Cms-10877 Interconnection Security Agreement

Supporting Statement for Direct Enrollment Entities (CMS-10877)

CMS-10877 - Appendix_Q_CMS-EDE-ISA-Template

DE Entity Operational Readiness Review (ORR)

OMB: 0938-1463

⚠️ Notice: This form may be outdated. More recent filings and information on OMB 0938-1463 can be found here:

2024-04-22 - New collection (Request for a new OMB Control Number)

Document [pdf]

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OMB Control #: 0938-NEW
Expiration Date: XX/XX/20XX

CMS SENSITIVE INFORMATION – REQUIRES SPECIAL HANDLING

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INTERCONNECTION SECURITY AGREEMENT (ISA)
BETWEEN
CENTERS FOR MEDICARE & MEDICAID SERVICES (CMS)
AND
ENHANCED DIRECT ENROLLMENT (EDE) ENTITY

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PRA DISCLOSURE: According to the Paperwork Reduction Act of 1995, no persons are required to respond to a collection of information unless
it displays a valid OMB control number. The valid OMB control number for this information collection is 0938-NEW, expiration date is XX/
XX/20XX. The time required to complete this information collection is estimated to take up to 144,652 hours annually for all direct enrollment
entities. If you have comments concerning the accuracy of the time estimate(s) or suggestions for improving this form, please write to: CMS,
7500 Security Boulevard, Attn: PRA Reports Clearance Officer, Mail Stop C4-26-05, Baltimore, Maryland 21244-1850. ****CMS Disclosure****
Please do not send applications, claims, payments, medical records or any documents containing sensitive information to the PRA Reports
Clearance Office. Please note that any correspondence not pertaining to the information collection burden approved under the associated OMB
control number listed on this form will not be reviewed, forwarded, or retained. If you have questions or concerns regarding where to submit
your documents, please contact Brittany Cain at [email protected].

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Table of Contents
1. Introduction ................................................................................................................... 1
2. CMS Background .......................................................................................................... 2
2.1
2.2
2.3

CMS .................................................................................................................................2
CMS Information Security Program ................................................................................2
CMS Roles and Responsibilities ......................................................................................2
2.3.1 CMS Chief Information Officer (CIO) .................................................................2
2.3.2 CMS Chief Information Security Officer (CISO) ................................................2
2.3.3 CMS Senior Official for Privacy (SOP) ...............................................................2
2.3.4 CMS Information System Security Officer (ISSO) ..............................................2
2.3.5 Center for Consumer Information and Insurance Oversight (CCIIO) ..................3
2.3.6 CMS Cyber Integration Center (CCIC) ................................................................3

3. Non-CMS Organization Background ......................................................................... 3
3.1
3.2
3.3

Non-CMS Organization ...................................................................................................3
IT Security Program .........................................................................................................3
Roles and Responsibilities ...............................................................................................3
3.3.1 ..................................................................................................................4
3.3.2 ..................................................................................................................4
3.3.3 ..................................................................................................................4
3.3.4 ..................................................................................................................4
3.3.5 ..................................................................................................................4

4. Scope ............................................................................................................................... 4
5. Authority ........................................................................................................................ 5
6. Statement of Requirements .......................................................................................... 5
6.1
6.2
6.3

General Information/Data Description .............................................................................6
6.1.1 CMS Hub Description ..........................................................................................6
6.1.2 Non-CMS Organization System Description .......................................................7
Services Offered ...............................................................................................................7
Security and Privacy Controls ..........................................................................................7

7. Request to Connect........................................................................................................ 8
7.1

Required Documents ........................................................................................................8

8. Security Responsibilities ............................................................................................... 8
8.1
8.2

Communication / Information Security Points of Contact ...............................................9
Responsible Parties ..........................................................................................................9

9. Personnel / User Security.............................................................................................. 9
9.1

User Community ..............................................................................................................9

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9.2
9.3
9.4

Commitment to Protect Sensitive Information...............................................................10
Training and Awareness .................................................................................................10
Personnel Changes / De-Registration .............................................................................11

10. Policies .......................................................................................................................... 11
10.1 Rules of Behavior ...........................................................................................................11
10.2 Security Documentation .................................................................................................11

