring 
progress and uncovering problems that needed attention in the federal 
government's efforts to meet the Year 2000 computing challenge. 
[Footnote 14] 

Third, GISRA takes a governmentwide approach to information security 
by accommodating a wide range of information security needs and 
applying requirements to all agencies, including those engaged in 
national security. This is important because the information security 
needs of civilian agency operations and those of national security 
operations have converged in recent years. In the past, when sensitive 
information was more likely to be maintained on paper or in stand-
alone computers, the main concern was data confidentiality, especially 
as it pertained to classified national security data. Now, virtually 
all agencies rely on interconnected computers to maintain information 
and carry out operations that are essential to their missions. While 
the confidentiality needs of these data vary, all agencies must be 
concerned about the integrity and the availability of their systems 
and data. It is important for all agencies to understand these various 
types of risks and take appropriate steps to manage them. 

Fourth, the annual reporting requirements provide a means for both OMB 
and the Congress to oversee the effectiveness of agency and 
governmentwide information security, measure progress in improving 
information security, and consider information security in budget 
deliberations. In addition to management reviews, annual IG reporting 
of the independent evaluation results to OMB and OMB's reporting of 
these results to the Congress provide an assessment of agencies' 
information security programs on which to base oversight and budgeting 
activities. Such oversight is essential for holding agencies 
accountable for their performance, as was demonstrated by the OMB and 
congressional efforts to oversee the Year 2000 computer challenge. 
This reporting also facilitates a process to help ensure consistent 
identification of information security weaknesses by both the IG and 
agency management. 

The first-year implementation of GISRA also yielded significant 
benefits in terms of agency focus on information security. A number of 
agencies stated that as a result of implementing GISRA, they are 
taking significant steps to improve their information security 
programs. For example, one agency stated that the law provided it with 
the opportunity to identify some systemic program-level weaknesses for 
which it plans to undertake separate initiatives targeted specifically 
to improve the weaknesses. Other benefits agencies observed included 
(1) higher visibility of information security within the agencies, (2) 
increased awareness of information security requirements among 
department personnel, (3) recognition that program managers are to be 
held accountable for the information security of their operations, (4) 
greater agency consideration of security throughout the system life 
cycle, and (5) justification for additional resources and funding 
needed to improve security. Agency IGs also viewed GISRA as a positive 
step toward improving information security particularly by increasing 
agency management's focus on this issue. 

Implementation of GISRA has also resulted in important actions by the 
administration which, if properly carried out, should continue to 
improve information security in the federal government. For example, 
OMB has issued guidance that information technology investments will 
not be funded unless security is incorporated into and funded as part 
of each investment, and NIST has established a Computer Security 
Expert Assist Team to review agencies' computer security management. 
The administration also has plans to: 

* direct large agencies to undertake a review to identify and 
prioritize critical assets within the agencies and to identify their 
interrelationships with other agencies and the private sector; 

* conduct a cross-government review to ensure that all critical 
government processes and assets have been identified; 

* integrate security into the President's Management Agenda Scorecard;
* develop workable measures of performance; 

* develop electronic training on mandatory topics, including security; 

* explore methods to disseminate vulnerability patches to agencies 
more effectively. 

Such benefits and planned actions demonstrate the importance of 
GISRA's requirements and the significant impact they have had on 
information security in the federal government. 

Major Changes Proposed by H.R. 3844: 

H.R. 3844 proposes a number of changes and clarifications that we 
believe could strengthen information security requirements, some of 
which address issues noted in the first-year implementation of GISRA. 

Establishing Mandatory Minimum Controls: 

Currently, agencies have wide discretion in deciding what computer 
security controls to implement and the level of rigor with which to 
enforce these controls. In theory, some discretion is appropriate 
since, as OMB and NIST guidance state, the level of protection that 
agencies provide should be commensurate with the risk to agency 
operations and assets. In essence, one set of specific controls will 
not be appropriate for all types of systems and data. Nevertheless, 
our studies of best practices at leading organizations have shown that 
more specific guidance is important.[Footnote 15] In particular, 
specific mandatory standards for specified risk levels can clarify 
expectations for information protection, including audit criteria; 
provide a standard framework for assessing information security risk; 
help ensure that shared data are appropriately and consistently 
protected; and reduce demands for already limited agency information 
security resources to independently develop security controls. 

