Control Origination Demystified

Control Origination can be confusing. Get it wrong and your System Security Plan (SSP) control definitions will not be attestable or certifiable.

Control Origination can be confusing. Get it wrong and your System Security Plan (SSP) control definitions will not be certifiable. This series of illustrations an explanation to guide you through Control Origination requirements present in all NIST and FISMA assessments such as FedRAMP, CMMC, 800-53, HIPAA, CJIS, DFARS, 800-171 and others.

All controls originate from a system or from a business process. It is important to describe where the control originates from so that it is clear whose responsibility it is to implement, manage and monitor the control. In some cases, the responsibility is shared by a CSP and by the customer. Use the definitions in the illustrations below to indicate where each security control originates from.

Throughout the SSP, policies and procedures must be explicitly referenced (title and date or version) so that it is clear which document is being referred to. Section numbers or similar mechanisms should allow the reviewer to easily find the reference.

For SaaS and PaaS systems that are inheriting controls from an IaaS (or anything lower in the stack), the “inherited” option in the SSP must be selected, and the implementation description must simply say “inherited.” Authorized reviewers will determine whether the control-set is appropriate or not.

The NIST term "organization defined" must be interpreted as being the CSP's responsibility, unless otherwise indicated. In some cases the JAB has chosen to define or provide, in others they have left the decision up to the CSP.

The official Control Origination classifications are:

  • Service Provider Corporate
  • Service Provider System Specific
  • Service Provider Hybrid (Corporate and System Specific)
  • Configured by Customer (Customer System Specific)
  • Provided by Customer (Customer System Specific)
  • Shared (Service Provider and Customer Responsibility)
  • Inherited from pre-existing FedRAMP Authorization
Control Origination can be confusing. Get it wrong and your System Security Plan (SSP) control definitions will not be attestable or certifiable.
FedRAMP Control Origination Service Provider Corporate
FedRAMP Control Origination Service Provider System Specific
FedRAMP Control Origination Service Provider Hybrid Corporate and System Specific
FedRAMP Control Origination Configured by Customer Customer System Specific
FedRAMP Control Origination Provided by Customer Customer System Specific
FedRAMP Control Origination Shared Service Provider and Customer Responsibility
FedRAMP Control Origination Inherited from pre-existing FedRAMP Authorization

HHS Publishes Healthcare Cyber Security Guidelines Based on NIST CSF

HHS Publishes Healthcare Cyber Security Guidelines Based on NIST CSF

New HHS publication outlines top cyber threats & best practices for healthcare industry

Noting that cyber security is “the responsibility of every health care professional, from data entry specialists to physicians to board members,” the U.S. Department of Health and Human Services (HHS) has published Health Industry Cybersecurity Practices: Managing Threats and Protecting Patients (HICP). The four-volume publication, which was mandated by the Cybersecurity Act of 2015, is aimed at hospital executives and cyber security professionals in healthcare organizations of all sizes and leverages the NIST Cybersecurity Framework.

HHS Publishes Healthcare Cyber Security Guidelines Based on NIST CSF

HHS: Email phishing & ransomware among top cyber threats to healthcare organizations

The HHS guide focuses on what the agency considers to be the current top cyber security threats to the healthcare industry: email phishing; ransomware; loss or theft of hardware; insider, accidental, or intentional data loss; and attacks against smart medical devices that put patient safety at risk. The publication’s two Technical Volumes outline 10 best practice areas to mitigate cyber security threats:

  • Email protection systems
  • Endpoint protection systems
  • Access management
  • Data protection and loss prevention
  • Asset management
  • Network management
  • Vulnerability management
  • Incident response
  • Medical device security
  • Cybersecurity policies

Rather than introducing a new framework, HHS instead maps its best practice and sub practice recommendations to those in the NIST CSF. Recognizing the fundamental differences and concerns that organizations of different sizes encounter, separate recommendations are given for small, medium, and large organizations.

The financial impact of healthcare breaches can be devastating, especially to small organizations. The HHS points out that the healthcare industry has the highest data breach cost of any industry, at an average of $408 per record and $2.2 million per organization. In 2016, the healthcare industry as a whole lost $6.2 billion to data breaches.

HHS urges proactive healthcare cyber security, comparing cyber hygiene to hand-washing

Healthcare cyber security has been a vexing issue for quite some time, and many issues stem from a lack of employee cyber security training. Unlike many industries, which made the switch from paper and typewriters to digital files and computers over a period of years, the healthcare industry digitized practically overnight. Employee training on cyber security best practices is notoriously spotty; healthcare organizations tend to focus on HIPAA compliance, with cyber security awareness an afterthought at best. The HHS notes that healthcare facilities often “deploy technologies without cybersecurity safeguards or use them (intentionally or unintentionally) without proper protections” and points out that four out of five U.S. physicians have experienced some form of cyber attack.

Employee buy-in presents another problem. Many front-line healthcare workers feel that their only job is to care for patients and that cyber security is the IT department’s problem. The HHS publication points out that in modern healthcare, cyber security is a function of patient care. Cyber attacks on electronic health records systems and smart medical devices don’t just disrupt business operations; they put patients’ health and even lives at risk. As such, the HHS states, healthcare workers must be taught to see cyber security hygiene the way they are taught to see hand hygiene; just as they wash their hands to prevent the spread of infections, they need to practice cyber hygiene to protect electronic patient records, IoT devices, and other healthcare systems from malware infections and other cyber attacks.

