Critical Infrastructure Protection: Additional Actions Are Essential for Assessing Cybersecurity Framework Adoption
Highlights
What GAO Found
Most of the 16 critical infrastructure sectors took action to facilitate adoption of the National Institute of Standards and Technology's (NIST) Framework for Improving Critical Infrastructure Cybersecurity by entities within their sectors. Federal policy directs nine federal lead agencies—referred to as sector-specific agencies (SSA)—in consultation with the Department of Homeland Security and other agencies, to review the cybersecurity framework and, if necessary, develop implementation guidance or supplemental materials to address sector-specific risks and operating environments.
In response, guidance for 12 of the 16 sectors for implementing the cybersecurity framework was developed. In addition, nonfederal led sector coordinating councils took additional steps to facilitate framework adoption. For example, 3 sectors that developed implementation guidance encouraged the alignment of the framework with existing cybersecurity guidelines used within their respective sectors.
Nevertheless, officials from the Department of Homeland Security, NIST, SSAs, and the sector coordinating councils identified four challenges to cybersecurity framework adoption, as reported by entities within their respective sectors. Specifically, some entities
May be limited in their ability to commit necessary resources towards framework adoption.
May not have the necessary knowledge and skills to effectively implement the framework.
May face regulatory, industry, and other requirements that inhibit adopting the framework.
May face other priorities that take precedence over conducting cyber-related risk management or adopting the framework.
Further, the nation's plan for national critical infrastructure protection efforts states that federal and nonfederal sector partners (including SSAs) are to measure the effectiveness of risk management goals by identifying high-level outcomes and progress made toward national goals and priorities, including securing critical infrastructure against cyber threats. However, none of the SSAs had measured the cybersecurity framework's implementation by entities within their respective sectors. None of the 16 coordinating councils reported having qualitative or quantitative measures of framework adoption because they generally do not collect specific information from entities about critical infrastructure protection activities. SSA officials also stated that the voluntary nature and other factors are impediments to collecting such information. While other entities, including a trade association and universities, had attempted to determine the use of the framework within certain sectors; none of those efforts yielded results that would articulate a sector-wide level of framework adoption.
Until SSAs have a more comprehensive understanding of the use of the cybersecurity framework by entities within the critical infrastructure sectors, they will be limited in their ability to understand the success of protection efforts or to determine where to focus limited resources for cyber risk mitigation.
Why GAO Did This Study
Our nation's critical infrastructure includes the public and private systems and assets vital to national security, economic stability, and public health and safety. Federal policy identifies 16 critical infrastructure sectors, including the financial services, energy, transportation, and communications sectors. To better address cyber-related risks to critical infrastructure, in 2014, NIST developed, as called for by federal law and policy, the Framework for Improving Critical Infrastructure Cybersecurity, a voluntary framework of cybersecurity standards and procedures for industry to adopt.
The Cybersecurity Enhancement Act of 2014 included provisions for GAO to review aspects of the cybersecurity standards and procedures in the framework developed by NIST. GAO's objective was to assess what is known about the extent to which critical infrastructure sectors have adopted the framework. To do so, GAO analyzed documentation, such as sector-specific guidance and tools to facilitate implementation, and interviewed relevant federal and nonfederal officials from the 16 critical infrastructure sectors.
Recommendations
GAO is making nine recommendations that methods be developed for determining framework adoption by the sector-specific agencies across their respective sectors, in consultation with their respective sector partner(s), such as the sector coordinating councils, the Department of Homeland Security, and NIST, as appropriate. Five agencies agreed with the recommendations, while four others neither agreed nor disagreed.
Recommendations for Executive Action
| Agency Affected | Recommendation | Status |
|---|---|---|
| Department of Agriculture |
Priority Rec.