In response to this need, H.R. 3844 includes a number of provisions 
that would require the development, promulgation, and compliance with 
minimum mandatory management controls for securing information and 
information systems to manage risks as determined by agencies. 

* NIST, in coordination with OMB, would be required to develop (1) 
standards and guidelines for categorizing the criticality and 
sensitivity of agency information according to the control objectives 
of information integrity, confidentiality, and availability, and a 
range of risk levels, and (2) minimum information security 
requirements for each information category. 

* OMB would issue standards and guidelines based on the NIST-developed 
information and would require agencies to comply with them. This 
increases OMB's information security authority, given that the 
secretary of commerce is currently required by the Computer Security 
Act to issue such standards. These standards would include (1) minimum 
mandatory requirements and (2) standards otherwise considered 
necessary for information security. 

* Agencies may use more stringent standards than provided by NIST, but 
H.R. 3844 would require building more stringent protections on top of 
minimum requirements depending on the nature of information security 

* Waiver of the standards is not permitted—they are intended to 
provide a consistent information security approach across all 
agencies, while meeting the mission-specific needs of each agency. 
Thus, agencies would be required to categorize their information and 
information systems according to control objectives and risk levels 
and to meet the minimum information security requirements. 

Reporting Information to the Congress: 

H.R. 3844 seeks to improve accountability and congressional oversight 
by clarifying agency reporting requirements and ensuring that the 
Congress and GAO have access to information security evaluation 
results. In particular, it requires agencies to submit an annual 
report to both OMB and the comptroller general. This reporting 
requirement is in addition to the requirement in both GISRA and H.R. 
3844 that IGs report the results of independent evaluations to OMB and 
would help to ensure that the Congress receives the information it 
needs for oversight of federal information security and related budget 
deliberations. However, to ensure that agencies provide consistent and 
meaningful information in their reports, it would be important that 
any such reporting requirement consider specifying what these reports 
should address. 

As reported in our March 2002 testimony, during first-year 
implementation of GISRA, OMB informed the agencies that it considered 
GISRA material the CIOs prepared for OMB to be predecisional and not 
releasable to the public, the Congress, or GAO.[Footnote 16] OMB also 
considered agencies' corrective action plans to contain predecisional 
budget information and would not authorize agencies to release them to 
us. Later, OMB did authorize the agencies to provide copies of their 
executive summaries, and through continued negotiations with OMB since 
our March testimony, many agencies are now providing us with the more 
detailed information that they submitted to OMB. We are continuing to 
work with OMB to obtain appropriate information from agencies' first-
year GISRA corrective action plans and to develop a process whereby 
this information can be routinely provided to the Congress in the 

The Congress should have consistent and timely information for 
overseeing agencies' efforts to implement information security 
requirements and take corrective actions, as well as for budget 
deliberations. In our report being released today, we recommend that 
OMB authorize the heads of federal departments and agencies to release 
information from their corrective action plans to the Congress and GAO 
that would (1) identify specific weaknesses to be addressed, their 
relative priority, the actions to be taken, and the timeframes for 
completing these actions and (2) provide their quarterly updates on 
the status of completing these actions.[Footnote 17] In commenting on 
our recommendation, OMB stated that it recognizes Congress's oversight 
role regarding agencies' actions to correct information security 
weaknesses and is continuing to develop a solution for next year's 
reporting to provide to the Congress information on agencies' 
corrective actions. However, OMB believed that removing predecisional 
information from current year plans would be difficult and is not 
having the agencies prepare information on their current plans that 
would be releasable to the Congress. One way to help ensure that the 
Congress receives such information would be to specifically require 
that agencies report it to the Congress and GAO. 

