1 System Security Plan (SSP) Training Conducted by Centers for Medicare & Medicaid Services November 4 - 7, 2002.

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System Security Plan (SSP) Training

Conducted by Centers for Medicare & Medicaid Services

November 4 - 7, 2002

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Faculty

List instructors contact information

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Describes steps to produce IS RA Report

The Information Security Risk Assessment process is presented as the following three phases:

System Documentation Phase

Risk Determination Phase

Safeguard Determination Phase

Risk Assessment (RA) Methodology

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System Documentation Phase1.1 System Identification

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System Documentation Phase1.1 System Identification (con’t)

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1.2 Asset Identification

1.2.1 System Environment and Special

Considerations

1.2.2 System Interconnection/Information Sharing

1.3 System Security Level


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1) Identify potential dangers to information and systems (threats).2) Identify the system weakness that could be exploited

(vulnerabilities) associated to generate the threat/vulnerability pair.3) Identify existing controls to reduce the risk of the threat to exploit

the vulnerability.4) Determine the likelihood of occurrence for a threat exploiting a

related vulnerability given the existing controls.5) Determine the severity of impact on the system by an exploited

vulnerability.6) Determine the risk level for a threat/vulnerability pair given the

existing controls.This six step process for Risk Determination is conducted for each

identified threat/vulnerability pair.

Risk Determination Phase

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Item No.

Threat Name

Vulnerability Name

Risk Description Existing Controls

Likelihood of

Occurrence

Impact Severity

Risk Level

Risk Determination Phase (con’t)Risk Determination Table

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Risk Determination Phase (con’t)Likelihood of Occurrence Levels

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Impact Severity Description

Insignificant

Will have almost no impact if threat is realized and exploits vulnerability.

Minor

Will have some minor effect on the system. It will require minimal effort to repair or reconfigure the system.

Significant

Will result in some tangible harm, albeit negligible and perhaps only noted by a few individuals or agencies. May cause political embarrassment. Will require some expenditure of resources to repair.

Damaging

May cause damage to the reputation of system management, and/or notable loss of confidence in the system’s resources or services. It will require expenditure of significant resources to repair.

Serious

May cause considerable system outage, and/or loss of connected customers or business confidence. May result in compromise or large amount of Government information or services.

Critical May cause system extended outage or to be permanently closed, causing operations to resume in a Hot Site environment. May result in complete compromise of Government agencies’ information or services.

Risk Determination Phase (con’t)Impact Severity Levels

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Impact Severity Likelihood of

Occurrence Insignificant Minor Significant Damaging Serious Critical

Negligible Low Low Low Low Low Low

Very Low Low Low Low Low Moderate Moderate

Low Low Low Moderate Moderate High High

Medium Low Low Moderate High High High

High Low Moderate High High High High

Very High Low Moderate High High High High

Extreme Low Moderate High High High High

Risk Determination Phase (con’t)Risk Levels Table

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1) Identify the controls/safeguards to reduce the risk level of an identified threat/vulnerability pair, if the risk level is moderate or high.

2) Determine the residual likelihood of occurrence of the threat if the recommended safeguard is implemented.

3) Determine the residual impact severity of the exploited vulnerability once the recommended safeguard is implemented.

4) Determine the residual risk level for the system.

Safeguard Determination Phase(4-steps)

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Use Table 5 to summarize the analysis performed during the Safeguard Determination Phase.

Use the item numbers created for Table 1 as reference in Table 5 to correlate the analysis summarized in both tables to the same threat/vulnerability pair and associated risk level.

Item No.

Recommended Safeguard Description

Residual Likelihood of Occurrence

Residual Impact Severity

Residual Risk Level

Safeguard Determination PhaseSafeguard Determination Phase Table

Risk Assessment Process Flow

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RA Methodology

Questions ?Questions ?

