Consensus Audit Guidelines no substitute for FISMA guidance

NIST is updating its comprehensive FISMA security control guidelines, which the CAG overlaps but does not duplicate.

A collaborative effort by government and private sector organizations has produced a prioritized set of security controls for information technology systems that are amenable to automated monitoring. The controls were released for public review yesterday as the Consensus Audit Guidelines (CAG).

These guidelines neither duplicate nor replace guidance for complying with federal IT security requirements.

The National Institute of Standards and Technology (NIST), charged with developing standards and guidelines for complying with the Federal Information Security Management Act (FISMA), has produced a comprehensive set of recommended security controls that covers much of the same territory as CAG.

“We included many of the same control elements addressed in the CAG initiative,” said Ron Ross, senior computer scientist at NIST.

NIST recently released for review its first major update of the guidelines, Special Publication 800-53, titled "Recommended Security Controls for Federal Information Systems and Organizations." When the public review for SP 800-53 is finished March 27, the two documents could be more closely aligned.

“Hopefully, we will be able to cover many of the things that CAG has done,” Ross said.

Ross does not see the two sets of guidelines as in competition, but warned that focusing on a small subset of threats, vulnerabilities and controls could miss fundamental weaknesses in information systems.

“Security managers need to take a holistic approach to a challenging set of problems,” he said. “The controls work as an interlocking set.”

The CAG does not attempt to provide a comprehensive set of security controls, but is an attempt to prioritize concerns and identify tools that can provide the best returns by focusing on critical issues and low hanging fruit. The CAG sites language in proposed FISMA reform legislation that calls for a prioritized baseline of IT security controls that can be continuously and automatically monitored.

“This consensus document is designed to begin the process of establishing that prioritized baseline of information security measures and controls,” the guidelines say. “The consensus effort that has produced this document has identified twenty specific security controls that are viewed as essential for blocking known high-priority attacks. Fifteen of these controls can be monitored, at least in part, automatically and continuously. The consensus effort has also identified a second set of five controls that are essential but that do not appear to be able to be monitored continuously or automatically with current technology and practices.”

However, FISMA already provides for meaningful security controls, Ross said. Since the law’s passage, NIST has developed a library of standards, specifications and guidance for not only complying with FISMA but standardizing and improving security.

“There continues to be a notion that FISMA is all about paperwork and compliance,” he said. “FISMA is about trying to improve the quality of information security. SP 800-53 is all about specific controls with detailed guidance.”

Ross said NIST has no formal relationship with the CAG initiative, but that it did an informal review of the guidelines. “Our main interest was to see how it compared with 800-53,” Ross said. “We have done a cursory mapping” between the two.

Although he is wary of agencies focusing too narrowly in implementing security controls, Ross said CAG could be a valuable resource. “We appreciate the contribution this group is making,” he said. “We’re going to be looking to see if anything that comes out of this we can benefit from. We’re looking for any possible way to improve what we’ve done.”

Among the changes in SP 800-53 are a new family of program management controls on issues that do not apply to specific information systems, but which an agency should consider in areas such as capital planning and budget, risk management and the Federal Enterprise Architecture. This allows the recommendations to cover the entire spectrum of managing information systems, from the systems level to operations to the enterprise.

Privacy-related material, originally scheduled to be included in this revision of SP 800-53, will undergo a separate public review process in the near future and be incorporated into the publication, when completed.

CAG is seeking comments on its guidelines, which should be sent to cag@sans.org by March 25.

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