Responsibilities for National Security Systems: 

In our March 2002 testimony, we reported that we were unable to obtain 
complete information on GISRA implementation for national security 
systems. Specifically, OMB did not summarize the overall results of 
the audits of the evaluations for national security systems in its 
report to the Congress,[Footnote 18] and the director of central 
intelligence declined to provide information for our review. In this 
regard, our report being released today includes a recommendation that 
OMB provide the Congress with appropriate summary information on the 
results of the audits of the evaluations for information security 
programs for national security systems. 

While we were unable to evaluate this aspect of GISRA implementation, 
H.R. 3844 proposes to modify GISRA in a number of ways to clarify the 
treatment of national security systems and to simplify statutory 
requirements while maintaining protection for the unique requirements 
of such systems within the risk management approach of the law. 

First, the bill replaces GISRA's use of the term "mission critical 
system." Instead, H.R. 3844 uses the traditional term "national 
security system," maintaining the longstanding statutory treatment of 
military and intelligence mission-related systems and classified 
systems.[Footnote 19] It would also eliminate a separate category of 
systems included in GISRA's definition of mission critical system-—
debilitating impact systems-—that broadened the exemption from GISRA 
for these systems.[Footnote 20] 

Second, consistent with the traditional definitions of national 
security systems, H.R. 3844 provides more straightforward distinctions 
between national security and non-national-security systems. This 
simplifies the law and could simplify compliance for agencies 
operating national security systems. The bill, for example, replaces 
GISRA's delegation of policy and oversight responsibilities for 
national security systems from OMB to national security agencies by 
simply continuing longstanding limitations on OMB and NIST authority 
over national security systems. 

Third, H.R. 3844 makes a number of changes to GISRA to streamline 
agency evaluation requirements that affect national security systems: 

* The bill clarifies procedures for evaluating national security 
systems within the context of agencywide evaluations. 

* The results of the evaluations of national security systems, not the 
evaluations themselves, are to be submitted to OMB, which will then 
prepare a summary report for the Congress. As in GISRA, the actual 
evaluations and any descriptions of intelligence-related national 
security systems are to be made available to the Congress only through 
the intelligence committees. 

* The requirement for an audit of the evaluation of national security 
systems is eliminated. Instead, agencies are required to provide 
appropriate protections for national security information and, as 
discussed above, submit only the results of the evaluations to OMB. 

We agree that these changes provide a more traditional definition of 
national security systems, and that such systems should be 
appropriately considered within the context of a comprehensive 
evaluation of agency information security. We also believe that 
requirements for reporting evaluation results to OMB and for OMB to 
prepare a summary report for the Congress would provide information 
needed for congressional oversight This reporting requirement is 
consistent with our recommendation contained in the report that we are 
issuing today: that OMB provide the Congress with appropriate summary 
information on evaluation results for national security systems. 

Additional Agency Requirements to Strengthen Information Security 

A number of provisions in the proposed legislation establish 
additional requirements for federal agencies that we believe would 
strengthen implementation and management of their information security 
programs. Some of the more significant requirements are as follows: 

* Agencies would be required to comply with all standards applicable 
to their systems, including the proposed mandatory minimum control 
requirements and those for national security systems. Thus, in 
implementing an agencywide risk-management approach to information 
security, agencies with both national security and non-national-
security systems would need to have an agencywide information security 
program that can address the security needs and standards for both 
kinds of systems. 

* Under the bill, the requirement for designating a senior agency 
information security officer is more detailed than that under GISRA. 
This official is to (1) carry out the CIO's responsibilities under the 
act; (2) possess appropriate professional qualifications; (3) have 
information security as his or her primary duty; and (4) head an 
information security office with the mission and resources needed to 
help ensure agency compliance with the act. 

