Recommendation: The Director of OMB should establish a process for monitoring and holding agencies accountable for authorizing cloud services through FedRAMP. (Recommendation 1)

Agency: Executive Office of the President: Office of Management and Budget: Office of the Director
Status: Open
Priority recommendation

Comments: OMB neither agreed nor disagreed with this recommendation and as of September 2020, the office has not provided information on its actions to implement our recommendation. To fully implement this recommendation, OMB needs to collect data on the extent to which federal agencies are using cloud services authorized outside of FedRAMP and oversee agencies' compliance with using the program. According to an OMB Associate General Counsel, the agency does not have a mechanism for enforcing agencies' compliance with its guidance on FedRAMP. However, we believe that OMB can and should hold agencies accountable for complying with its policies. By implementing this recommendation, OMB could substantially improve participation in the FedRAMP program, which is intended to standardize security requirements for federal agencies' authorizations of cloud services. We will update the status of this recommendation when OMB provides information on its corrective actions.

Recommendation: The Administrator of GSA should direct the Director of FedRAMP to clarify guidance to agencies and cloud service providers on program requirements and responsibilities. (Recommendation 2)

Agency: General Services Administration: Office of the Administrator
Status: Open

Comments: As of September 2020, GSA has not provided evidence to close this recommendation. We will continue to monitor the agency's progress and update the recommendation's status when GSA provides its corrective actions.

Recommendation: The Administrator of GSA should direct the Director of FedRAMP to improve the program's continuous monitoring process by allowing more automated capabilities, including for agencies to review documentation. (Recommendation 3)

Agency: General Services Administration: Office of the Administrator
Status: Open

Comments: As of September 2020, GSA has not provided evidence to close this recommendation. We will continue to monitor the agency's progress and update the recommendation's status when GSA provides its corrective actions.

Recommendation: The Administrator of GSA should update security plans for selected systems to include the description of security controls and reviews and approvals plan. (Recommendation 4)

Agency: General Services Administration: Office of the Administrator
Status: Open

Comments: As of September 2020, GSA has not provided evidence to close this recommendation. We will continue to monitor the agency's progress and update the recommendation's status when GSA provides its corrective actions.

Recommendation: The Administrator of GSA should update the security assessment report for the selected system to identify the summarized results of control effectiveness tests. (Recommendation 5)

Agency: General Services Administration: Office of the Administrator
Status: Open

Comments: As of September 2020, GSA has not provided evidence to close this recommendation. We will continue to monitor the agency's progress and update the recommendation's status when GSA provides its corrective actions.

Recommendation: The Administrator of GSA should update the list of corrective actions for selected systems to identify the responsible office and estimated funding required and anticipated source of funding. (Recommendation 6)

Agency: General Services Administration: Office of the Administrator
Status: Open

Comments: As of September 2020, GSA has not provided evidence to close this recommendation. We will continue to monitor the agency's progress and update the recommendation's status when GSA provides its corrective actions.

Recommendation: The Administrator of GSA should develop guidance requiring that cloud service authorization letters be provided to the FedRAMP program management office. (Recommendation 7)

Agency: General Services Administration: Office of the Administrator
Status: Open

Comments: As of September 2020, GSA has not provided evidence to close this recommendation. We will continue to monitor the agency's progress and update the recommendation's status when GSA provides its corrective actions.

Recommendation: The Secretary of HHS should direct the Director of CDC to update the security plan for the selected system to identify the authorization boundary, the system operational environment and connections, a description of security controls, and the individual reviewing and approving the plan and date of approval. (Recommendation 8)

Agency: Department of Health and Human Services: Office of the Secretary
Status: Open

Comments: In June 2020, CDC stated it has taken actions to address our recommendations, but we have not received evidence of its corrective actions. We will continue to monitor the agency's progress and update the recommendation's status when CDC provides its corrective actions.