The Secretary of Agriculture, in cooperation with the Secretary of Health and Human Services, should take steps to consult with respective sector partner(s), such as the sector coordinating council (SCC), Department of Homeland Security (DHS) and NIST, as appropriate, to develop methods for determining the level and type of framework adoption by entities across their respective sector. (Recommendation 1) |
Open – Partially Addressed
USDA neither agreed nor disagreed with the recommendation, but stated that it would attempt to develop a measurement mechanism as part of its annual data calls to the Food and Agriculture Sector. USDA has taken steps towards determining framework adoption across the sector. For example, USDA has distributed several requests for information to sector members that include questions regarding framework adoption and resulting improvements. In addition, USDA requested feedback from sector partners and made subsequent changes to its data calls responses. Despite these efforts, as of February 2024, USDA has not yet received information from sector entities regarding their adoption of the NIST cybersecurity framework. To fully implement this recommendation, USDA needs to implement actions that will allow the agency to better assess framework adoption among entities within its sector. USDA has been encouraging and supporting the use of the framework. However, in order to assist in protecting critical infrastructure the agency needs to implement our recommendation so it can gain a more comprehensive understanding of the framework's use.
|
| Department of Defense |
Priority Rec.
The Secretary of Defense should take steps to consult with respective sector partner(s), such as the SCC, DHS and NIST, as appropriate, to develop methods for determining the level and type of framework adoption by entities across their respective sector. (Recommendation 2) |
Closed – Implemented
As of November 2019, the Department of Defense (DOD), in coordination with the Defense Industrial Base sector, had developed a process to monitor the level or extent to which all contracts (not including commercial-off-the-shelf contracts) were or were not adhering to the cybersecurity requirements in DOD acquisition regulations. The regulations call for organizations to implement the security requirements in NIST SP 800-171, which is mapped to the functional areas of the cybersecurity framework. By doing so, DOD is able to determine the level at which the sector organizations are implementing the framework and the type of framework adoption through the mapping to the functional areas.
|
| Department of Energy |
Priority Rec.
The Secretary of Energy should take steps to consult with respective sector partner(s), such as the SCC, DHS and NIST, as appropriate, to develop methods for determining the level and type of framework adoption by entities across their respective sector. (Recommendation 3) |
Closed – Implemented
DOE did not explicitly agree or disagree with our recommendation. As of August 2023, DOE demonstrated that, in coordination with a third-party contractor, it had identified strengths and weaknesses in the energy sector's implementation of the NIST cybersecurity framework and DOE's Cybersecurity Capability Maturity Model (C2M2) practices. While DOE found that there was strong performance in the implementation of some fundamental practices, the agency identified areas of opportunity in other cybersecurity domains. By taking these steps, DOE will have a more comprehensive understanding of the framework's use by energy sector entities and where to focus limited resources for cyber risk mitigation efforts.
|
| Environmental Protection Agency |
Priority Rec.
The Administrator of the Environmental Protection Agency should take steps to consult with respective sector partner(s), such as the SCC, DHS and NIST, as appropriate, to develop methods for determining the level and type of framework adoption by entities across their respective sector. (Recommendation 4) |
Closed – Implemented
The Environmental Protection Agency (EPA) did not explicitly state whether or not it agreed or disagreed with our recommendation. As of January 2022, the agency had taken steps to determine framework adoption for the water and wastewater systems sector through its Technical Assistance Provider Initiative. Through this initiative, EPA conducted, on a voluntary basis, technical assessments of water and wastewater utilities and determined whether and how these utilities used the framework. As of October 2021, the agency determined that 146 out of 264 water and wastewater utilities that were eligible for the voluntary assessments had adopted the framework and obtained metrics on the utilities' implementation of the framework's security controls. Officials in EPA's Office of Ground Water and Drinking Water stated that they expect the data on framework adoption and usage from this initiative to continue to evolve as EPA assesses more utilities and obtains additional data. By determining whether and how utilities used the framework through its Technical Assistance Provider Initiative, EPA has a more comprehensive grasp of the use of the cyber framework by its critical infrastructure sector including understanding the success of protection efforts and where to focus limited resources for cyber risk mitigation.
|
| General Services Administration |
Priority Rec.
The Administrator of General Services, in cooperation with the Secretary of Homeland Security, should take steps to consult with respective sector partner(s), such as the Coordinating Council and NIST, as appropriate, to develop methods for determining the level and type of framework adoption by entities across their respective sector. (Recommendation 5) |
Closed – Implemented
As of February 2020, the federal departments and agencies that form the government facilities sector had submitted their risk management reports to the Department of Homeland Security and the Office of Management and Budget (OMB) that described agencies' action plans to implement the framework, as required under Executive Order 13800. The risk management assessments are included as part of OMB's Federal Information Security Modernization Act Annual Report to Congress. As a result, the reports could be used as a resource to inform the level and type of framework adoption.
|
| Department of Health and Human Services |
Priority Rec.