11. Network Security ......................................................................................................... 12
11.1
11.2
11.3
11.4
11.5
11.6

Network Management ....................................................................................................12
Material Network Changes.............................................................................................12
New Interconnections.....................................................................................................12
Network Inventory .........................................................................................................13
Firewall Management .....................................................................................................13
Penetration Test ..............................................................................................................13

12. Incident Prevention, Detection, and Response ......................................................... 14
12.1 Incident Handling ...........................................................................................................14
12.2 Intrusion Detection .........................................................................................................15
12.3 Disasters and Other Contingencies.................................................................................15

13. Notice ............................................................................................................................ 15
14. Modifications ............................................................................................................... 16
15. Compliance................................................................................................................... 16
16. Termination.................................................................................................................. 16
17. Cost Considerations .................................................................................................... 16
18. Timeline ........................................................................................................................ 17
19. Order of Precedence.................................................................................................... 17
20. Confidentiality ............................................................................................................. 17
21. Survival......................................................................................................................... 17
22. Records ......................................................................................................................... 18
23. Assignment and Severability ...................................................................................... 18
24. Warranty ...................................................................................................................... 18
25. Limitation of Liability................................................................................................. 18
26. Force Majeure.............................................................................................................. 19
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27. Signatures ..................................................................................................................... 20
Appendix A. Responsible Parties .................................................................................... 23
A.1 Authorizing Official .......................................................................................................23
A.2 Other Designated Contacts .............................................................................................23
A.3 Assignment of Security and Privacy Responsibility ......................................................24

Appendix B. Primary EDE Entities Connection and Data Sharing with Upstream
EDE Entities ................................................................................................................. 26
B.1
B.2
B.3
B.4

Upstream EDE Entities Overview..................................................................................26
Data Connections ...........................................................................................................27
Additional Functionality or Systems ..............................................................................29
Data Flow/Topological Diagram ....................................................................................32

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List of Figures
Figure 1: EDE Data Flow Diagram ................................................................................................ 6
Figure 2. Data Flow/Topological Diagram ................................................................................... 32

List of Tables
Table 1. System Authorizing Official ........................................................................................... 23
Table 2. Information System Management Point of Contact ....................................................... 24
Table 3. Information System Technical Point of Contact............................................................. 24
Table 4. EDE Entity Name Internal ISSO (or Equivalent) Point of Contact................................ 24
Table 5. EDE Entity Internal Official for Privacy (or Equivalent) Point of Contact.................... 25
Table 6. CMS ISSO Point of Contact ........................................................................................... 25
Table 7. Upstream EDE Entity Overview..................................................................................... 26
Table 8. Interconnections and Data Exchange Between EDE Environment Provider and
Upstream Entities .......................................................................................................................... 28
Table 9. Additional Functionality or Systems .............................................................................. 31

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The following CMS and ISA Review Log is maintained
to record the annual reviews.

Record of Changes
Version

Date

Author / Owner

Description of Change

CR #

CR: Change Request

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1. Introduction
The purpose of this Interconnection Security Agreement (ISA) is to establish procedures for
mutual cooperation and coordination between the Centers for Medicare & Medicaid Services
(CMS) and the Enhanced Direct Enrollment (EDE) Entity, 1 (hereafter referenced as the “Non-CMS Organization”), regarding the development,
management, operation, and security of a connection between CMS’s Data Service Hub (Hub)
(hereafter known as the CMS Network) and the Non-CMS Organization’s network. This ISA is
intended to minimize security risks and ensure the confidentiality, integrity, and availability
(CIA) of CMS information 2 as well as the information that is owned by the external organization
that has a network interconnection 3 with CMS. This ISA ensures the adequate security 4 of CMS
information being accessed and provides that all network access satisfies the mission
requirements of both CMS and the Non-CMS Organization (hereafter referenced as “both
parties”).
0F

Federal policy requires agencies to develop ISAs for federal information systems and networks
that share or exchange information with external information systems and networks. This ISA is
based on the National Institute of Standards and Technology (NIST) Special Publication (SP)
800-47, Rev. 1, Managing the Security of Information Exchanges, 5 and shall comply with the
security required by Federal Acquisition Regulation (FAR) clause 52.239-1, Privacy or Security
Safeguards. The guidelines establish information security (IS) measures that shall be taken to
protect the connected systems and networks and shared data. CMS Information Technology (IT)
managers and IS personnel shall comply with the NIST guidelines in managing the process of
interconnecting information systems and networks.
4F