Recommendation: The Secretary of HHS should direct the Director of CDC to update the security assessment report for the selected system to identify the summarized results of control effectiveness tests. (Recommendation 9)

Agency: Department of Health and Human Services: Office of the Secretary
Status: Open

Comments: In June 2020, CDC stated it has taken actions to address our recommendations, but we have not received evidence of its corrective actions. We will continue to monitor the agency's progress and update the recommendation's status when CDC provides its corrective actions.

Recommendation: The Secretary of HHS should direct the Director of CDC to update the list of corrective actions for the selected system to identify the specific weaknesses, funding source, changes to milestones and completion dates, identified source of weaknesses, and status of corrective actions. (Recommendation 10)

Agency: Department of Health and Human Services: Office of the Secretary
Status: Open

Comments: In June 2020, CDC stated it has taken actions to address our recommendations, but we have not received evidence of its corrective actions. We will continue to monitor the agency's progress and update the recommendation's status once CDC provides its corrective actions.

Recommendation: The Secretary of HHS should direct the Administrator of CMS to update the system security plans for selected systems to identify a description of security controls. (Recommendation 11)

Agency: Department of Health and Human Services: Office of the Secretary
Status: Open

Comments: In June 2020, HHS stated CMS took actions to close this recommendation, but CMS has not yet provided evidence of its corrective actions. We will continue to monitor the agency's progress and update the recommendation's status when CMS provides its corrective actions.

Recommendation: The Secretary of HHS should direct the Administrator of CMS to update the security assessment report for selected system to identify the summarized results of control effectiveness tests. (Recommendation 12)

Agency: Department of Health and Human Services: Office of the Secretary
Status: Open

Comments: In June 2020, HHS stated CMS took actions to close this recommendation, but CMS has not yet provided evidence of its corrective actions. We will continue to monitor the agency's progress and update the recommendation's status when CMS provides its corrective actions.

Recommendation: The Secretary of HHS should direct the Administrator of CMS to update and document the CMS remedial action plan for the selected system to identify the anticipated source of funding. (Recommendation 13)

Agency: Department of Health and Human Services: Office of the Secretary
Status: Open

Comments: In June 2020, HHS stated CMS took actions to close this recommendation, but CMS has not yet provided evidence of its corrective actions. We will continue to monitor the agency's progress and update the recommendation's status when CMS provides its corrective actions.

Recommendation: The Secretary of HHS should direct the Administrator of CMS to prepare letters authorizing the use of cloud services for the selected systems and submit the letters to the FedRAMP program management office. (Recommendation 14)

Agency: Department of Health and Human Services: Office of the Secretary
Status: Open

Comments: In June 2020, HHS stated CMS took actions to close this recommendation, but CMS has not yet provided evidence of its corrective actions. We will continue to monitor the agency's progress and update the recommendation's status when CMS provides its corrective actions.

Recommendation: The Secretary of HHS should direct the Director of NIH to update security plans for selected systems to identify the authorization boundary, system operation in terms of mission and business processes, operational environment and connections, and a description of security controls. (Recommendation 15)

Agency: Department of Health and Human Services: Office of the Secretary
Status: Open

Comments: In June 2020, NIH stated it is taking actions to address this recommendation, but the agency did not provide evidence of its corrective actions. NIH stated it will provide an update in December 2020. We will continue to monitor the agency's progress and update the recommendation's status when NIH provides its corrective actions.

Recommendation: The Secretary of HHS should direct the Director of NIH to update the security assessment report for selected systems to identify summarized results of control effectiveness tests. (Recommendation 16)

Agency: Department of Health and Human Services: Office of the Secretary
Status: Open

Comments: In June 2020, NIH stated it is taking actions to address this recommendation, but the agency did not provide evidence of its corrective actions. NIH stated it will provide an update in December 2020. We will continue to monitor the agency's progress and update the recommendation's status when NIH provides its corrective actions.

