What is the Risk Management Framework (RMF)?
The National Institute of Standards and Technology (NIST) created the RMF to provide a structured, flexible process to manage risk throughout a system’s life cycle. Using the RMF process helps CMS authorize and monitor our information systems and keep them safe.
The RMF is made up of 7 steps:
What is the Categorize step?
The purpose of the Categorize step is to inform organizational risk management processes and tasks by determining the adverse impact to organizational operations and assets, individuals, other organizations, and the Nation with respect to the loss of confidentiality, integrity, and availability of organizational systems and the information processed, stored, and transmitted by those systems
System level Categorize tasks
System level Categorize tasks also take into consideration mission/business process concerns
Task C-1: System description
The first step in the categorization process involves creating a comprehensive description of an information system, which is foundational for the security and privacy planning process. This description helps stakeholders understand the system's characteristics, operational context, and how it fits within the organization's technology ecosystem.
Potential Inputs:
- The System Design and Requirements Documentation provides detailed information about the system's architecture, functionalities, and intended use. It is crucial that these documents are up-to-date and accurately reflect both the current state of the system and its intended evolution. This documentation serves as the foundation for understanding how the system operates and its technical specifications
- The Authorization Boundary Information defines the scope of the system within the organization. It delineates what is included in the security accreditation and ensures that all relevant stakeholders have a clear understanding of the system's boundaries. This clarity helps prevent scope creep and ensures that critical components are not overlooked during the security assessment
- The List of Security and Privacy Requirements outlines the security and privacy expectations set by the organization, regulatory bodies, and other stakeholders. These requirements should be comprehensive, encompassing both organizational policies and applicable legal or regulatory standards. Ensuring that all security and privacy requirements are included is essential for the accurate categorization and protection of the system
- System Element Information provides details on the individual components that make up the system, including hardware, software, firmware, and network components. This information helps in understanding the technical makeup of the system and its operational context.
- The System Component Inventory is a detailed list of all components within the system. This includes hardware, software, and firmware versions and configurations. Maintaining an accurate inventory is vital for tracking changes, assessing vulnerabilities, and managing the system’s security posture.
- System Element Supply Chain Information includes details about the suppliers and the supply chain for system elements. This information is crucial for assessing supply chain risks and ensuring the integrity and security of the components used in the system.
- Security Categorization determines the system’s security impact level based on the sensitivity of the information processed, stored, and transmitted. This categorization helps prioritize security measures and allocate resources effectively.
- A Data Map of the Information Life Cycle illustrates the life cycle of information types processed, stored, and transmitted by the system. It includes data creation, modification, storage, transmission, and deletion stages. This mapping is essential for understanding data flows and implementing appropriate security controls throughout the data lifecycle.
- Information on System Use, Users, and Roles details how the system is used, who uses it, and their roles. This includes user access levels, user roles, and operational processes. Understanding this information helps in defining security measures tailored to the system’s usage patterns and user interactions.
Expected Outputs:
This output is a detailed description of the system, including all critical aspects that define its operation and security posture. The system description should include:
- System Characteristics: An overview of the system’s purpose, functionalities, and intended use. This section provides a high-level understanding of what the system is designed to achieve and its role within the organization.
- System Components: A breakdown of the individual components that make up the system. This includes hardware, software, firmware, and network elements. Detailed information about each component, including versions and configurations, is essential for tracking and managing the system’s security.
- Users and Roles: Information on who uses the system, their roles, and their access levels. Understanding the user base and their interactions with the system helps in defining appropriate security measures and access controls.
- Information Flow: A map of how information is processed, stored, and transmitted within the system. This includes data creation, modification, storage, transmission, and deletion stages. Visual representations, such as diagrams or flowcharts, can enhance clarity and understanding.
- Operational Context: The environment in which the system operates, including any dependencies on other systems or processes. This context helps in understanding potential risks and the system’s integration within the broader organizational framework.
Discussion:
The categorization step is crucial for understanding and documenting a system’s characteristics. The System Security and Privacy Plan (SSPP) provides an accurate and detailed description of the FISMA system, including its security requirements and controls. Managed within the CMS FISMA Continuous Tracking System (CFACTS), the SSPP is a living document that must be continually updated to reflect changes in the system's design, functionality, or operational context.
The process begins with collecting key inputs, such as system design and requirements documentation, authorization boundary information, and a list of security and privacy requirements. These inputs are crucial for creating a comprehensive system description, which captures the system’s characteristics, components, users, information flow, and operational context.
The final output of this process is a documented system description, which should be treated as a living document, continuously updated to reflect any changes in the system.
Several stakeholders play important roles in this task
- The System Owner is responsible for ensuring the system is accurately and comprehensively described
- The Authorizing Official provides oversight, ensuring that the system description aligns with organizational risk management strategies
- The Information Owner or Steward contributes details about the types of information processed by the system
- The System Security Officer and System Privacy Officer provide input on security and privacy considerations, identifying potential threats and controls
Effective documentation requires up-to-date system design documents that accurately reflect the system. Clear authorization boundaries must be defined and understood to prevent scope creep. Comprehensive security and privacy requirements, adhering to organizational policies and regulatory standards, are essential.