This ISA documents interconnection arrangements and IS responsibilities for both parties,
outlines security safeguards, and provides the technical and operational security requirements.
This ISA also specifies business and legal requirements for the information systems and
networks being interconnected. This ISA authorizes mutual permission to connect both parties
and establishes a commitment to protect data that is exchanged between the networks or
processed and stored on systems that reside on the networks. Through this ISA, both parties shall
minimize the susceptibility of their connected systems and networks to IS risks and aid in
mitigation and recovery from IS incidents.

EDE Entities are considered Non-Exchange Entities (NEE) and, as such, are required to comply with the privacy
and security standards that are at least as protective as the standards the Exchange has established and
implemented for itself.
“Information” is defined as “any knowledge that can be communicated or documentary material, regardless of its
physical form or characteristics, that is owned by, produced by or for, or is under the control of the United States
Government.” (Executive Order 12958)
“Network interconnection” is defined as the primary “direct connection of two or more IT networks for the purpose
of sharing data and other information resources.” (This is based on the definition of system interconnection in
NIST SP 800-47, Security Guide for Interconnecting Information Technology Systems.)
“Adequate security” is defined as “a level of security that is commensurate with the risk and magnitude of the
harm resulting from the loss, misuse, or unauthorized access to or modification of the information.” (Office of
Management and Budget [OMB] Circular A-130)
Located at: https://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-47r1.pdf.

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2. CMS Background
2.1

CMS

As an Operating Division of the Department of Health and Human Services (HHS), CMS
administers Medicare, Medicaid, Children’s Health Insurance Program (CHIP), as well as
programs created under the Patient Protection and Affordable Care Act (PPACA) of 2010,
including the Health Insurance Exchange program. It is CMS’s mission to ensure effective, upto-date health care coverage and to promote quality care for beneficiaries.

2.2

CMS Information Security Program

The CMS IS Program helps CMS accomplish its mission by ensuring the CIA of CMS
information resources. The CMS IS Program has developed policies, standards, procedures, and
guidelines that ensure the adequate protection of agency information and comply with federal
laws and regulations. CMS monitors the security of its network twenty-four (24) hours a day,
seven (7) days a week (i.e., 24/7) through various management, operational, and technical
processes. Training initiatives are continuously updated to ensure that managers, users, and
technical personnel are aware that they are responsible for the adequate security of their
information systems.

2.3
2.3.1

CMS Roles and Responsibilities
CMS Chief Information Officer (CIO)

The CMS CIO is responsible for the overall implementation and administration of the CMS
Information Security and Privacy Program.

2.3.2

CMS Chief Information Security Officer (CISO)

The CMS CISO supports the CMS CIO in the implementation of the CMS Information Security
Program. The CMS CISO directs, coordinates, and evaluates CMS’s Information Security
policy. The CISO collaborates with the CMS Senior Official for Privacy to carry out Information
Security and Privacy responsibilities.

2.3.3

CMS Senior Official for Privacy (SOP)

The CMS SOP carries out the CIO’s privacy responsibilities under federal requirements in
conjunction with the CISO. The CMS SOP leads CMS privacy programs and promotes proper
information security and privacy practices and is responsible for the development and
implementation of privacy policies and procedures.

2.3.4

CMS Information System Security Officer (ISSO)

The CMS ISSO is the liaison for IS within their assigned area of responsibility. ISSOs
implement standard IS policies and collaborate across CMS concerning the CIA of information
resources. Although the ISSOs report directly to their own management, they have
responsibilities to the CMS CISO as part of their IS responsibilities, and therefore, to the CMS
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CIO. In their IS role, ISSOs take direction from the CMS CIO or the CMS CISO when action is
required to protect CMS assets from potential vulnerabilities and threats. The CMS CISO and
ISSOs will work with Non-CMS Organization to enhance IS measures.