Recommendation: The Secretary of HHS should direct the Director of NIH to update the NIH list of corrective actions for selected systems to identify estimated funding and anticipated source of funding, key milestones with completion dates, and changes to milestones and completion dates. (Recommendation 17)

Agency: Department of Health and Human Services: Office of the Secretary
Status: Open

Comments: In June 2020, NIH stated it is taking actions to address this recommendation, but the agency did not provide evidence of its corrective actions. NIH stated it will provide an update in December 2020. We will continue to monitor the agency's progress and update the recommendation's status when NIH provides its corrective actions.

Recommendation: The Secretary of HHS should direct the Director of NIH to submit the division's letters authorizing the use of cloud services for the selected systems to the FedRAMP program management office. (Recommendation 18)

Agency: Department of Health and Human Services: Office of the Secretary
Status: Open

Comments: In June 2020, NIH stated it is taking actions to address this recommendation, but the agency did not provide evidence of its corrective actions. NIH stated it will provide an update in December 2020. We will continue to monitor the agency's progress and update the recommendation's status when NIH provides its corrective actions.

Recommendation: The Administrator of EPA should update security plan for the selected operational system to identify a description of security controls, and the individual reviewing and approving the plan and date of approval. (Recommendation 19)

Agency: Environmental Protection Agency
Status: Open

Comments: In June 2020, EPA stated it is taking actions to address this recommendation, but the agency did not provide evidence of its corrective actions. We will continue to monitor the agency's progress and update the recommendation's status when EPA provides its corrective actions.

Recommendation: The Administrator of EPA should update the security assessment report for the selected operational system to identify the summarized results of control effectiveness tests. (Recommendation 20)

Agency: Environmental Protection Agency
Status: Open

Comments: EPA did not concur with this recommendation and as of September 2020, the agency has not provided any evidence of its corrective actions. We will continue to monitor the agency's progress and update the recommendation's status when EPA provides its corrective actions.

Recommendation: The Administrator of EPA should update the list of corrective actions for the selected operational system to identify the specific weakness, estimated funding and anticipated source of funding, key remediation milestones with completion dates, changes to milestones and completion dates, and source of the weaknesses. (Recommendation 21)

Agency: Environmental Protection Agency
Status: Open

Comments: In June 2020, EPA stated it is taking action to address this recommendation, but the agency did not provide evidence of its corrective actions. We will continue to monitor the agency's progress and update the recommendation's status when EPA provides its corrective actions.

Recommendation: The Administrator of EPA should prepare the letter authorizing the use of cloud service for the selected operational system and submit the letter to the FedRAMP program management office. (Recommendation 22)

Agency: Environmental Protection Agency
Status: Open

Comments: EPA did not concur with this recommendation and as of September 2020, the agency has not provided any evidence of its corrective actions. We will continue to monitor the agency's progress and update the recommendation's status when EPA provides its corrective actions.

Recommendation: The Administrator of EPA should develop guidance requiring that cloud service authorization letter be provided to the FedRAMP program management office. (Recommendation 23)

Agency: Environmental Protection Agency
Status: Open

Comments: EPA did not concur with this recommendation and as of September 2020, the agency has not provided any additional evidence. We will continue to monitor the agency's progress and update the recommendation's status when EPA provides its corrective actions.

Recommendation: The Director of OMB should expand its coordination of CyberStat review meetings for those agencies with a demonstrated need for assistance in implementing information security. (Recommendation 2)

Agency: Executive Office of the President: Office of Management and Budget
Status: Open
Priority recommendation

Comments: In January 2020, OMB officials stated that they have incorporated agency feedback for enhancing the CyberStat program into an updated concept of operations document that is currently in draft. To consider this recommendation fully implemented, OMB needs to provide us with an updated concept of operations document for the CyberStat program, and demonstrate the expansion of CyberStat review meetings to agencies that require additional assistance due to persistent information security deficiencies. As of September 2020, OMB has not provided sufficient evidence to close this recommendation.