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Course Objectives

Understand SSP methodology Version 3.0 (DRAFT) Certification & Documentation Requirements for

SSPs SSPs within the Information Systems Security

Program

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Legal Requirements

Computer Security Act of 1987 OMB A-130, Appendix III Government Information Systems Reform Act

(GISRA) of 2000 Contractual

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CMS Requirements

CMS SSP Methodology Version 3.0 (DRAFT) CMS Risk Assessment (RA) Methodology

Version 1.1

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CMS SSP Architecture

3-Tier Architecture CMS Systems Master General Support System (GSS) Major Application (MA)

SSP Methodology SSP Methodology

Section 1.2 Section 1.2

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General Support Systems

Defined elements of the infrastructure that provide support for a variety of users and/or applications under the same direct management control

Normally includes hardware, software, information, data, applications, communication, facilities, and people

Users may be from the same or different organizations

Physical platform and infrastructure with environmental software SSP MethodologySSP Methodology

Section 1.4.1 Section 1.4.1

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Major Applications

Systems, usually software applications, that support clearly defined business function for which there are readily identifiable security considerations and needs

Application code Examples include: MCS, FISS, CWF

SSP MethodologySSP Methodology

Section 1.4.2 Section 1.4.2

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BP SSP Documentation

Tab A: Certification Form Tab B: Accreditation Form Tab C: System Security Plan with Appendices &

Attachments Tab D: Summaries and References



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BP SSP Formal Submission

Original Certification Form with all signatures must be forwarded to:

[address]

SSP with a copy of the Certification Form must be filed in your Security Profile.

SSP Methodology SSP Methodology


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Reviewing and Updating an SSP

Security may degrade over time as technology changes

Changes occur to authorizing legislation or requirements

People and procedures change



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Certification

Acceptance of the security risk by the system ownerAcceptance of the security risk by the system owner

Requirement for all CMS systems Based on technical evaluation of a system to see how well

it meets security requirements System Owners/Manager, ISSO/SSO, and System

Maintainer/Manager must sign the certification form



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Re-Certification

Major system modification Change in security profile Serious security violation occurs Changes to threat environment Every year Expiration of Certification



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Accepts the risk of the system as it impacts the rest of the agency as Accepts the risk of the system as it impacts the rest of the agency as certified by the system ownercertified by the system owner

CMS Internal Systems - formal accreditation by CIO or Sr. Systems Security Advisor (SSA) Must authorize in writing the use of each system based on the

SSP documentation, certification and the level of risk



Accreditation Accreditation

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BP SSP Development Hints

The SSP is not: a future planning document an opportunity to educate the reader on security

terminology, controls, best practices, etc. a document to restate the CMS views on SSP methodology

The SSP is: a document that describes the current operation states what is and what is not in place, with any rational or

compensating measures for what is not in place Does not need to be developed from scratch

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SSP Development Hints

Refer to/use existing system documentation Must contain high-level summary of technical information

about the system, its security requirements, and the controls implemented to provide protection against its vulnerabilities

Where possible provide references to policy/procedures, responsible component, and how it can be reviewed

Must be dated to allow ease of tracking modifications and approvals

Use a 3-ring binder for certified SSP Maintain a history of all documentation and sign-offs

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System Security Plan Sections

An Executive Summary is OPTIONAL. If included provide a summary of each of the first four sections of the SSP

Section 1: System Identification

Section 2: Management Controls

Section 3: Operational Controls

Section 4: Technical Controls

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Section 1: System Identification

1.1 System Name/Title

1.2 Responsible Organization

1.3 Information Contact(s)

1.4 Assignment of Security Responsibility

1.5 System Operational Status

1.6 General Description / Purpose

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1.1 System Name/Title

Official name and title of the system, including acronym (example:) Fiscal Intermediary Standard System (FISS)

SOR # Financial Management Investment Board(FMIB)

N/A Web Support Team (WST) # N/A

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1.2 Responsible Organization

Name of Organization, address, city, state, zip, contract number, contractor name (if applicable)

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1.3 Information Contact(s)

Title, organization, address, city, state, zip, e-mail address, and phone number for: SSP Author System Owner/Manager System Maintainer/Manager Business Owner/Manager

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1.4 Assignment of Security Responsibility

