Improve FISMA processes now, experts say

FISMA must evolve from paper-based compliance processes to technology-based security processes, said Alan Paller of the SANS Institute and Bruce Brody of CACI.

SAN FRANCISCO -- The federal government has made little progress in improving its security grade under the Federal Information Security Management Act. The problem lies with Congress and the Office of Management and Budget, which have failed to use the FISMA process effectively so that agencies measure security procedures, leading security experts said Feb. 6 at the RSA Conference. Speaking at a session titled “The Federal Information Security Management Act (FISMA) – Should Congress Get an ‘F’?” Alan Paller, director of research at the SANS Institute, and Bruce Brody, vice president of information assurance at CACI, said it is time to improve the process. FISMA must evolve from largely paper-based compliance processes to technology-based security processes, they said. FISMA consists of a set of directives governing what security responsibilities federal entities have. It outlines oversight and management roles for the implementation of those directives. As a result, agencies must establish an integrated, risk-based information security program, and the National Institute of Standards and Technology has to set centralized standards and guidance for agencies. OMB oversees agency reporting for FISMA. The overall agency grade in 2005 was a D+, and industry experts don’t expect the result to be much better for 2006 when the grade is released in a few weeks. The stakes are high, Paller said. Organized crime is stealing billions of dollars, terrorists have discovered cyber crime as a way to raise money to buy bombs and foreign countries are stealing critical military and economic data. Paller said he senses that many taxpayers don’t realize “a lot of [their] money is being thrown away.” He hoped that the conference session would motivate attendees to encourage federal policy-makers to use continuous monitoring of metrics that actually measure security effectiveness. Also, he wants to encourage policy-makers to use the government’s $65 billion information technology procurement power to persuade vendors to build security into systems federal agencies acquire. To improve security, managers must measure what people need to be able to do. Today, agencies measure periodic certification and accreditation reports, checklists, and security awareness attendance. “If we want to fix the problem, we’ll measure continuously and we will use attack-based metrics,” Paller said. Industry should stop blaming the users and build security into systems, he added. Measuring the percentage of employees who have completed security awareness training each year is not always a good indication of how secure agencies are, Paller said. He cited a National Security Agency program at the U.S Military Academy in which cadets were given four hours of security training on spear phishing, a targeted approach to getting information that is being deployed by other countries. After the training, they were given a spear phishing test and 80 percent of the cadets fell for the attacks, Paller said. A new metric would be to measure the percent of employees who do not fall for spear phishing attempts, he said. Brody, a former chief security officer at the departments of Energy and Veterans Affairs, said he agreed with Paller. He said he worked with FISMA for five years and got a C grade only once. The other four grades were Fs. Brody said policy-makers should be asking questions such as: Brody cited some problems with FISMA grades such as annual testing, which was worth 20 points in 2005 reporting. It does not specify technical testing on a continuous basis and does not empower chief information officers to conduct it, he said. For effective IT security, CIOs must know five things, Brody said:The answers to those questions require technology such as network discovery and mapping, device discovery and identification, and software and patch management. And each question can be measured to determine the effectiveness of security, he said. FISMA is better than nothing, Brody said. It has raised awareness of security. However, now is a good time for improvement, he said.























  • Is it possible to receive a high FISMA grade and not have a secure enterprise?”
  • Worse, is it possible for an agency with a high FISMA grade to be unaware that its enterprise has been compromised?
  • Does FISMA measure the right things?



  1. What are the boundaries and topologies of the interconnected enterprise?
  2. What are the connected devices and associated communications on the enterprise’s network?
  3. How are those devices configured?
  4. Who is accessing those devices and is the access authenticated and authorized?
  5. What are the authorized and unauthorized users doing while accessing them?