* H.R. 3844 also requires each agency to document its agencywide 
security program and prepare subordinate plans as needed for networks, 
facilities, and systems. GISRA uses both the terms "security program" 
and "security plan" and does not specifically require that the program 
be documented. Our guidance for auditing information system controls 
states that entities should have a written plan that clearly describes 
the entity's security program and policies and procedures that support 
it.[Footnote 21] 

* H.R. 3844 stresses the importance of agencies having plans and 
procedures to ensure the continuity of operations for information 
systems that support the operations and assets of the agency. Such 
plans, procedures, and other service continuity controls are important 
because they help ensure that when unexpected events occur, critical 
operations will continue without undue interruption and that crucial, 
sensitive data are protected. Losing the capability to process, 
retrieve, and protect electronically maintained information can 
significantly affect an agency's ability to accomplish its mission. If 
service continuity controls are inadequate, even relatively minor 
interruptions can result in lost or incorrectly processed data, which 
can cause financial losses, expensive recovery efforts, and inaccurate 
or incomplete information. For some operations, such as those 
involving health care or safety, system interruptions could even 
result in injuries or loss of life. GAO and IG audit work indicate 
that most of the 24 large agencies we reviewed had weaknesses in 
service continuity controls, such as plans that were incomplete or not 
fully tested. 

Updating the Mission of NIST and Its Advisory Board: 

H.R. 3844 maintains NIST's standards development mission for 
information systems, federal information systems, and federal 
information security (except for national security and classified 
systems), but updates the mission of NIST. Some of H.R. 3844's more 
significant changes to NIST's role and responsibilities would require 
NIST to: 

* develop mandatory minimum information security requirements and 
guidance for detecting and handling of information security incidents 
and for identifying an information system as a national security 

* establish a NIST Office for Information Security Programs to be 
headed by a senior executive level director; and; 

* report annually to OMB to create a more active role for NIST in 
governmentwide information security oversight and to help ensure that 
OMB receives regular updates on the state of federal information 

In addition, H.R. 3844 would revise the National Institute of 
Standards and Technology Act to rename NIST's Computer System Security 
and Privacy Advisory Board as the Information Security Advisory Board 
and to ensure that this board has sufficient independence and 
resources to consider information security issues and provide useful 
advice to NIST. The bill would strengthen the role of the board by (1) 
mandating that it provide advice not only to NIST in developing 
standards, but also to OMB who promulgates such standards; (2) 
requiring that it prepare an annual report; and (3) authorizing it to 
hold its meetings where and when it chooses. 

Other Changes to Clarify and Streamline the Law:	 

Our analysis of H.R. 3844 identified other proposed changes and 
requirements that could enhance federal information security, as well 
as help improve compliance by clarifying inconsistent and unclear 
terms and provisions, streamlining a number of GISRA requirements, and 
repealing duplicative provisions in the Computer Security Act and the 
Paperwork Reduction Act. These changes include the following: 

Information security. H.R. 3844 would create a definition for the term 
"information security" to address three widely accepted objectives—
integrity, confidentiality, and availability. Including these 
objectives in statute highlights that information security involves 
not only protecting information from disclosure (confidentiality), but 
also protecting the ability to use and rely on information 
(availability and integrity). 

Information technology. H.R. 3844 would retain GISRA's use of the 
Clinger-Cohen Act definition of "information technology." However, 
H.R. 3844 clarifies the scope of this term by using consistent 
references to "information systems used or operated by any agency or 
by a contractor of an agency or other organization on behalf of an 
agency." This emphasizes that H.R. 3844 is intended to cover all 
systems used by or on behalf of agencies, not just those operated by 
agency personnel. As discussed previously, both OMB's and GAO's 
analyses of agencies' first-year GISRA reporting showed significant 
weaknesses in information security management of contractor-provided 
or -operated systems. 

Independent evaluations. The legislation would continue the GISRA 
requirement for an annual independent evaluation of each agency's 
information security program and practices. However, several language 
changes are proposed to clarify this requirement. For example, the 
word "representative" would be substituted for "appropriate" in the 
requirement that the evaluation involve the examination of a sample of 
systems or procedures. In addition, the bill would also require that 
the evaluations be performed in accordance with generally accepted 
government auditing standards, and that GAO periodically evaluate 
agency information security policies and practices. We agree with 
these proposed changes to independent evaluations, but as noted in our 
March 2002 testimony, these evaluations and expanded coverage for all 
agency systems under GISRA and H.R. 3844 place a significant burden on 
existing audit capabilities and require ensuring that agency IGs have 
necessary resources to either perform or contract for the needed work. 
[Footnote 22] 