Title, organization, address, city, state, zip, email address, and phone number for: Individual(s) responsible for security from BP Component Information System Security

Officer/System Security Officer (ISSO/SSO) Emergency contact information (name and phone

number of different person for backup) NOTE - This section must contain 4 different individuals

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1.5 System Operational Status

New Operational Undergoing a major modification

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1.6 General Description / Purpose

New “check one only” block for CMS On-site systems, CMS off-site system or External Business Partners (Medicare Contractors)

Brief description (1-3 paragraphs) on the purpose of the system and the organizational processes supported (include major inputs/outputs, users and major business functions performed)

If GSS, include all applications supported, including functions and information processed

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1.6.1 System Environment and Special Considerations

Brief (1-3 paragraphs) general description of the technical system describing the flow of data and processes through the infrastructure covered by the SSP.

Describe environmental factors that raise special security concerns

Document the physical location of the system Provide a network diagram or schematic to help

identify, define, and clarify the system boundaries

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1.6.2 System Interconnection / Information Sharing

Describe any system interconnections and/or information sharing(inputs and outputs) outside the scope of this plan

Include information on the authorization for connection to other systems or the sharing of information

Written management authorization must be obtained prior to connection

Document any written management authorizations (MOA/MOU or Data Exchange Agreement)

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1.6.2 System Interconnection / Information Sharing (cont’d)

For GSSs describe various components and sub-networks connections and /or interconnections to LAN or WAN

For MAs provide description of the major application and sub-applications along with other software interdependencies

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1.6.3 Applicable Laws or Regulations

List the laws and regulations not already listed in the CMS Master Plan

Any laws or regulations that establish system specific requirements for confidentiality, integrity, availability, audit ability, and accountability of information in the system

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1.6.4 General Description of Information Security Level

Appendix B, SSP Methodology Information Security Levels Table Information Security Levels by Information

Categories Information Owner (CMS) must define the

Information Security Level Claims processing systems have a Information Security

Level of …

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Section 1


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2.0 Management Controls

Management controls focus on the management of the computer security system and the management of risk for a system

2.1 Risk Assessment and Risk Management

2.2 Review of Security Controls

2.3 Rules of Behavior

2.4 Planning for Security in the Life Cycle

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Attach the risk assessment to the SSP and provide a summary in this section including: Value of the system or application (ie. assets) ?? Threats Vulnerabilities Effectiveness of current or proposed safeguards Describe the methods used to assess the nature and level of risk to

the GSS or MA Identify the risk assessment methodology used

Complete chart in Section 2.1 of SSP

2.1 Risk Assessment and Risk Management

Sample RA Charts for 2.1

RISK ASSESSMENT RISK MANAGEMENTVulnerability Risk

LevelRecommended

SafeguardResidual

RiskStatus of

SafeguardUpdated

RiskV1: The assignedISSO to the DSRDSGSS lacks thetechnical knowledgespecific to thissystem

HIGH Ensure the ISSOassignedresponsibility tothe DSRDS GSShas completeunderstanding ofthe system andreceivesappropriate levelsof training

Low Continuoustraining for theISSO will bescheduled astraining fundsbecomeavailable

HIGH

V2: Backup tapes arenot stored off-site

HIGH Store backuptapes off-site, aswell as on-site

Low 3 cycles ofweekly anddaily backuptapes are storedoff-site

Low

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2.2 Review of Security Controls

Summarize any/all security evaluation conducted within the last 12 months on the system (e.g.SAS-70, GAO, IG, Internal Revenue Service, Self Assessments, CAST,audits) for each review Who performed the review When the review was performed The findings and actions taken as a result of the review Where the final report is located and who to contact for

review of the final report

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2.3 Rules of Behavior

Provide summary of ROB, reference policy and how it can be reviewed Describe and document the system specific rules of

behavior or “code of conduct” of users of the GSS or MA Must include the consequences of non-compliance Must clearly state the exact behavior expected of each

person Include appropriate limits on interconnections to other

systems Cover such matters as work at home, dial-in access,

connection to the Internet, the assignment and limitation of system privileges

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2.4 Planning for Security in the Life Cycle