The cyber security experts at Lazarus Alliance have deep knowledge of the cyber security field, are continually monitoring the latest information security threats, and are committed to protecting organizations of all sizes from security breaches. Our full-service risk assessment services and Continuum GRC RegTech software will help protect your organization from data breaches, ransomware attacks, and other cyber threats.

Lazarus Alliance is proactive cyber security®. Call 1-888-896-7580 to discuss your organization’s cyber security needs and find out how we can help your organization adhere to cyber security regulations, maintain compliance, and secure your systems.

Why your cloud business needs FedRAMP certification

Now more than ever, FedRAMP certification will put your cloud services or SaaS solution head and shoulders above the competition.

Now more than ever, FedRAMP certification will put your cloud services or SaaS solution head and shoulders above the competition.

The Federal Risk and Authorization Management Program, or FedRAMP, was designed to support the federal government’s “cloud-first” initiative by making it easier for federal agencies to contract with vendors that provide SaaS solutions and other cloud services. Unlike FISMA, which requires service providers to seek an Authority to Operate (ATO) from each individual agency they want to do business with, a FedRAMP ATO qualifies a provider to work with any federal agency.

Cloud service providers aren’t required to comply with FedRAMP unless they work with the U.S. federal government. However, FedRAMP certification is a sound investment for all SaaS and cloud services providers, even if they are not currently federal contractors.

FedRAMP will make your company stand out in an increasingly crowded marketplace and reduce your company’s risk exposure

Cloud services and SaaS solutions have exploded in popularity. Everyone is racing to get their piece of the cloud market, and it can be challenging for your solution to stand out, especially if you run a small or mid-sized company. At the same time, consumer anger over data breaches has reached a boiling point, and enterprises are highly concerned about cyber risks, especially risks posed by third-party cloud services and SaaS providers.

Private-sector companies view FedRAMP as a gold standard of data security because they know how companies must meet exacting requirements to obtain it. The FedRAMP certification process will uncover your risks and vulnerabilities, providing a solid foundation for risk assessment, documentation review, and consistent use of internal security protocols that will benefit both your company and your customers.

Completing the FedRAMP certification process will make complying with other standards easier

FedRAMP controls are based on NIST 800-53, which is the basis for other common security regulations and industry standards that your company may have to comply with, including HIPAA, DFARS, PCI DSS, COBIT, ISO 27001, and CJIS.

FedRAMP certification will make it easier for you to sell services to federal contractors

Depending on the services provided, companies that are subcontractors to federal contractors don’t necessarily need to be FedRAMP compliant, but a FedRAMP certification will make your business stand out in this type of scenario as well, especially in this threat environment. The military and other federal government agencies are under attack from nation-state cyber criminals, and in many cases, these hackers target federal contractors and subcontractors. Chinese hackers have already breached U.S. Navy contractors on multiple occasions.

You’ll also have the option of selling services directly to federal government agencies

Federal contracting is stable and lucrative. The U.S. government is the single largest buyer of goods and services in the world, and federal agencies are reliable, steady customers even during economic downturns, when private-sector firms cut back. It’s a particularly attractive market for SaaS developers and other cloud services providers because federal agencies are mandated to be “cloud-first.” A White House directive requires them to evaluate cloud options “before making any new investments.”

Cloud service providers that are FedRAMP certified are listed in the FedRAMP marketplace, so that federal agencies can easily find them when they are looking to buy services.

Become FedRAMP certified at a price you can afford

Enterprises cannot self-certify. FedRAMP certification must be performed by a certified third-party assessment organization (3PAO) such as Lazarus Alliance.

According to FedRAMP.gov, the total median cost for a mid-range cloud services provider to attain a FedRAMP certification is $2,250,000. About half of this is for engineering costs, with the other half spent on the process itself. Additionally, providers can expect to spend about $1,000,000 a year on continuous monitoring to maintain an acceptable risk posture.

Lazarus Alliance understands that these costs are out of reach for most small and medium-sized providers, and we think that’s a shame. Our industry-leading FedRAMP 3PAO services will enable you to expand your business into government markets at a price you can afford. We work smarter, not harder, to drive down your costs by giving you access to Continuum GRC’s proprietary IT Audit Machine (ITAM), the number-one ranked FedRAMP-ready SaaS GRC audit software solution. ITAM utilizes pre-loaded, drag-and-drop modules to simplify and accelerate the FedRAMP certification process. Some of our clients have saved up to 1,000% over traditional FedRAMP assessment methods.

The cyber security experts at Lazarus Alliance have deep knowledge of the cyber security field, are continually monitoring the latest information security threats, and are committed to protecting organizations of all sizes from security breaches. Our full-service risk assessment services and Continuum GRC RegTech software will help protect your organization from data breaches, ransomware attacks, and other cyber threats.

Lazarus Alliance is proactive cyber security®. Call 1-888-896-7580 to discuss your organization’s cyber security needs and find out how we can help your organization adhere to cyber security regulations, maintain compliance, and secure your systems.