Cybersecurity: HHS Defined Roles and Responsibilities, but Can Further Improve Collaboration

GAO-21-403 Published: Jun 28, 2021. Publicly Released: Jun 28, 2021.
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Fast Facts

Health care organizations' IT systems are critical to the nation's well-being. Cyberattacks on them could, for example, put patient privacy at risk or disrupt essential telehealth services. (The nation's cybersecurity is on our High Risk List.)

The Department of Health and Human Services coordinates with health care organizations and others to support cybersecurity efforts. Its policies and procedures clearly describe roles and responsibilities, which is good for collaboration.

But we found areas where HHS could improve collaboration, such as by routinely sharing threat information with its partners.

Our recommendations address these issues.

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Highlights

What GAO Found

The Department of Health and Human Services' (HHS) Office of Information Security is responsible for managing department-wide cybersecurity. HHS clearly defined responsibilities for the divisions within that office to, among other things, document and implement a cybersecurity program, as required by the Federal Information Security Modernization Act of 2014.

For healthcare and public health critical infrastructure sector cybersecurity, HHS also defined responsibilities for five HHS entities. Among these entities are the Health Sector Cybersecurity Coordination Center, which was established to improve cybersecurity information sharing in the sector, and the Healthcare Threat Operations Center, a federal interagency program co-led by HHS and focused on, among other things, providing descriptive and actionable cyber data. Private-sector partners that receive information provided by the Health Sector Cybersecurity Coordination Center informed GAO that they could benefit from receiving more actionable threat information. However, this center does not routinely receive such information from the Healthcare Threat Operations Center, and therefore is not positioned to provide it to sector partners. This lack of sharing is due, in part, to HHS not describing coordination between the two entities in procedures defining their responsibilities for cybersecurity information sharing. Until HHS formalizes coordination for the two entities, they will continue to miss an opportunity to strengthen information sharing with sector partners.

Further, HHS entities led, or participated in, seven collaborative groups that focused on cybersecurity in the department and healthcare and public health sector. These entities regularly collaborated on cyber response efforts and provided cybersecurity information, guidance, and resources through these groups and other means during COVID-19 between March 2020 and December 2020. In addition, the HHS entities coordinated with the Department of Homeland Security's Cybersecurity and Infrastructure Security Agency (CISA) to address cyber threats associated with COVID-19. Further, the HHS entities fully demonstrated consistency with four of the seven leading collaboration practices that GAO identified, and partially addressed the remaining three (see table). Until HHS takes action to fully demonstrate the remaining three leading practices, it cannot ensure that it is improving cybersecurity within the department and the healthcare and public health sector.

Extent to Which the Department of Health and Human Services (HHS) Demonstrated Leading Practices for Collaborating

Leading practice

Extent to which the HHS working groups demonstrated the leading practice

Define and track outcomes and accountability

◑ - five groups met this practice

Bridge organizational cultures

● – all seven groups met this practice

Identify leadership

● – all seven groups met this practice

Clarify roles and responsibilities

◑ - six groups met this practice

Include relevant participants in the group

● – all seven groups met this practice

Identify resources

● – all seven groups met this practice

Document and regularly update written guidance and agreements

◑ - six groups met this practice

Source: GAO analysis of HHS documentation. | GAO-21-403

Why GAO Did This Study

HHS and the healthcare and public health sector rely heavily on information systems to fulfill their missions, including delivering healthcare-related services and responding to national health emergencies, such as COVID-19. Federal laws and guidance have set requirements for HHS to address cybersecurity within the department and the sector. Federal guidance also requires collaboration and coordination to strengthen cybersecurity at HHS and in the sector.

GAO was asked to review HHS's organizational approach to address cybersecurity. This report discusses HHS's roles and responsibilities for departmental cybersecurity; HHS's roles and responsibilities for healthcare and public health sector cybersecurity; and HHS's efforts to collaborate to manage its cybersecurity responsibilities.

To perform its work, GAO reviewed documentation describing HHS's cybersecurity roles and responsibilities, assessed those responsibilities for fragmentation, duplication, and overlap, and evaluated the department's collaborative efforts against GAO's leading practices for collaboration. GAO also interviewed relevant officials at HHS and CISA, and in the sector.

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Recommendations

GAO is making seven recommendations to HHS to improve its collaboration and coordination within the department and the sector. HHS agreed with six of the recommendations and disagreed with one. GAO continues to believe that all recommendations are appropriate.