Summarize how security is handled by your corporation/business entity for each phase of the life cycle, reference policy and where it can be found Phase 1: Pre-Development Phase 2: Development Phase 3: Post-Development

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Section 2


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3.0 Operational Controls

Operational controls are the day-to-day procedures and mechanisms

3.1 Personnel Security

3.2 Physical and Environmental Protection

3.3 Production, I/O Controls

3.4 Incident Response Capability

3.5 Contingency Planning

3.6 Hardware, Operating Systems and System Software Maintenance Controls

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3.0 Operational Controls - con’t

3.7 Data Integrity/Validation Controls3.8 Documentation3.9 Security Awareness and Training

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3.1 Personnel Security

Provide a detailed summary of personnel security requirements of your corporation/business entity, reference policy/procedures, the responsible component, and how it can be reviewed IT related positions require evaluation and sensitivity

level designations and screening Mechanisms in place for holding users accountable for

their actions (individual accountability) User access restrictions (least privilege) Are critical functions divided among different

individuals (separation of duties)

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3.2 Physical & Environmental Protection

Provide a detailed summary of physical and environmental protections, reference policy/procedures, the responsible component, and how it can be reviewed Describe and document the physical security and

environmental controls List attributes of the physical protection afforded the

area where processing of the MA system takes place Access Controls Fire Safety Factors Water sensors

Plumbing Raised floor access Emergency exits

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3.3 Production, I/O Controls

Summarize hardcopy and media controls in place, reference policy/procedures, the responsible component, and how it can be reviewed Handling, processing, storage, and disposal of media System unique production rules, if any Describe Help-Desk support, if any is provided

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3.4 Incident Response

Summarize the following information, reference policy and how it can be reviewed Detail the preventative measures in place (automated

intrusion detection tools, automated audit logs, penetration testing)

Describe the procedures for recognizing, handling, and reporting incidents

Document who responds to alerts/advisories Describe and document the formal incident response

capability and the capability to provide users with help when an incident occurs

Applies to GSS system security plans only, for MAs refer to the GSSApplies to GSS system security plans only, for MAs refer to the GSS

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Provide a detailed summary of the contingency plan, reference policy and how it can be reviewed Discuss the arrangement and planned safeguards to

ensure the alternate processing site will provide an adequate level of security

Describe any documented backup procedures Describe coverage of backup procedures and physical

location of stored backups Describe the generations of backups kept

3.5 Contingency Planning

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3.6 Hardware, Operating System, and System Software Maintenance Controls

Summarize security controls used to monitor the installation and updates to hardware, operating system software, and other system software to ensure that the hardware and software functions as expected and that a historical record is maintained of system changes 3.6.1 Configuration Management (GSS) 3.6.2 Software Management (GSS) 3.6.3 Application Software Management Controls (MA)

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Summarize Configuration Management Procedures, reference policy and how it can be reviewed Testing and/or approving system components prior to

production Impact analyses to determine the effect of proposed

changes Change identification, approval, and documentation

procedures


3.6.1 Configuration Management

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3.6.2 Software Management (Environmental Software)

Summarize software management, reference policy and how it can be reviwed Coordinate and control updates to environment

software Monitor installation and updates Version Control Describe and document the policies for handling

copyrighted software or shareware


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3.6.3 Application Software Management Controls

Summarize Application Software Management Controls, reference policy and how it can be reviewed Describe the application software controls Version control Describe the security controls used to monitor the

installation and updates of the application software Describe: (or summarize and reference procedures)

If the application software is developed in-house or under contract Who owns the software How emergency fixes are handled If test data is “live” data or made-up

Applies to MA security plans onlyApplies to MA security plans only

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Summarize controls in place to prevent/detect destruction or unauthorized data modification, reference policy and how it can be reviewed Virus detection and elimination software procedures Reconciliation routines used by the system Integrity verification programs used by the application to

look for evidence of data tampering, errors, and omissions

System performance monitoring Message authentication

3.7 Data Integrity/Validation Controls

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3.8 Documentation

Describe the set of formal materials which support the operation of the GSS or MA, its components, operations, and use