2.3.5

Center for Consumer Information and Insurance Oversight (CCIIO)

The CCIIO, as the CMS Business Owner (BO), is responsible for the management and oversight
of CMS’s Health Insurance Exchange Hub system, which is the CMS information system that
requires the interconnection with the Non-CMS Organization. The BO serves as the primary
point of contact (POC) for the CMS information system.

2.3.6

CMS Cyber Integration Center (CCIC)

The CCIC monitors the security of the CMS information system 24/7 using the expertise of
Information Technology (IT) security professionals and automated IS processes. The CCIC
identifies IS incidents, characterizes the nature and severity of incidents, and provides immediate
diagnostic and corrective actions when appropriate. CCIC members are trained in investigating
IS events such as web defacements, computer compromises, and viruses. The CCIC continuously
enhances its IS auditing methods as well as incident handling procedures to respond to the
growing demands of IS.

3. Non-CMS Organization Background
3.1

Non-CMS Organization
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3.2

IT Security Program
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3.3

Roles and Responsibilities
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4. Scope
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“Bullet List Single Last,” respectively.

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indenture after the second, simply hit a second , as follows:
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The scope of this ISA is based on, but is not limited to, the following activities, users, and
components:
•

Interconnection between a CMS information system(s) and the Non-CMS Organization.

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•

Existing and future users, including employees from both parties, contractors, and
subcontractors at any tier; and other federally and non-federally funded users managing,
engineering, accessing, or utilizing the Non-CMS Organization Network.

•

Related network components belonging to both parties, such as hosts, routers, and
switches; IT devices that assist in managing security such as firewalls, intrusion detection
systems (IDS), and vulnerability scanning tools; desktop workstations; servers; and major
applications (MA) that are associated with the network connection between both parties. 6
5F

5. Authority
By connecting with the CMS network and CMS information system, Non-CMS Organization
agrees to be bound by this ISA and use the CMS Network and CMS information system(s) in
compliance with this ISA.
The authority for this ISA is based on, but not limited to, the following, if and to the extent
applicable:
•

Federal Information Security Modernization Act of 2014 (FISMA);

•

OMB Circular A-130, Appendix III, Security of Federal Automated Information Systems;

•

18 U.S.C. § 641 Criminal Code: Public Money, Property or Records;

•

18 U.S.C. § 1905 Criminal Code: Disclosure of Confidential Information;

•

Privacy Act of 1974, 5 U.S.C. § 552a;

•

Health Insurance Portability and Accountability Act (HIPAA) of 1996, P.L. 104-191;

•

45 C.F.R. § 155.260 Privacy and Security of Personally Identifiable Information;

•

45 C.F.R. § 155.280 Oversight and Monitoring of Privacy and Security Requirements;
and

•

Patient Protection and Affordable Care Act of 2010.

This ISA is also in compliance with HHS policies 7 and CMS policies listed at the CMS IS
webpage. 8
6F

6. Statement of Requirements
The expected benefit of the interconnection is .

7
8

A “major application” is an application that requires special attention to security due to the risk and magnitude of
the harm resulting from the loss, misuse, or unauthorized access to or modification of the information in the
application. (OMB A-130)
Located at: https://www.hhs.gov/about/agencies/asa/ocio/cybersecurity/index.html.
Located at: http://www.cms.gov/Research-Statistics-Data-and-Systems/CMS-InformationTechnology/InformationSecurity/.

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6.1
6.1.1

General Information/Data Description
CMS Hub Description

All communication with the Hub is facilitated via Web services over the Internet. The Hub
conveys information, using Transport Layer Security (TLS), version 1.2 for data encryption,
server authentication, and message integrity. It uses Public Key Infrastructure (PKI) to
authenticate connections. To protect the confidentiality of data transmitted from one system to
another system, messages are encrypted, using the Hypertext Transfer Protocol Secure (HTTPS)
protocol.
All Application Programming Interface (API) transactions provided by an EDE Entity will go
through the Hub for confirmation that the requesting EDE Entity is authorized by CMS. Upon
confirmation, the API request will be passed to the Federally-facilitated Exchange (FFE), at
which point the FFE will validate the API request. The groups of services depicted in Figure 1
enable the FFE to provide internal and external stakeholders with the following capabilities:
•

Marketplace Consumer Record (MCR) APIs: Enable the Exchange to provide
customer-related data and search capabilities.

