Open Recommendations

We recommend that the HHS OCIO work with the OPDIVs to: Implement the enterprise-wide configuration management plan, working with system owners to align system configuration management plans with the enterprise plan.

We recommend that the HHS OCIO work with the ODPIVs ensure that: A process be designed and implemented that ensures the collection and maintenance of artifacts evidencing the successful completion of annual RBT for all users with significant security responsibilities.

We recommend that the HHS OCIO work with the OPDIVs to ensure that all ODPIVs: Create and implement a process to require privileged users to sign a privileged user rules of behavior agreement for all systems prior to provisioning privileged access to those systems.

We recommend that the HHS OCIO: Work with the OPDIVs to ensure that all PIAs are reviewed, approved and signed by the appropriate HHS personnel at a minimum within three (3) years of the last PIA approval date.

HHS should continue to provide department-wide guidance and DHS-supplied Continuous Diagnostics and Mitigation (CDM) tools to each OPDIV for the implementation of their ISCM programs.

We recommend that the HHS OCIO work with the ODPIVs ensure that: OPDIVs’ security management improve their processes to consistently and accurately track training to ensure that everyone has taken the training prior to granting them system access. Obtain and retain training certificates as evidence of completed training.

We recommend that the HHS OCIO work with the OPDIVs to: - Review the monthly reconciliation report, currently provided by the HHS OCIO, to ensure that discrepancies on the POA&M exception report are corrected to enable accurate OPDIV and Department-level reporting.

HHS should commit to creating and implementing a Cybersecurity Maturity Migration Strategy to advance the cybersecurity program from its current maturity state to an effective state across HHS. This strategy should include the following: - Perform a risk assessment and identify the optimal maturity level that achieves cost-effective security based on your missions and risks faced, risk appetite, and risk tolerance level. - Identify gaps between the current state at each OPDIV and the criteria required to reach the optimal level across HHS’ enterprise-wide cybersecurity program and develop security controls to implement effective security. - Ensure the requirements for all…

We recommend that the HHS OCIO work with the OPDIVs to ensure that all ODPIVs: Establish a repository to retain signed copies of privileged user rules of behavior agreements for holders of privileged access for all systems.

We recommend that OPM evaluate any study conducted pursuant to Recommendation 1 and, with due diligence, formulate recommendations and a plan for agency action based on the best interests of the government, the FEHBP, and its enrollees.

Improve and continue to implement ongoing risk communication efforts by promptly providing residents in all communities near the 25 ethylene oxide-emitting facilities identified as high-priority by the EPA with a forum for an interactive exchange of information with the EPA or the statesregarding health concerns related to exposure to ethylene oxide.

Using the results of recommendations one (1) and two (2) :a. Implement an automated solution to help maintain an up-to-date, complete, accurate, and readily available Agency-wide view of the security configurations for all its GSS components; Cybersecurity Team exports metrics and vulnerability reports and sends them to the CISO and CIO’s Office monthly for review. Develop a centralized dashboard that Cybersecurity Team and the CISO can populate for real-time assessments of compliance and security policies.b. Collaborate with DNFSB Cybersecurity Team Support to establish performance metrics in service level agreements to measure, report on, and monitor the risks related to contractor…

Management should re-enforce requirements for performing DNFSBs change control procedures in accordance with the agency’s Configuration Management Plan by defining consequences for not following these procedures and conducting remedial training as necessary.

Based on the results of DNFSB’s supply chain risk assessment included in the recommendation for the Identify function above, update DNFSB’s contingency planning policies and procedures to address ICT supply chain risk.

NIH should update its training materials routinely to include informationabout breaches of peer reviewer confidentiality and possibleundue foreign influence.

NIH should require all peer reviewers to attend periodic trainings aboutpeer review integrity.

NIH should conduct targeted, risk-based oversight of peer reviewers using analysis of information about threats to research integrity.

NIH should consult with Federal law enforcement and national securityexperts to determine what additional steps it might take toidentify and address potential risks to the confidentiality of thepeer review process, including possible undue foreign influence.

Ensure future process changes are implemented according to change management best practices noted by GAO.

The Office ofInformation Technology (OIT), in partnership with OFP and OFO, should re-evaluate IMS requirements, and requirementsfor the framework of its successor system, to determine what additional reporting functionalities are needed in order to analyze data about staff and office productivity. A Voice of the Customer exercise or a user requirement meeting could serve as starting point to gather current requirements from IMS main users (OFP and OFO) and to determine what other current systems need to be integrated to make them function in alignment with IMS (Power BI, Complainant Portal).

OIT developers should meet directly with software users, such as OFO attorneys and supervisory attorneys and OFP AJs and Supervisory AJs(SAJ)to determine additional requirements.

OFO and OFP, in partnership with OIT, should consider development of an IMS training guide or document that is consistently updated and reviewed following upgrades, enhancements or modifications of the software. This guide should include all necessary codes for every action item in the process and should be available for all product users. This guide should ensure that product users track all mandated steps in IMS. Given that each office’s staff has their own needs within IMS: One guide should be made for OFP legal techs, AJs, and SAJs. A separate guide should be available for OFO CCD staff, attorneys…

Assign a target amount of days for intake so that management can determine if changes implemented impact the efficiency of the process.

We recommend that the New York State Department of Health obtain and review the results of MCO site visits at adult day care facilities as part of its beneficiary health and safety monitoring activities.

We recommend that the New York State Department of Health ensure that MCOs work with their contracted adult day care services providers to correct the 476 instances of noncompliance with health and safety requirements identified in this report.