List the existing documentation maintained, including the title, date, and office responsible for maintaining the documentation

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Hardware and software descriptions

Standard operating procedures

Application requirements Application program

documentation and specs

Security policies, standards, procedures, and approvals

Emergency procedures MOU/MOAs User manuals Backup procedures

3.8 Documentation (con’t)

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3.9 Security Awareness and Training

List the types and frequency of system-specific security training established, how the training is conducted, attendance is documented and how the system owner ensures that it is conducted prior to allowing access

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Section 3


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4.0 Technical Controls

Technical and logical in place controls to authorize or restrict users and information. For MAs, describe additional enhancements or modifications of the controls beyond the GSS

4.1 Identification and Authentication4.2 Authorization & Access Controls4.3 Remote Users & Dial Up Controls4.4 Wide Area Network (WAN) Controls4.5 Public Access Controls4.6 Test Scripts/Results4.7 Audit Trails

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4.1 Identification & Authentication Controls

Provide a detailed summary of the Identification and Authentication controls in place, reference policy and how it can be reviewed Unique identification, e.g., UserId Unique authentication, e.g. password Maintenance of UserId and password Length of password and frequency of password changes For GSS state name of software used to control all

aspects of UserID and password If used, describe biometrics or token controls

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4.2 Authorization & Access Controls

Provide a detailed summary of procedures, hardware, and/or software used to control access to resources, reference policy and how it can be reviewed Role based access Separation of duties Usage of Access Control Lists (ACL’s) Security software and restricting access How access is restricted between systems Controls for detecting unauthorized access Inactive user activity and automated disconnection System access outside normal working hours

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4.2 Authorization & Access Controls - con’d

How the access control mechanism supports individual accountability and audit trails

State the number of invalid access attempts that may occur and the actions taken when that limit is exceeded

If cryptography is used, provide a detailed summary of methodology and key management procedures

Provide sample system-specific warning banner

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4.3 Remote Users & Dial-up Controls

Provide a detailed summary of remote users and dial-up controls, reference policy and how it can be reviewed Describe the type of remote access (dial, Internet)

permitted Functions that may or may not be authorized for remote

use, i.e., differences from internal access permissions

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4.4 Wide Area Networks (WAN) Controls

Provide a detailed summary of the wide area network controls Protection against unauthorized system penetration,

Internet threats & vulnerabilities Types of network connections, e.g., Internet Describe additional hardware or technical controls to

provide protection e.g., firewalls, proxy servers Network Diagram can be included

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4. 5 Public Access Controls

Provide detail summary when or if public access is authorized, reference policy/procedures, the responsible component and how it can be reviewed Access controls used to secure the system Controls to prevent public users, if access is authorized, from

modifying information on the system Legal considerations to allowing access to the information Describe rationale for the use or non-use of warning banners

and provide an example of the banners used for this system If no public access state “system does not allow public access”

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4.6 Test Scripts/Results

Summarize the findings of all tests/results Describe the test scripts and results that were used to

test the effectiveness of the security controls Include title, date, and office responsible for

maintaining the test scripts/results

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4.7 Audit Trails

Provide a detailed summary of existing audit trails Document the auditing mechanisms Describe what is recorded, who reviews, how often are

they reviewed and what procedures are employed for corrective actions as a result of a finding

Describe when audit trails are employed, e.g., on a given cycle, continuously, when an incident occurs, etc.

Describe audit trail archive procedures including how long they are kept, where stored, and what media type

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5.0 Appendices & Attachments

Appendix A – Equipment List (Primarily for GSS) Appendix B – Software List Attachments

Risk Assessment (Required)

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Section 4 & 5


1 System Security Plan (SSP) Training Conducted by Centers for Medicare & Medicaid Services November 4 - 7, 2002.

Documents

ssp u security

u contractual slide

address u ssp

u application code u

u ssp methodology version

risk determination phase

u use table

requirements u people