•

Standalone Eligibility Service (SES) APIs: Enable the Exchange to determine the
customer’s eligibility for Qualified Health Plans (QHP) and /or Qualified Dental Plans
(QDP) and associated subsidies.

•

Issuer and Enrollment Services (IES) APIs: Enable the Exchange to provide data to
redirect consumers to the issuer payment portal.

•

Document Storage and Retrieval Service (DSRS) APIs: Enable the Exchange to
provide document upload and retrieval of Exchange-generated notices.

•

Eligibility and Enrollment (EE) APIs: Enable the Exchange to provide enrollment
generation capabilities.

Figure 1 is a high-level topological diagram illustrating the interconnectivity between the Hub
and EDE entity systems.

Figure 1: EDE Data Flow Diagram

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6.1.2

Non-CMS Organization System Description
Instruction: Insert high-level Non-CMS Organization description of the information and
data that will be made available, exchanged, or passed one-way only by the
interconnection of the two systems / networks. Non-CMS Organization, Primary EDE
Entity, must complete Appendix B. The description should also include the method of
interconnection to the Hub.
Include a Topological Diagram of the system which depicts the interconnectivity between
the Hub and the Non-CMS Organization including all components (i.e., firewalls, routers,
switches, hubs, servers, encryption devices, and computer workstations) and interfaces
(i.e., real-time, on-demand, and batch) on which data and information is exchanged.
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6.2

Services Offered

CMS shall:
•

Provide 24/7 operation of the CMS IT Service Desk (1-800-562-1963, 410-786-2580, or
[email protected]) for the Non-CMS Organization POC to
communicate any security issues; and

•

Provide installation, configuration, and maintenance of CMS edge router(s) with
interfaces to multiple CMS core and edge routers.

The Non-CMS Organization shall:
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6.3

Security and Privacy Controls

CMS shall:
•

Comply with the latest CMS Acceptable Risk Safeguards (ARS) 9, which are based on the
most recent NIST SP 800-53 and HHS policy and standards.
8F

The Non-CMS Organization shall:
9

The CMS Acceptable Risk Safeguards (ARS) is located at: https://www.cms.gov/Research-Statistics-Data-andSystems/CMS-Information-Technology/InformationSecurity/Information-Security-Library.

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•

Adhere to the security and privacy requirements specified in the Non-Exchange Entity
(NEE) System Security and Privacy Plan (SSP) document, 10 which are specifically
incorporated herein.
9F

7. Request to Connect
The Non-CMS Organization sends to CMS a completed ISA document and artifacts of
compliance with security and privacy control requirements. After review of the ISA, along with
all required artifacts and an evaluation of risk, the CMS CIO, or his designee, will act on the
request to connect to the Hub in writing by signing the ISA or by denying the request. No PII
shall pass through any CMS network before the Non-CMS Organization obtains a fully signed
ISA.
The Non-CMS Organization must also send to CMS a signed EDE Agreement and meet all
requirements set forth in that Agreement before CMS will permit connection to the Hub.

7.1

Required Documents

Pursuant to 45 C.F.R. § 155.260, Privacy and Security of Personally Identifiable Information,
and 45 C.F.R. § 155.280, Oversight and Monitoring of Privacy and Security Requirements, the
Non-CMS Organization shall report, on a continuing basis, the status of their security posture to
Non- CMS Organization’s authorizing official and CMS. If the Non-CMS Organization does not
meet the required reporting timeframes, the ISA may be revoked. Before CMS can make a riskbased decision on the system’s ISA, the following agreements and compliance artifacts are
required:
1. EDE Agreement;
2. Interconnection Security Agreement (ISA), renewed every year or whenever there is a
major change;
3. Security Assessment Report (SAR), performed by an auditor, and Plan of Action &
Milestones (POA&M); and
4. Information Security and Privacy Continuous Monitoring (ISCM) 11 artifacts.
10F

8. Security Responsibilities
Both parties shall:
•

10
11

Maintain a level of security that is commensurate with the risk and magnitude of the
harm that could result from the loss, misuse, disclosure, or modification of the
information contained on the system with the highest sensitivity levels.

