I am more than willing to stand corrected, although I believe that is not
completely accurate.  NIST and the Federal CIO Council developed the
framework for risk assessment and several (valuable) questionnaires
and other resources for federal agencies to evaluate and address
ecurity risk.  CMS developed numerous documents and templates based
on this framework for its own use in evaluating, certifying, and
accrediting federal information systems.  So the NIST documents
articulate the conceptual framework and provide some sample forms and
questionnaires to assist in the process, but CMS actually wrote (at least
they claim they wrote them!) their own RA Template, SSP Template,
methodology guides, etc. based on the NIST documentation.

I am not sure what you were getting at re: these documents relating
largely to unclassified systems (which I don't think is wholly accurate -
CMS uses them for its own systems, many of which carry a Secret
classification).  Is your point that, given they are targeted at unclassified
systems, they would not be adequate or appropriate for basing a CE's
RA methodology on?

In any case, whether you employ (through adaptation and modification)
the actual NIST sample documents, or the CMS templates, you are
working within exactly the conceptual framework.  The CMS templates
follow precisely the same outline presented in the NIST documentation.  I,
like William, highly recommend reviewing the two NIST documents he
references below, along with 800-37 - Draft Guidelines for the Security
Certification and Accreditation (C&A) of Federal Information Technology
Systems and 800-18 - Guide to Developing Security Plans for Information
Technology Systems.

Again, hope this helps.

Andrew S. McLetchie
Information Security Analyst
Sparrow Health System
Lansing, MI

>>> <[EMAIL PROTECTED]> 07/25/03 09:51am >>>
These were developed by NIST and the CIO IT Council....not CMS and
apply generally to unclassified federal information systems.   See NIST
800-30 and 800-26 along with their automated risk assessment
software, ASSET.  These excellent tools can easily be modified to cover
various security criteria including HIPAA and the process can (and
should) be slimmed down for smaller private organizations.

Bill Dobson, CISSP
TrustWave Corporation

-----Original Message-----
From: Andrew McLetchie [mailto:[EMAIL PROTECTED]
Sent: Friday, July 25, 2003 9:17 AM
To: WEDI SNIP Security Workgroup List
Subject: Risk Analysis Template -Reply


Chris,

Check out the following URL:

http://cms.hhs.gov/it/security/References/ps.asp#isp

CMS has developed an excellent set of templates for risk analysis,
threat/vulnerability identification, system security planning and more. 
These are the methods and documents that CMS uses within its own
organization for performing risk analyses and developing security plans. 
This page also has templates for certification (now evaluation) and
accreditation of systems.  We are using these documents (with some
pretty significant rework) as the foundation for our risk assessment
program.  You gotta figure that if the Security Rule enforcement body is
using these, they will be more than sufficient (if implemented consistently
with a sound methodology) to demonstrate that our organization has
taken all reasonable steps to comply.  Hope this helps!

Andrew S. McLetchie, CISSP
Information Security Analyst
Sparrow Health System
Lansing, MI

>>> Chris McLean <[EMAIL PROTECTED]> 07/25/03 08:20am
>>>
Hello all,
  Does anyone know where I can get a decent Risk Analysis Template
for the
HIPAA guidelines? or something that would be along those lines and
wouldn't
need too much tweaking. I know I'm not asking for much :)  But thought
you
all may be able to help me out.  Thanks, in advance!

Chris McLean
Network Coordinator
Greystone Health Care Management
813-635-9500
[EMAIL PROTECTED]



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