The Secretary of Health and Human Services, in cooperation with the Secretary of Agriculture, should take steps to consult with respective sector partner(s), such as the SCC, DHS and NIST, as appropriate, to develop methods for determining the level and type of framework adoption by entities across their respective sector. (Recommendation 6) |
Open – Partially Addressed
HHS agreed with this recommendation. In April 2023, HHS, in collaboration with the Healthcare and Public Health Sector Coordinating Council, published an analysis that describes industry adoption of the National Institute of Standards and Technology cybersecurity framework based on results from a third-party survey sent to hospitals. HHS also evaluated the extent to which responding hospitals adopted the five core functions of the cybersecurity framework and its associated subcategories. In addition, HHS coordinated with the Department of Agriculture in taking initial steps to determine framework adoption across the sector by distributing several requests for information to food and agriculture sector members. However, those efforts did not generate enough responses to be useful. For instance, the Department of Agriculture did not receive any responses from private sector members regarding plans to implement, adopt, and measure improvements resulting from use of the framework. The Department of Agriculture stated that it has collaborated with HHS and DHS to determine if there are alternative methods for collecting and assessing more substantive information. As of February 2024, HHS and the other agencies have not yet identified alternative approaches or completed other actions for determining framework adoption in the food and agriculture sector. To fully implement this recommendation, HHS needs to implement actions that will allow the agency to better assess framework adoption among entities within the food and agriculture sector. Until sector risk management agencies have a more comprehensive understanding of the use of the cyber framework by the critical sectors, they will be limited in their ability to evaluate the success of protection efforts or to determine where to focus limited resources for cyber risk mitigation.
|
| Department of Homeland Security |
Priority Rec.
The Secretary of Homeland Security, in cooperation with the co-SSAs as necessary, should take steps to consult with respective sector partner(s), such as the SCC, and NIST, as appropriate, to develop methods for determining the level and type of framework adoption by entities across their respective sectors. (Recommendation 7) |
Closed – Implemented
DHS concurred with our recommendation and has taken actions to implement it. In October 2022, the Cybersecurity and Infrastructure Security Agency (CISA) developed cross-sector cybersecurity performance goals that align with practices in the National Institute for Standards and Technology's cybersecurity framework. In March 2024, CISA demonstrated that it had begun measuring critical infrastructure sectors' adoption of the cross-sector goals. By taking these steps, DHS will have a more comprehensive understanding of how the framework's use is impacting critical infrastructure protection efforts.
|
| Department of Transportation |
Priority Rec.
The Secretary of Transportation, in cooperation with the Secretary of Homeland Security, should take steps to consult with respective sector partner(s), such as the SCC, DHS and NIST, as appropriate, to develop methods for determining the level and type of framework adoption by entities across their respective sector. (Recommendation 8) |
Closed – Implemented
The Department of Transportation (DOT) agreed with this recommendation. In January 2023, DOT, in coordination with DHS, analyzed the results of a sector-wide survey examining the transportation systems sector's use of the NIST cybersecurity framework. The analysis identified the usage, awareness, and implementation of the framework's five core functions by entities across the transportation systems sector. The analysis also identified four findings and related corrective actions for the co-sector risk management agencies. By taking these steps, DOT will have a more comprehensive understanding of the framework's use by transportation systems sector entities and where to focus limited resources for cyber risk mitigation efforts.
|
| Department of the Treasury |
Priority Rec.
The Secretary of Treasury should take steps to consult with respective sector partner(s), such as the SCC, DHS and NIST, as appropriate, to develop methods for determining the level and type of framework adoption by entities across their respective sector. (Recommendation 9) |
Open
Treasury neither agreed nor disagreed with this recommendation, stating that it does not have the authority to compel entities to share cybersecurity framework (framework) adoption data. Treasury stated that the voluntary nature of private sector participation in sector risk management agency activities affects its ability to implement certain recommendations, but it plans to collaborate with the sector to develop methods to determine the level and type of framework adoption. As of March 2024, Treasury had not identified a time frame for completing these efforts. Although working across the sector may be challenging, implementing the recommendation to gain a more comprehensive understanding of the level and type of framework adoption by the critical infrastructure sector is essential to the success of cybersecurity protection efforts.
|