Recommendation: The Director of OMB should collaborate with CIGIE to ensure that the inspector general reporting metrics include the FISMA-required information security program element for system security plans. (Recommendation 3)

Agency: Executive Office of the President: Office of Management and Budget
Status: Open

Comments: As of September 2020, we were still waiting to receive OMB's 180-day letter detailing the actions it plans to take to address the recommendation.

Recommendation: The Secretary of Education should enroll loan servicers in FSA's continuous monitoring program and, in the interim, require these entities to report the results of security controls testing at an FSA-defined frequency. (Recommendation 1)

Agency: Department of Education
Status: Open

Comments: FSA concurred with this recommendation and the agency stated that loan servicers are scheduled to be enrolled in its ongoing security authorization program beginning in fiscal year 2019. In November 2019, FSA officials told us that this recommendation had been implemented; however, they did not provide documentation to demonstrate actions taken to address the recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Education should enroll private collection agencies in FSA's continuous monitoring program, and, in the interim, require these entities to test all controls at an FSA-defined frequency and regularly report the results. (Recommendation 2)

Agency: Department of Education
Status: Open

Comments: FSA stated that it concurred with this recommendation, but the actions it said it planned to take would not fully address it. In November 2019, FSA officials told us that this recommendation had been implemented; however, they did not provide documentation to demonstrate actions taken to address the recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Education should modify FSA's agreements with guaranty agencies to specify a required baseline of security controls based on the impact level of the information shared with these agencies, as determined by FSA. (Recommendation 3)

Agency: Department of Education
Status: Open

Comments: FSA concurred with this recommendation and described planned actions to address it. In November 2019, FSA officials told us that this recommendation has a pending date of 5/31/2020 for completion When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Education should establish a process for continuous monitoring of guaranty agencies' implementation of security and privacy requirements between on-site assessments, to include testing all controls at an FSA-defined frequency and regularly reporting results. (Recommendation 4)

Agency: Department of Education
Status: Open

Comments: FSA partially concurred with this recommendation and described actions it planned to take in response. However, we believe the entire recommendation is still warranted. In November 2019, FSA officials told us that this recommendation had been implemented; however, they did not provide documentation to demonstrate actions taken to address the recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Education should include specific security and privacy requirements in agreements with the Federal Family Education Loan (FFEL) Program lenders based on FSA's categorization of the information shared with the lenders. (Recommendation 5)

Agency: Department of Education
Status: Open

Comments: FSA stated that it partially agreed with this recommendation; however, if effectively implemented, the planned actions it described would address this recommendation. In November 2019, FSA officials told us that this recommendation had been implemented; however, they did not provide documentation to demonstrate actions taken to address the recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: The Secretary of Education should develop policies and procedures to gain assurance that FFEL lenders have appropriate security and privacy controls in place and that these controls are being regularly tested and monitored. (Recommendation 6)

Agency: Department of Education
Status: Open

Comments: FSA did not concur with this recommendation. However, we believe it is still warranted. In November 2019, FSA officials told us that this recommendation had been implemented; however, they did not provide documentation to demonstrate actions taken to address the recommendation. When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Recommendation: As the Board of Governors implements plans to develop an ERM framework, it should include a component to identify and assess risks of regulatory capture across the LISCC program. (Recommendation 1)

Agency: Federal Reserve System: Board of Governors
Status: Open

Comments: In September 2020, the Federal Reserve told us the status of their response to this recommendation had remained unchanged since their August 2018 update. In August 2018, the Board of Governors reported to us that it was developing its ERM framework. The Board added that it was establishing a Board Risk Committee (comprised of senior leaders) to oversee its ERM program and serve as the central forum for addressing Board-wide risk issues. The Board also said that it has begun to implement a number of strategic components of the ERM framework. In August 2019, the Board stated that in their view, the ERM framework they are developing would not significantly alter the management processes that the Board and System have in place under the LISCC program that continue to work effectively. The Board reported to us that it has continued to develop the ERM program with guidance of the Board Risk Committee, which meets quarterly, and continues to serve as the central forum for Board-wide risk issues and oversight of the ERM program. In August 2020, the Board added that it would take several years to develop the ERM program. The Board also will continue to implement strategic components of the ERM framework throughout the Board.