The Non-Exchange Entity System Security and Plan (SSP) is located at:
https://zone.cms.gov/document/enhanced-direct-enrollment-ede-documents-and-materials.
The Non-Exchange Entity (NEE) Information Security and Privacy Continuous Monitoring (ISCM) Strategy Guide
is located at: https://zone.cms.gov/document/enhanced-direct-enrollment-ede-documents-and-materials.

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•

8.1

Non-CMS Organization’s responsibilities under this provision are in addition to those
specified in Section 6.3.

Communication / Information Security Points of Contact

Both parties shall:
•

Designate a technical lead for their respective network and provide POC information to
facilitate direct contacts between technical leads of each party to support the management
and operation of the interconnection;

•

Maintain open lines of communication between POCs at both the managerial and
technical levels to ensure the successful management and operation of the
interconnection; and

•

Inform their counterpart promptly of any change in technical POCs and interconnections.

CMS shall:
•

Ensure its staff informs their counterparts at the Non-CMS Organization promptly of any
change in technical POC and interconnection; and

•

Identify a CMS ISSO to serve as a liaison between CMS and the Non-CMS Organization
and assist the Non-CMS Organization in ensuring that its IS controls meet or exceed
CMS requirements.

The Non-CMS Organization shall:
•

8.2

Designate an IS POC, the equivalent of the CMS ISSO, who shall act on behalf of the
Non-CMS Organization and communicate all IS issues involving the Non-CMS
Organization to CMS via the CMS ISSO.

Responsible Parties

Appendix A is a list of the responsible parties for each system. Appendix A will be updated
whenever necessary. Updating Appendix A does not require either party to re-sign this ISA. It is
the responsibility of each respective approving authority to ensure the timely updating of
Appendix A and to notify the alternate party of such changes; each party will use reasonable
efforts to do so within thirty (30) days of any material personnel change.

9. Personnel / User Security
9.1

User Community

Both parties shall:
•

Ensure that all employees, contractors, and other authorized users with access to the CMS
Network and the Non-CMS Organization as well as the data sent and received from either
organization are not security risks and meet the personnel security / suitability

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requirements of the CMS Business Partners System Security Manual (2018) 12 as a guide,
which is specifically incorporated herein.
11F

The Non-CMS Organization shall:
•

9.2

Enforce the following IS best practices:
– Least Privilege – Only authorizing access to the minimal amount of resources
required for a function;
– Separation of Duties – A security method that manages conflict of interest, the
appearance of conflict of interest, and fraud. It restricts the amount of power held by
any one individual; and
– Role-Based Security – Access controls to perform certain operations ("permissions")
are assigned to specific roles.

Commitment to Protect Sensitive Information

Both parties shall:
•

Not release, publish, or disclose information to unauthorized personnel, and shall protect
such information in accordance with this ISA, the EDE Agreement, and any other
pertinent laws and regulations governing the responsibility to adequately safeguard
federal agency systems.

The Non-CMS Organization shall:
•

Require that its employees and contractors comply with the security requirements set
forth in this ISA, EDE Agreement, and the organization’s specific information security
policies, standards, and procedures.

•

Require that outsourced operations where non-CMS personnel may have access to
information, CMS systems, and network components comply with requirements of
Federal Acquisition Regulation (FAR) clause 52.239-1, Privacy or Security Safeguards,
and CMS IS policies, standards, and procedures, which are specifically incorporated
herein.

9.3

Training and Awareness

Both parties shall:

•

Have all users, including employees, contractors, and other authorized users, complete
the information security and privacy awareness training on execution of this ISA and then
annually thereafter; and

•

Train, monitor, and audit staff on requirements related to the authorized use and sharing
of PII with third parties, and on the consequences of unauthorized use or sharing of PII.

The CMS Business Partners System Security Manual is located at: http://www.cms.gov/Regulations-andGuidance/Guidance/Manuals/downloads/117_systems_security.pdf.

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9.4

Personnel Changes / De-Registration

Both parties shall:
•

Provide notification to their respective BOs of the separation or long-term absence of
their network owner or technical lead; and

•

Provide notification to their respective BO of any changes in the ISSO or POC
information.

