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UNCLASSIFIED<br />

performance. For example, the <strong>Information</strong> System <strong>Security</strong> Officers (ISSO) have not<br />

established and implemented a reporting process to verify that the responsible groups have<br />

implemented the security configuration patches and s<strong>of</strong>tware updates identified by DS and IRM.<br />

Although system owners are responsible for the systems’ operations and compliance, DS and<br />

IRM did not establish reporting procedures to obtain, between each other, assurance that patches<br />

were actually installed. To correct these weaknesses, IRM/OPS/ENM is implementing the endto-end<br />

CM initiative, which includes a standard operating environment to support development<br />

<strong>of</strong> effective CM plans for the computing environments commonly used throughout the<br />

<strong>Department</strong>.<br />

Without effective configuration management controls, the <strong>Department</strong> increases the risks<br />

that <strong>Department</strong>-sensitive data, systems, and hardware may be exposed to loss <strong>of</strong> integrity and<br />

confidentiality. Additionally, the <strong>Department</strong> increases the risks that known security weaknesses<br />

will be exploited by individuals to perform unauthorized activities. The <strong>Department</strong>’s<br />

decentralized patch management and CM processes and procedures do not ensure that all system<br />

and operating system security residing on the network will be properly patched to reduce the<br />

security exposure to other <strong>Department</strong> bureaus and system owners in a timely manner.<br />

Recommendation 4. We recommend that the Chief <strong>Information</strong> Officer expedite the<br />

<strong>Information</strong> Resource Management, Operations, Enterprise Network Management and<br />

Diplomatic <strong>Security</strong>, <strong>Security</strong> Infrastructure, Office <strong>of</strong> Computer <strong>Security</strong> process to<br />

finalize and implement the elements within the Cyber <strong>Security</strong> Architecture draft target<br />

architecture and initiatives for end-to–end configuration management and take immediate<br />

action to correct or mitigate the high risk vulnerabilities identified by the vulnerability<br />

scanning as required by the Foreign Affairs Manual and Diplomatic <strong>Security</strong> System<br />

Configuration Policy and Procedures.<br />

Management Response: The <strong>Department</strong> stated the following:<br />

In general, the OIG is using a criterion focused upon completeness, and<br />

overlooking timeliness. This is a “compliance-based” approach not consistent<br />

with FY2011 FISMA reporting instructions that require both the <strong>Department</strong><br />

and OIG to assess risk and make judgments <strong>of</strong> how to best achieve security.<br />

More specifically, the OIG asserts the <strong>Department</strong> is not checking 100% <strong>of</strong><br />

configuration settings within the “required” three-year timeframe. Utilizing a<br />

risk-based approach, the <strong>Department</strong> is applying the analysis conducted by<br />

MIT Lincoln Labs examining the trade<strong>of</strong>f between completeness and<br />

timeliness <strong>of</strong> testing. This study shows the following two conditions have<br />

approximately equal risk [Chart in <strong>Department</strong> response: “100% completeness<br />

every year =17% completeness every two months”].<br />

Because the <strong>Department</strong> checks nearly 90% <strong>of</strong> configuration settings every<br />

three days, the <strong>Department</strong>’s risk is significantly lower than the traditional<br />

C&A requirement (100% completeness every three years). In this case,<br />

evidence shows timeliness trumps completeness in lowering risk.<br />

12<br />

UNCLASSIFIED

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