OMB reporting guidelines cause semantic disputes
Members of the federal Chief Information Security Officers Forum have sent a memo to the Office of Management and Budget seeking clarification of OMB's security reporting policies.
The security officials said much is still open to interpretation in OMB's guidelines for helping agencies comply with the Federal Information Security Management Act of 2002. The confusion, they said, has given some agency officials an excuse to treat the new law as a burdensome reporting exercise, while others are trying hard to comply with the law's requirements.
Daniel Galik, chief of mission assurance at the Internal Revenue Service, belongs to the latter group. "FISMA is pretty clear on the major systems," he said. "It's all the other little cats and dogs, the minor systems," about which the rules are unclear, he said.
Much of the confusion derives from interpretations of terms such as "major systems" and "minor systems." In sum, minor systems outnumber major systems in most agencies. And when combined, they add up to "a lot of computing power, a lot of information being processed," Galik said.
The IRS has 90 major systems but more than 325 minor ones. With 90 major systems to worry about, dwelling on minor systems may seem unnecessary, he said. But he wants to do the right thing.
Others share Galik's wish that OMB officials would include more examples of major and minor systems in their forthcoming FISMA guidelines for federal agencies. "Without actual examples, there's always room for interpretation," said David Filbey, chief information security officer at the National Archives and Records Administration.
Filbey and other security experts said they want OMB officials to help them resolve the semantic disputes and other interpretive disagreements. As it is, the agencies charged with ensuring FISMA compliance — OMB and the National Institute of Standards and Technology — tend to steer clear of disagreements among agency security officers, chief information officers and inspectors general, Filbey said.
Taking the necessary steps to secure major systems is expensive, he added, so some agencies are tempted to hide a number of their systems behind a definition of a major system that is overly broad or too narrow.
"If everything goes under the radar screen as not being a major information system, then you don't have to do all these other things," Filbey said. Other activities include having the systems certified and accredited by security experts and senior agency officials. Both procedures are required under FISMA guidelines.
Until federal agencies reach a common understanding of what the new law requires, security software companies such as Xacta Corp. will find their roles much more difficult. Xacta receives "inconsistent feedback [from agency officials] on what they want our product to provide," said Richard Tracy, chief security officer for Xacta, which makes a FISMA compliance and reporting product called Xacta IA Manager.
Agency officials will struggle with system definitions until they adjust to the new type of management challenge that FISMA has created, said Kenneth Ammon, a former National Security Agency official who now is president of NetSec Inc., a security services company. But it will take time, he said, for agency officials to learn how to think less like technology managers and more like information managers. That, in a nutshell is what FISMA is all about, he added.
Ammon said FISMA compliance requires managers who can conceptualize information as a mission-critical system and can identify all of the people who touch that information, no matter what hardware they use or where their offices are. "It takes a lot of work to do that," he said.
WHAT IS A SYSTEM?
Defining a system has become important for federal officials and software vendors trying to provide appropriate security protection for agency information systems. Answers vary depending on whom you ask.
Here is how Richard Tracy, chief security officer at Xacta Corp., sums up the semantic foolishness:
At one extreme is somebody who wants to draw a boundary around an entire Air Force base and call it a system. At the other extreme is someone whose definition of a system is a computer mouse.
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