Recommendations for Executive Action

Agency Affected Recommendation Status
Department of Health and Human Services The Secretary of HHS should direct the Chief Information Officer to coordinate cybersecurity information sharing between the Health Sector Cybersecurity Coordination Center and Healthcare Threat Operations Center. (Recommendation 1)
Closed – Implemented
In January 2022, HHS provided documentation showing that the department has developed an Information Sharing Policy that sets requirements for the sharing of information from the Healthcare Threat Operations Center (HTOC) to the Health Sector Cybersecurity Coordination Center (HC3). HHS has also developed an information sharing guide that describes how certain data in an HTOC report, such as indicators of compromise, threat information, and sensitive incident data, should be handled before being sent to HC3 and other approved distribution channels. In August 2022, HHS provided examples showing that it is implementing the information sharing policy and guide. Specifically, the department demonstrated that HTOC and HC3 are coordinating cybersecurity information sharing for threat briefings and threat incident notifications.
Department of Health and Human Services The Secretary of HHS should direct the Chief Information Officer to monitor, evaluate, and report on the progress and performance of the HHS Chief Information Security Officer Council, Continuous Monitoring and Risk Scoring Working Group, and Cloud Security Working Group. (Recommendation 2)
Open
As of September 2022, HHS provided updates on its efforts to monitor, evaluate, and report on the progress of the Chief Information Security Officer (CISO) Council, Information Security Continuous Monitoring Working Group (ISCM, formerly known as the Continuous Monitoring and Risk Scoring Working Group), and Cloud Security Working Group. Specifically, officials stated that the Chief Information Officer and CISO were evaluating performance metrics that would assist with monitoring the effectiveness of the CISO Council. Additionally, the officials stated that the department was updating the charters and other documentation for the Information Security Continuous Working Group to reflect the development of performance measures for the monitoring, evaluation, and reporting of progress for those groups. We will follow up with HHS to obtain documentation of these efforts.
Department of Health and Human Services The Secretary of HHS should direct the Assistant Secretary for Preparedness and Response to monitor, evaluate, and report on the progress and performance of the Government Coordinating Council's Cybersecurity Working Group and HHS Cybersecurity Working Group. (Recommendation 3)
Open
As of September 2022, HHS reported several actions the department has taken to improve the operations of the Government Coordinating Council's (GCC) Cybersecurity Working Group and the HHS Cybersecurity Working Group. For example, the department stated that the Assistant Secretary for Preparedness and Response's (ASPR) Division of Critical Infrastructure Protection is planning to develop a charter for the GCC Cybersecurity Working Group. In addition, HHS stated that ASPR began using contract support to develop a responsibility assignment matrix for the HHS Cybersecurity Working Group. We will follow up with the department to obtain updates and documentation of these efforts.
Department of Health and Human Services The Secretary of HHS should direct the Chief Information Officer to regularly monitor and update written agreements describing how the HHS Chief Information Security Officer Council, Continuous Monitoring and Risk Scoring Working Group, and Cloud Security Working Group will facilitate collaboration, and ensure that authorizing officials review and approve the updated agreements. (Recommendation 4)
Open
As of September 2022, HHS reported actions the department has taken to update the charters for the CISO Council, Information Security Monitoring Working Group (ISCM, formerly known as the Continuous Monitoring and Risk Scoring Working Group), and Cloud Security Working Group. Specifically, the officials stated that the Chief Information Officer and Chief Information Security Officer (CISO) have regularly reviewed the CISO Council charter and updated it as needed, and will continue to do so. HHS also stated that it is in the process of updating the Continuous Monitoring and Risk Scoring Working Group to establish an Information Security Continuous Monitoring Working, which will broaden the scope of the initial working group. The department anticipates having the new charter finalized and approved by quarter 3 of fiscal year 2022. Further, HHS stated that it is currently updating the Cloud Security Working Group Charter and anticipates having the charter finalized and approved by the end of March 2022. We will follow up with HHS to obtain the updated charters as they are finalized.
Department of Health and Human Services The Secretary of HHS should direct the Assistant Secretary for Preparedness and Response to ensure that authorizing officials review and approve the charter describing how the HHS Cybersecurity Working Group will facilitate collaboration. (Recommendation 5)
Open
As of September 2022, HHS reported that the Assistant Secretary for Preparedness and Response's Division of Critical Infrastructure Protection had briefed department leadership on its plans to revise the organization of the working groups it managed, to include the HHS Cybersecurity Working Group. We will follow up with the department to obtain an update on these efforts.
Department of Health and Human Services The Secretary of HHS should direct the Assistant Secretary for Preparedness and Response to (1) finalize written agreements that include a description of how the Government Coordinating Council's Cybersecurity Working Group will collaborate, (2) identify the roles and responsibilities of the working group, (3) monitor and update the written agreements on a regular basis, and (4) ensure that authorizing officials leading the working group approve the finalized agreements. (Recommendation 6)
Open
As of September 2022, HHS informed us that it would begin starting work to address this recommendation once it had finalized efforts to strengthen the HHS Cybersecurity Working Group, another collaborative group it manages. The department estimated that it would start this work in quarter 2 of fiscal year 2022. We will follow up with the department to obtain an update on this effort.
Department of Health and Human Services The Secretary of HHS should direct the Assistant Secretary for Preparedness and Response to update the charter for the Joint Healthcare and Public Health Cybersecurity Working Group for the current fiscal year and ensure that authorizing officials leading the working group review and approve the updated charter. (Recommendation 7)
Open
As of September 2022, HHS informed us that it would begin starting work to address this recommendation once it had finalized efforts to strengthen the HHS Cybersecurity Working Group and Government Coordinating Council's Cybersecurity Working Group, two other collaborative groups it manages. The department estimated that it would start this work in quarter 3 of fiscal year 2022. We will follow up with the department to obtain an update on this effort.

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