Review of Medicare Contractor Information Security Program Evaluations for Fiscal Year 2007

The Medicare Prescription Drug, Improvement, and Modernization Act of 2003 requires that each Medicare contractor must have its information security program evaluated annually by an independent entity. To comply with this provision, CMS contracted with PricewaterhouseCoopers to evaluate information security programs at the Medicare administrative contractors, fiscal intermediaries, and carriers. CMS also contracted with JANUS Associates, Inc. (JANUS), to perform technical assessments at Medicare data centers.

PricewaterhouseCoopers' reviews of the Medicare contractor information security program evaluations were adequate in scope and sufficiency. We could not determine the extent and sufficiency of the JANUS work for the data center technical assessments because of several issues with its working papers.

We recommended that CMS review all contractor documentation related to future data center technical assessments and ensure that the work performed complies with CMS contractual requirements. At a minimum, this should include a review of test plans to ensure that the contractor has completed all required testing procedures and a review of contractor working papers to verify that reported gaps have been adequately supported, identified, and included in the technical assessment reports. We also recommended that CMS test security control areas in which a considerable number of gaps have consistently been identified in the past 2 fiscal years at all CMS Medicare data centers every year. CMS concurred with our recommendations.