Letter: FISMA improvements right on target

Regarding Christopher Fountain’s comment piece “FISMA's fifth birthday”: Well put, Christopher. I think your Federal Information Security Management Act improvement recommendations are right on target.

On the issue of creating accountability at all levels, I would add that the accountability must be real, with actual ramifications. To quote Ron Ross of the National Institute of Standards and Technology, “The most dangerous person to an enterprise is an uninformed authorizing official.” I couldn’t agree more. I recently blogged on the potential value of a well-publicized disciplinary action for an authorizing official who granted an authorization to operate a system that was inadequately certified.

Seeing a few of their fellow chief financial officers in orange jumpsuits sure lit a fire under many firms subject to Sarbanes-Oxley Act compliance requirements, and the same could be true for FISMA.

Another recommendation I would make is to accelerate the transition from negative-only reporting on certification efforts to evidence-based positive reports that provide the authorizing official with tangible, current evidence of controls that ARE operating effectively — not just findings for those that are not. Far too many security assessment reports produced by certification agents would never pass muster to a private-sector IT auditor.

Mike Nelson
STI


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