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Review of the Department of Health and Human Services’ Compliance With the Federal Information Security Modernization Act of 2014 for Fiscal Year 2025

Issued on  | Posted on  | Report number: OAS-25-18-041

Why OIG Did This Audit

  • The Federal Information Security Modernization Act of 2014 (FISMA) requires Inspectors General to perform an annual independent evaluation of their agency’s information security programs and practices to determine the effectiveness of those programs and practices. OIG engaged Ernst & Young LLP (EY) to conduct this audit.
  • EY conducted a performance audit of HHS’s compliance with FISMA as of July 31, 2025, based upon the 2025 FISMA reporting metrics.
  • The audit examined whether HHS’s overall information security program and practices were effective as they relate to Federal information security requirements and included systems from five HHS divisions.

What OIG Found

For FY 2025, EY rated HHS’s information security program “Not Effective” for the sixth consecutive year. To be considered “Effective,” an agency must achieve at least a “Managed and Measurable” maturity level.

In FY 2025, HHS did not achieve a “Managed and Measurable” rating for either the Core or Supplemental Inspector General metrics in any of the six cybersecurity function areas: Govern, Identify, Protect, Detect, Respond, and Recover. Specifically, the overall maturity level for Core metrics was assessed as “Consistently Implemented,” while the Supplemental metrics were rated “Ad Hoc.” Together, these ratings fall below the “Managed and Measurable” level, resulting in an overall determination of “Not Effective.”

What OIG Recommends

Based on the audit, EY made ten recommendations to HHS to strengthen its information security program through improved oversight of the Operating and Staff Divisions’ (Divisions) implementation of Federal information security requirements for an effective FISMA program.

HHS concurred with seven recommendations and detailed steps it has taken and plans to take in response to the recommendations. HHS did not concur with three recommendations.

26-A-18-055.01 to OS - Open Unimplemented
Update expected on 09/23/2026
We recommend that HHS develop a formal process for creating and maintaining cybersecurity profiles (current and target), including developing policies and procedures and implementing these policies and procedures at the Department level and at the Division level.

26-A-18-055.02 to OS - Open Unimplemented
Update expected on 09/23/2026
We recommend that HHS implement the Cybersecurity Risk Management Strategy at the Department level and confirm implementation of the CRMS at the Division level. All Divisions should inherit the HHS Department enterprise-wide risk management strategy or develop and implement their own. Additionally, HHS should confirm that all risks, including those incurred during organizational restructuring, are documented, evaluated, and accounted for according to the CRMS.

26-A-18-055.03 to OS - Open Unimplemented
Update expected on 09/23/2026
We recommend that HHS require and ensure Divisions implement SCRM policy and procedures.

26-A-18-055.04 to OS - Open Unimplemented
Update expected on 09/23/2026
We recommend that HHS update the departmental policy to accurately define cybersecurity roles and responsibilities and define the processes to evaluate the performance of cybersecurity roles and responsibilities.

26-A-18-055.05 to OS - Open Unimplemented
Update expected on 09/23/2026
We recommend that HHS conduct the workforce skills assessment/gap analysis timely and periodically update the assessment/gap analysis to account for changes in the risk environment across HHS and the Divisions.

26-A-18-055.06 to OS - Open Unimplemented
Update expected on 09/23/2026
We recommend that HHS confirm that Divisions maintain comprehensive and accurate software and hardware asset and license inventories and employ the use of information system security continuous monitoring (ISCM) tools to monitor the security posture of assets in accordance with the defined standards across HHS. HHS should confirm that implementation of these inventories is consistent with established standards.

26-A-18-055.07 to OS - Open Unimplemented
Update expected on 09/23/2026
We recommend that HHS develop policies, procedures, and guidance for the creation and maintenance of data and metadata inventories. These policies, procedures, and guidance should be implemented throughout HHS. HHS should establish a process to monitor Divisions' adherence to department-level policies, procedures, and guidance.

26-A-18-055.08 to OS - Open Unimplemented
Update expected on 09/23/2026
We recommend that HHS require Divisions to implement common secure configurations and effective flaw remediation processes for all their systems according to Divisions standards or standards approved by HHS for the Division. Divisions should ensure that scanning for compliance and vulnerabilities is performed according to HHS policies and procedures and that all deviations and vulnerabilities are remediated within the defined timelines set by HHS. HHS should confirm that Divisions are meeting the established standards.

26-A-18-055.09 to OS - Open Unimplemented
Update expected on 09/23/2026
We recommend that HHS enforce HHS policies and procedures for provisioning and monitoring access of all privileged users and confirm implementation aligns with the policies and procedures. Privileged user access requests with the required approval should be documented and retained.

26-A-18-055.10 to OS - Open Unimplemented
Update expected on 09/23/2026
We recommend that HHS enforce policies and develop procedures for conducting and updating Business Impact Analyses (BIAs) and require implementation at the Department level and Division level. Divisions should implement as necessary and reference HHS policy as part of their contingency planning efforts to standardize the prioritization of business operations and functions.

View in Recommendation Tracker