Enhancing the system description by incorporating visual representations such as diagrams or models can significantly improve understanding. Leveraging existing documentation from the Target Life Cycle (TLC) saves time and ensures consistency. Regular updates to the system description are crucial to maintain its accuracy and relevance.
Understanding the system’s dependencies on external systems or services is vital for comprehensive risk management. The system description should align with the organization’s business continuity and disaster recovery planning efforts
Documenting security and privacy by design principles, along with any cloud services or third-party components, ensures a robust and compliant system architecture.
Cybersecurity Framework: Profile
TLC Cycle Phase:
Task C-2: Security categorization
Categorize the system and document the security categorization results. Task C-2 involves assigning a security categorization to an information system based on the potential impact of a compromise in confidentiality, integrity, and availability (CIA) of the information processed, stored, and transmitted. This task is essential for defining the baseline security controls required for the system.
Potential Inputs:
- Risk Management Strategy & Organizational Risk Tolerance: Guides the overall approach to assessing and accepting risk levels
- Authorization Boundary Information: Outlines the system's scope within the organization, crucial for understanding the context of the security categorization
- Organizational and System-level Risk Assessment Results: Provides a detailed view of identified risks, informing the categorization process
- Information Types Processed, Stored, or Transmitted: Key to determining the potential impact levels for CIA
- List of Security and Privacy Requirements: Ensures that categorization aligns with identified requirements and controls
- Organizational authority or purpose for operating the system
- Business Impact Analyses or Criticality Analyses: Offers insight into the system's importance to the organization's mission and business function
- Information about missions, business functions, and mission/business
Expected Outputs:
- Documented Security Categorization: This includes impact levels for each information type and for each CIA security objective. The categorization is based on the highest (i.e., the "high-water mark") impact level among the information types.
Discussion: This Task involves assessing the potential impact of security breaches on CMS operations, assets, individuals, and national security. Utilizing frameworks such as FIPS 199 and 200 or CNSSI 1253, CMS categorizes systems based on the highest level of impact (the high-water mark concept) concerning confidentiality, integrity, and availability
Essential inputs include the risk management strategy, organizational risk tolerance, and results from organizational and system-level risk assessments.
As directed by guidelines in FISMA and using FIPS Pub 199 (PDF link) as additional guidance, CMS business systems and applications are each provided a security category of LOW, MODERATE, or HIGH. The CMS business owner makes this determination based upon the security risk of the application and its data relative to the security objectives of Confidentiality, Integrity, and Availability
ISSOs leverage CFACTS to complete their system categorization
To learn more about this process, please refer to this video on System Categorization.
Cybersecurity Framework: ID.AM-1; ID.AM-2; ID.AM-3; ID.AM-4; ID.AM-5; Profile
TLC Cycle Phase:
Task C-3: Security categorization review and approval
Review and approve the security categorization results and decision. Task C-3 ensures the results and decisions made during the Security Categorization process (Task C-2) are validated and formally approved. This step is crucial for ensuring the security categorization aligns with the organizational mission, business functions, and overall risk management strategy.
Potential Inputs:
- Impact Levels for Each Information Type and Security Objective: Results from Task C-2, indicating the potential impact on the organization if confidentiality, integrity, or availability were compromised
- Security Categorization Documentation: Includes the rationale for chosen impact levels and any supporting analyses or assessments
- List of High-Value Assets: To consider if the system contains or supports high-value assets, which may require enhanced security measures
- Organizational Authority or Purpose for Operating the System: Provides context for the system’s role within the organization and its significance
- The comprehensive documentation of security categorization decisions facilitates a smoother review process
- Understanding the system’s role and its importance in supporting high-value assets can influence the review and approval process
Expected Outputs:
- Approval of Security Categorization: Formal documentation signifying that the system's security categorization is appropriate and has been accepted by the relevant authority.
Discussion:
Every information system operated by or on behalf of the U.S. federal government is required to meet FISMA standards, which includes an Authorization to Operate (ATO) signed by an Authorizing Official (AO) or Authorizing Official Designated Representative. This means that before a system can be deployed into production at CMS, the Business Owner and other stakeholders must go through the process of testing and documenting the system’s security to demonstrate its compliance with federal requirements
All information regarding the ATO process and the different roles involved in the process can be found at the ATO page
The categorization results are scrutinized by the authorizing official (or a designated representative) and, for systems processing PII, the Senior Agency Official for Privacy. This review ensures that categorization aligns with CMS's mission, business functions, and overarching risk management strategy.
Cybersecurity Framework: Profile
TLC Cycle Phase:
Determine adverse impact to inform organizational risk management processes and tasks