NASA's new FISMA approach and what it means for you

A NASA deputy CIO explains NASA's new policy for certifying its systems as secure

This year, NASA officials won't have to go through a traditional paper-based process for recertifying existing systems as compliant with security requirements, according to a notice from the agency's information technology office.

The edict is a significant break with the way agencies typically have measured their systems' security and, if other agencies follow NASA's lead, it could have governmentwide implications.   

Agencies are required to get their systems certified and accredited under the Federal Information Security Management Act. However, critics say the paper-based reports that agencies have typically completed to meet those requirements amount to costly, time-consuming, snap-shots of security.

Last month the Obama administration announced new standards for agency reporting under FISMA as part of an effort to get agencies to shift from paper-based reports to real-time monitoring of systems. Citing those new instructions, NASA’s Deputy Chief Information Officer for IT Security Jerry Davis sent a memo May 18 that said the agency will not generally require leaders to recertify existing systems with the paper-based process.

Davis wrote that NASA is developing a new program for the security authorization proces based on continuous monitoring, automated tools and reducing paperwork. However, new systems or those which have undergone significant changes will still have to go through the standard certification and accreditation process until the new process is in place.

The C&A process that NASA plans to put in place amounts to changing a bureaucratic process to one that's focused on risk management. NASA hopes to have it in place for fiscal 2011, Davis told FCW.

Davis said the thinking behind the shift is that once a system is certified and accredited it should immediately be continuously monitored using tools that the agency already has, rather than hiring someone three years later to come in and look at the controls that are in place on existing systems. 

“Security is still going to be done. Certification and accreditation will still be done, but the way we do it is going to change significantly and the frequency of it will change,” he said. “Instead of every three years, you’re really going to be doing it, in a sense, on like a weekly or monthly basis, you’re always going to be looking at those controls and adjusting them for changes." spoke with Davis about the new guidance and what it would mean for NASA's 627 IT systems that do everything from control launches to handle back-office processing functions. Here are some additional portions of that interview, edited for length and clarity: What led you to release this memo, and what was the thought process behind where you are going?

Jerry Davis: A lot of it had to do with timing. .. You have at least six or seven different cybersecurity bills going through Congress, you had [the Office of Management and Budget] with [Federal CIO] Vivek Kundra trying to change things for the better and getting away from this paper-based activity.

The other side it that really drove it is that NASA was at a point where three years ago we had certified and accredited systems, and the requirement is that you have to do it every three years or when there is a significant change. Well, our three year [certification expires] in a few months, and I just thought it was the perfect opportunity for system owners to save money by not doing this large paper process that really at the end of the day doesn’t provide much benefit. And I'd like to see the money that they would have spent on doing this paper process, put it back into their programs and their projects and get back to the mission that NASA has in front of it.

Timing had a lot to do with it, and doing what’s right also had a lot to do with it. FISMA was very good when it came out at getting everybody’s focus on security and getting the focus on C&A, but we have to evolve and we haven't evolved in the last 10 years or so as it relates to threats and attacks and that sort of thing. So we’re trying to evolve and this is our first step forward. Can you tell us a little bit about the automated controls that you’ve been developing?

JD: The continuous monitoring activity is really just a system that collects security information, tools that we already had that collects information about systems and security controls on that system. For instance, we have things like patch management where we can scan all of our system to make sure they have latest and most critical patches. We have vulnerability management systems that look for common vulnerabilities in those same systems and those applications, and things like configuration.

What we do is we take all that information and basically crunch it up into a database and it produces a score, a risk score, that we can produce back for those system owners to tell them what their risk score is for their system based on looking at common controls [and] security configurations with tools that we already had. We’re just bringing it all together now for it to make sense. So your three-year cycle for recertifying systems was coming up this year?

JD: Exactly; it was coming up in September of this year and I just couldn’t see NASA spending the money to go through this process of looking at controls [for which] the posture will change ten minutes after they’ve looked at them. How much money would it have cost to recertify the system controls this year with the paper process, and how much do you think you will save with this new approach?

JD: We know for a fact that in 2007, for these systems, we spent somewhere close to $12 million, and that was just to have the contractors come in an assess the controls for that four- or five-day period. That does not include the dollar amount that system owners spend having someone sit at a desk and type up paperwork to do the system security plan.