Federal information security incident center. The bill would direct 
OMB to oversee the establishment of a central federal information 
security incident center and expands GISRA references to this 
function. While not specifying which federal agency should operate 
this center, H.R. 3844 specifies that the center would: 

* provide timely technical assistance to agencies and other operators 
of federal information systems; 

* compile and analyze information security incident information; 

* inform agencies about information security threats and 
vulnerabilities; and; 

* consult with national security agencies and other appropriate 
agencies, such as an infrastructure protection office. 

H.R. 3844 would also require that agencies with national security 
systems share information security information with the center to the 
extent consistent with standards and guidelines for national security 
systems. This provision should encourage interagency communication and 
consultation, while preserving the discretion of national security 
agencies to determine appropriate information sharing. 

Technical and conforming amendments. In addition to its substantive 
provisions, H.R. 3844 would make a number of minor changes to GISRA 
and other statutes to ensure consistency within and across these laws. 
These changes include the elimination of certain provisions in the 
Paperwork Reduction Act and the Computer Security Act that are 
replaced by the requirements of GISRA and H.R. 3844. 

Improvements Underway, But Challenges to Federal Information Security 

As discussed previously, GISRA established important program, 
evaluation, and reporting requirements for information security; and 
the first-year implementation of GISRA has resulted in a number of 
important administration actions and significant agency benefits. In 
addition, H.R. 3844 would continue and strengthen these requirements 
to further improve federal information security. However, even with 
these and other information security-related improvement efforts 
undertaken in the past few years—such as the president's creation of 
the Office of Homeland Security and the President's Critical 
Infrastructure Protection Board—challenges remain. 

Given the events of September 11, and reports that critical operations 
and assets continue to be highly vulnerable to computer-based attacks, 
the government still faces a challenge in ensuring that risks from 
cyber threats are appropriately addressed in the context of the 
broader array of risks to the nation's welfare. Accordingly, it is 
important that federal information security efforts be guided by a 
comprehensive strategy for improvement. In 1998, shortly after the 
initial issuance of Presidential Decision Directive (PDD) 63 on 
protecting the nation's critical infrastructure, we recommended that 
OMB, which, by law, is responsible for overseeing federal information 
security, and the assistant to the president for national security 
affairs work together to ensure that the roles of new and existing 
federal efforts were coordinated under a comprehensive strategy. 
[Footnote 23] Our later reviews of the National Infrastructure 
Protection Center and of broader federal efforts to counter computer-
based attacks showed that there was a continuing need to clarify 
responsibilities and critical infrastructure protection objectives. 
[Footnote 24] 

As I emphasized in my March 2002 testimony, as the administration 
refines the strategy that it has begun to lay out in recent months, it 
is imperative that it take steps to ensure that information security 
receives appropriate attention and resources and that known 
deficiencies are addressed.[Footnote 25] These steps would include the 

* It is important that the federal strategy delineate the roles and 
responsibilities of the numerous entities involved in federal 
information security and related aspects of critical infrastructure 
protection. Under current law, OMB is responsible for overseeing and 
coordinating federal agency security, and NIST, with assistance from 
the National Security Agency, is responsible for establishing related 
standards. In addition, interagency bodies—such as the CIO Council and 
the entities created under PDD 63 on critical infrastructure 
protection—are attempting to coordinate agency initiatives. Although 
these organizations have developed fundamentally sound policies and 
guidance and have undertaken potentially useful initiatives, effective 
improvements are not yet taking place. Further, it is unclear how the 
activities of these many organizations interrelate, who should be held 
accountable for their success or failure, and whether they will 
effectively and efficiently support national goals. 

