The Federal Information Security Management Act (FISMA) as represented in the report by the CSIS Commission on Cyber Security for the 44th Presidency, was noted as needing an overhaul; however the report only considered a limited scope in evaluating the purpose and role FISMA plays in securing federal government information systems.  Notwithstanding the discussion of making progressive updates to FISMA, in fairness with the intent of FISMA, the report fails to present many of the improvements already made as a result to the initial implementation of FISMA.  A key point this section of the report focuses on is integrating performance-based measures of security into FISMA.  However this ideal concept of a performance-based system only expands upon the current scorecard approach that seemingly puts agencies into a false sense of security if they achieve a higher score.  Performance as a measure for security only causes an undue burden on agencies to try to improve a scores (or a performance metric), rather than improve security as a function of the operational environment that must have a directly relationship with mission assurance.

The report does indicate an active role of the government in conducting cyber assessments to assess the cyber infrastructure, but again the report does not consider the larger picture of security.  The importance in external entities evaluating agency policies and procedures demonstrate the weaknesses in the organization structure for effectively delivering a mature security program.  How the agency integrates security into budgetary decision-making process is key to ensure security is adequately funded (with directly relationship in the financial reports to security costs).  Additionally, it is important to ensure agencies do not places security into the IT organization which must work extra hard at demonstrating to the business-side the value security provides as a cost-savings, rather than a necessary component of protecting the overall mission.

The report lacked significant substance regarding any currently ongoing activities to revamp the Federal Information Security Management Act by the amendment of the original law through the adoption (in whole or part), the Federal Information Security Management Act of 2008 (S.3474) that recently received approval by the Senate Homeland Security and Governmental Affairs.  The bill in its current state takes some aggressive steps to achieve a more proactive role by the federal agencies to demonstrate their security posture to Congress, hopefully giving the American's public more confidence in the security of the federal government.

Some points really not emphasized in the report that would improve the discussion of FISMA as part of the overall advice to “Modernize authorities”, should have considered organizational improvement in information security.  FISMA it a good framework, however it lacks in necessary authorities and should emphasize the realistic nature of the operations of the federal government (a diverse and decentralized infrastructure) and the challenges for implementing government policy, that do not provide flexibility to the mission constraints.  The report should have added substance that reflects the role security plays in the overall strategy presented by the executive leadership.  Agencies should adopt leadership roles that place information security at the executive level with a decision-making authority that enables security to be part of the business, rather than represented as a “compliance arm” or “cyber cop” of the organization.





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