[When] we start adding in the support, contractors that help support that process, [the cost] could easily double. We suspect that it’s at least $20 million or so we could end up coming close to saving.

FCW: What has the response been like your memo? Have you heard from other chief information officers? Have you heard from OMB and Vivek Kundra?

JD: Not directly [from Kundra]. We know that he has the memo, we know that OMB has a favorable light on this because we’re doing exactly what was mentioned in the FISMA guidance and in [Kundra’s] testimony to Congress back in March.

From the field, from my counterparts, I’ve got nothing but kudos from everywhere, from places I used to work to my counterparts at other agencies. And we’re getting kudos from the Hill, from Congress ... I'm on tap go to and brief two congressional senators' staff over the next week or so because they said they believe [what we're doing] is the right move, and they want to hear what we plan on doing going forward and how we came to making this decision.

FCW: Do you get the impression from your colleagues that other departments and agencies might soon follow suit?

JD: I’ve gotten positive word from a couple of agencies that say they’re following suit. They may not be as vocal about it as NASA was, but they are going to follow suit. I think it was a catalyst that a lot of people needed to get out of the mire of paperwork that they’re in today.


About the Author

Ben Bain is a reporter for Federal Computer Week.

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Reader Comments

Mon, Sep 20, 2010 Jack

This sums it up: We found that NASA’s IT security program had not fully implemented key FISMA requirements needed to adequately secure Agency information systems and data. For example, we found that only 24 percent (7 of 29) of the systems we reviewed met FISMA requirements for annual security controls testing and only 52 percent (15 of 29) met FISMA requirements for annual contingency plan testing. In addition, only 40 percent (2 of 5) of the external systems we reviewed were certified and accredited. These deficiencies occurred because NASA did not have an independent verification and validation function for its IT security program. We also found that NASA’s Office of Chief Information Officer (OCIO) had not effectively managed corrective action plans used to prioritize the mitigation of IT security weaknesses. This occurred because OCIO did not have a formal policy for managing the plans and did not follow recognized best practices when it purchased an information system that it hoped would facilitate Agency-wide management of IT corrective action plans. However, after spending more than $3 million on the system since October 2005, implementation of the software failed. The Agency is currently expending funds to acquire a replacement system. Specifically, we found that the information system was significantly underutilized and therefore was not an effective tool for managing corrective action plans across NASA. For example, the system contained corrective actions plans for only 2 percent (7 of 289) of the 29 systems we sampled. In our judgment, the system was underutilized because OCIO did not fully document detailed system requirements prior to selecting the system and did not have users validate requirements via acceptance testing prior to implementing it. Because the information system contained minimal data and the manual process the Agency relied on was not consistently followed, OCIO’s management of corrective actions plans was ineffective and did not ensure that significant IT security weaknesses were corrected in a timely manner. Until NASA takes steps to fully meet FISMA requirements and to improve its system acquisition practices, NASA’s IT security program will not be fully effective in protecting critical Agency information systems. Moreover, until such improvements are made OCIO will not be in a position to effectively allocate resources to correct IT security weaknesses.

Sun, Jun 6, 2010 Tcompton Newport News

Per the 2009 GAO report, "NASA has not yet fully implemented key activities of its information security program to ensure that controls are appropriately designed and operating effectively." ( No longer doing C&A assessments will not only save NASA money but also avoid documenting these policy and procedural lapses. Studying an agency that has successfully implemented FISMA as an actual security process (e.g. George Strawn at NSF, would be a much wiser path rather than abandoning the FISMA framework because of their implementation challenges.

Sun, May 30, 2010 badgeswapper

This is an interesting policy twist. The contractor workforce has expended a great deal of effort gearing up to support the government's C&A requirements. It, however, does seem to be a move in the right direction away from the endless reporting and data calls. --------------------------------------- - the forum for government contractors

Fri, May 28, 2010

What confidence?? One of the ways you formally proved your maturity and adherence to the Risk Management Framework. As Davis is throwing this out the window expect NO assurance and NO confidence.

Thu, May 27, 2010

How does the Davis directive impact agency confidence in NASA SEWP?

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