* Ensuring effective implementation of agency information security and 
critical infrastructure protection plans will require active 
monitoring by the agencies to determine if milestones are being met 
and testing to determine if policies and controls are operating as 
intended. Routine periodic audits, such as those required by GISRA and 
H.R. 3844, could allow for more meaningful performance measurement. In 
addition, the annual evaluation, reporting, and monitoring process 
established through these provisions, is an important mechanism, 
previously missing, to hold agencies accountable for implementing 
effective security and to manage the problem from a governmentwide 

* Agencies must have the technical expertise they need to select, 
implement, and maintain controls that protect their information 
systems. Similarly, the federal government must maximize the value of 
its technical staff by sharing expertise and information. Highlighted 
during the Year 2000 challenge, the availability of adequate technical 
and audit expertise is a continuing concern to agencies. 

* Agencies can allocate resources sufficient to support their 
information security and infrastructure protection activities. Funding 
for security is already embedded to some extent in agency budgets for 
computer system development efforts and routine network and system 
management and maintenance. However, some additional amounts are 
likely to be needed to address specific weaknesses and new tasks. OMB 
and congressional oversight of future spending on information security 
will be important to ensuring that agencies are not using the funds 
they receive to continue ad hoc, piecemeal security fixes that are not 
supported by a strong agency risk management process. 

* Expanded research is needed in the area of information systems 
protection. While a number of research efforts are underway, experts 
have noted that more is needed to achieve significant advances. As the 
director of the CERT® Coordination Center[Footnote 26] testified 
before this subcommittee last September, "It is essential to seek 
fundamental technological solutions and to seek proactive, preventive 
approaches, not just reactive, curative approaches." In addition, in 
its December 2001 third annual report, the Advisory Panel to Assess 
Domestic Response Capabilities for Terrorism Involving Weapons of Mass 
Destruction (also known as the Gilmore Commission) recommended that 
the Office of Homeland Security develop and implement a comprehensive 
plan for research, development, test, and evaluation to enhance cyber 
security.[Footnote 27] 

In summary, the first-year implementation of GISRA has resulted in a 
number of benefits and positive actions, but much work remains to be 
done to achieve the objectives of this legislation. Continued 
authorization of federal information security legislation is essential 
to sustain agencies' efforts to implement good security practices and 
to identify and correct significant weaknesses. This reauthorization 
will also help reinforce the federal government's commitment to 
establishing information security as an integral part of its 
operations, as well as help ensure that the administration and the 
Congress receive the information they need to effectively manage and 
oversee federal information security. 

The changes in requirements, responsibilities, and legislative 
language proposed in H.R. 3844 would further strengthen the 
implementation and oversight of information security in the federal 
government, particularly in establishing mandatory minimum controls 
and creating reporting requirements to ensure that the Congress 
receives the information it needs for oversight and budget 
deliberations related to federal information security. In addition, 
other changes proposed by H.R. 3844 would clarify and streamline the 
law and could increase agency compliance with information security 
requirements. At the same time, with the increasing threat to critical 
federal operations and assets and poor federal information security, 
it is imperative that the administration and the agencies implement a 
comprehensive strategy for improvement that emphasizes information 
security and addresses known weaknesses. 

Messrs. Chairmen, this concludes my statement. I would be pleased to 
answer any questions that you or other members of the subcommittees 
may have at this time. 


If you should have any questions about the testimony, please contact 
me at (202) 512-3317. I can be reached by e-mail at 

[End of section] 


[1] Title X, Subtitle G—Government Information Security Reform, Floyd 
D. Spence National Defense Authorization Act for Fiscal Year 2001, 
P.L. 106-398, October 30, 2000. 

[2] U.S. General Accounting Office, Information Security: Additional 
Actions Needed to Fully Implement Reform Legislation, [hyperlink,] (Washington, D.C.: Mar. 6, 

[3] [hyperlink,], Washington, 
D.C.: May 2, 2002. 

[4] U.S. General Accounting Office, Information Security: 
Opportunities for Improved OMB Oversight of Agency Practices. 
[hyperlink,] (Washington, 
D.C.: Sept. 24, 1996). 

[5] U.S. General Accounting Office, Information Security: Serious 
Weaknesses Place Critical Federal Operations and Assets at Risk, 
[hyperlink,] (Washington, 
D.C.: Sept. 23, 1998); Information Security: Serious and Widespread 
Weaknesses Persist at Federal Agencies [hyperlink,] (Washington, D.C.: Sept. 
6, 2000). 