Recommendation: The Board of Governors should finalize and implement program-wide guidance for the LISCC Reserve Banks on implementing LISCC policies. (Recommendation 2)

Agency: Federal Reserve System: Board of Governors
Status: Open

Comments: In September 2020, the Federal Reserve told us the status of their response to this recommendation had remained unchanged since their August 2019 update. In August 2019, the Board of Governors told us that the LISCC supervisory program had taken several steps to "finalize and implement program-wide guidance for the LISCC Reserve Banks on implementing LISCC policies." The Board reported that in 2017 it had issued a near-final LISCC program manual, which they said will memorialize all aspects of the LISCC supervisory program. The Board added the updated manual will reflect the results of a self-assessment of the LISCC Program's first full year of operations under the LISCC core program model, and the initial implementation of the new Large Financial Institution Ratings Framework. The Board also said that, since the last update, the LISCC supervisory program's operating policies, procedures, and templates for the conduct of supervisory activities have been completed and implemented.

Recommendation: The Board of Governors should streamline its conflict-of-interest disclosure review process for participants in the LISCC program, such as by storing disclosure information in compatible electronic systems. (Recommendation 4)

Agency: Federal Reserve System: Board of Governors
Status: Open

Comments: In September 2020, the Federal Reserve told us the status of their response to this recommendation had remained unchanged since their August 2018 update. In August 2018, the Board of Governors told us that they were assessing the feasibility of integrating existing electronic systems. They added that they have drafted guidance that develops a LISCC-specific conflicts of interest and examiner credential program that will seek to ensure consistency in the interpretation and application of conflicts of interest rules for all staff, both at the Board and the Reserve Banks, that participate in the LISCC supervisory program. They said that the Board plans to issue this guidance and begin implementation of a more consistent and centralized disclosure review approach in 2018. In addition, they said that they have begun collecting and storing conflicts of interest disclosure information for all LISCC participants, including Board LISCC staff, in one electronic system. They added that they have provided initial training to Board LISCC staff on the disclosure review process and the electronic system to ensure consistent collection of conflicts of interest data for all LISCC participants.

Recommendation: The Board of Governors should systematically collect and maintain information on the institutions supervisory employees work for before they are hired by the Federal Reserve and their employment destination when they leave. (Recommendation 5)

Agency: Federal Reserve System: Board of Governors
Status: Open

Comments: In September 2020, the Federal Reserve told us the status of their response to this recommendation had remained unchanged since their August 2018 update. In August 2018, the Board of Governors told us that they had implemented policies intended to mitigate the risk that an employee may be influenced by prior employment or the prospect of future employment and place their private interests ahead of the organization's supervisory mission. As an example, they said that recently the Federal Reserve broadened the scope of post-employment restrictions applicable to senior examiners. They added that the Board has begun to develop a more systematic approach to collect and monitor pre- and post-employment data through the use of an electronic system. They said that this updated electronic system is scheduled to be released, for both Board and Reserve Banks use, in 2019.

Recommendation: The Board of Governors should conduct a periodic self-assessment of ethics programs, policies, and procedures that apply to LISCC program participants. (Recommendation 6)

Agency: Federal Reserve System: Board of Governors
Status: Open

Comments: In September 2020, the Federal Reserve told us the status of their response to this recommendation had remained unchanged since their August 2018 update. In August 2018, the Board of Governors told us that their Ethics program staff and Supervision & Regulation staff are jointly assessing the current ethics programs, policies, and procedures applicable to LISCC program participants. The Federal Reserve expects to finalize and implement new conflicts of interest policies and procedures applicable to LISCC participants in 2019.