[6] U.S. General Accounting Office, High-Risk Series: Information 
Management and Technology, [hyperlink,] (Washington, D.C.: Feb. 1, 
1997); High-Risk Series: An Update, [hyperlink,] (Washington, D.C.: Jan. 
1999); High Risk Series: An Update, [hyperlink,] (Washington, D.C.: Jan. 2001). 

[7] U.S. General Accounting Office, Computer Security: Improvements 
Needed to Reduce Risk to Critical Federal Operations and Assets, 
[hyperlink,] (Washington, 
D.C.: Nov. 9, 2001). 

[8] U.S. General Accounting Office, Computer Security: Critical 
Federal Operations and Assets Remain at Risk, [hyperlink,] (Washington, D.C.: 
Sept. 11, 2000). 

[9] Primarily OMB Circular A-130, Appendix BI, "Security of Federal 
Automated Information Resources," February 1996. 

[10] Numerous publications made available at [hyperlink,] including National Institute of Standards 
and Technology, Generally Accepted Principles and Practices for 
Securing Information Technology Systems, NIST Special Publication 800-
14, September 1996. 

[11] U.S. General Accounting Office, Federal Information System 
Controls Audit Manual, Volume 1—-Financial Statement Audits, 
[hyperlink,] (Washington, 
D.C.: Jan. 1999); Information Security Management: Learning from 
Leading Organizations, [hyperlink,] (Washington, D.C.: May 

[12] [hyperlink,], March 6, 

[13] General Accounting Office, [hyperlink,], Washington, D.C.: May 
1998; Information Security Risk Management: Practices of Leading 
Organizations, [hyperlink,] 
(Washington, D.C.: November 1999). 

[14] U.S. General Accounting Office, Year2000 Computing Challenge: 
Lessons Learned Can Be Applied to Other Management Challenges, 
[hyperlink,] (Washington, 
D.C.: Sept. 12, 2000). 

[15] [hyperlink,], May 1998. 

[16] [hyperlink,], March 6, 

[17] [hyperlink,], May 2, 2002. 

[18] Office of Management and Budget, FY 2001 Report to the Congress 
on Federal Government Information Security Reform, February 2002. 

[19] This two-part definition includes (1) the national security 
system definition for military and intelligence mission-related 
systems, and (2) the classified system definition for systems that are 
protected at all times by procedures established for information that 
has been appropriately authorized to be kept secret in the interest of 
national defense or foreign policy. 

[20] GISRA defines debilitating impact systems as systems that process 
information, "the loss, misuse, disclosure, or unauthorized access to 
or modification of would have a debilitating impact on the mission of 
the agency." 

[21] U.S. General Accounting Office, Federal Information System 
Controls Audit Manual, Volume 1—-Financial Statement Audits, 
[hyperlink,] (Washington, 
D.C.: January 1999). 

[22] [hyperlink,], March 6, 

[23] U.S. General Accounting Office, Information Security: Serious 
Weaknesses Place Critical Federal Operations and Assets at Risk. 
[hyperlink,] (Washington, 
D.C.: Sept. 23, 1998). 

[24] U.S. General Accounting Office, Critical Infrastructure 
Protection: Significant Challenges in Developing National 
Capabilities. [hyperlink,] 
(Washington, D.C.: Apr. 25, 2001); Combating Terrorism: Selected 
Challenges and Related Recommendations. [hyperlink,] (Washington, D.C.: Sept. 20, 

[25] [hyperlink,], March 6, 

[26] CERT® Coordination Center (CERT-CC) is a center of Internet 
security expertise located at the Software Engineering Institute, a 
federally funded research and development center operated by Carnegie 
Mellon University. 

[27] Third Annual Report to the President and Congress of the Advisory 
Panel to Assess Domestic Response Capabilities for Terrorism Involving 
Weapons of Mass Destruction, December 15, 2001. 

[End of section]