10. Policies
10.1 Rules of Behavior
CMS shall:
•

Ensure that all CMS system users with access to the CMS Network shall adhere to all
current HHS Rules of Behavior. 13
12F

The Non-CMS Organization shall:
•

Require that all users with access to the Non-CMS Organization’s system and its
connection with the Hub, adhere to the terms of this ISA and the EDE Agreement
executed between the Non-CMS Organization and CMS.

•

Require the Non-CMS Organization’s Rules of Behavior provide protections that are
commensurate with current HHS Rules of Behavior.

10.2 Security Documentation
Both parties shall:
•

Ensure that security is planned for, documented, and integrated into the System Life
Cycle from the IT system’s initiation to the system’s disposal. For applicable guidance,
please refer to CMS Target Life Cycle 14 and the CMS Risk Management Handbook. 15
13F

14F

CMS shall:
•

13
14
15

Review the CMS System Security and Privacy Plan (SSP) for CMS information systems
and the CMS network annually and update it when a major modification occurs, as
required by the CMS SSP Procedures.

Located at: https://www.hhs.gov/about/agencies/asa/ocio/cybersecurity/rules-of-behavior-for-use-of-hhsinformation-resources/index.html.
Located at: https://www.cms.gov/Research-Statistics-Data-and-Systems/CMS-Information-Technology/TLC.
Located at: https://www.cms.gov/Research-Statistics-Data-and-Systems/CMS-InformationTechnology/InformationSecurity/Information-Security-Library.

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The Non-CMS Organization shall:
•

Maintain an SSP based on the Non-Exchange Entity (NEE) System Security and Privacy
Plan (SSP) document 16 on the Non-CMS Organization’s network and update annually or
whenever there is a significant change; 17 and
15F

16F

•

Make accessible to CMS all IS program documents including, but not limited to, those
documents specified in Section 7.1.

11. Network Security
11.1 Network Management
Both parties shall:
•

Ensure that this interconnection is isolated from all other customer / business processes to
the greatest extent possible.

11.2 Material Network Changes
Both parties shall:
•

Submit to the CMS CCIIO any proposed material changes to either network or the
connecting medium accompanied by a valid business justification;

•

Renegotiate this ISA before any material changes are implemented;

•

Report planned technical changes to the network architecture that affect the
interconnection to the CMS CCIIO Hub team;

•

Conduct a risk assessment based on the new network architecture and modify and re-sign
this ISA within one (1) month prior to implementation; and

•

Notify the CMS CCIIO Hub team when access is no longer required.

11.3 New Interconnections
The Non-CMS Organization shall:
•

16
17

List and define any new interconnections or updates to any existing interconnections,
including any new updates in processes related to sharing, utilizing, and downloading
data; and

The Non-Exchange Entity System Security and Plan (SSP) is located at:
https://zone.cms.gov/document/enhanced-direct-enrollment-ede-documents-and-materials.
Per NIST SP 800-37, significant changes to an information system may include, for example: (i) installation of a
new or upgraded operating system, middleware component, or application; (ii) modifications to system ports,
protocols, or services; (iii) installation of a new or upgraded hardware platform; (iv) modifications to cryptographic
modules or services; or (v) modifications to security controls. Examples of significant changes to the environment
of operation may include, for example: (i) moving to a new facility; (ii) adding new core missions or business
functions; (iii) acquiring specific and credible threat information that the organization is being targeted by a threat
source; or (iv) establishing new/modified laws, directives, policies, or regulations.

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•

Notify CMS when new interconnections impact the security posture of the EDE Pathway
or the Hub, unless expressly agreed in a modification to the relevant ISA and signed by
both parties.

11.4 Network Inventory
The Non-CMS Organization shall:
•

Maintain and make available to CMS on request a list of all Non-CMS Organization
subnets connected to CMS’s network, if applicable, and periodically update the
information, including information on each owner, physical location, Internet Protocol
(IP) address, host’s name, hardware, operating system version, and applications.

11.5 Firewall Management
CMS shall:
•

Configure the CMS network perimeter firewall in accordance with CMS IS policy;

•

Block all network traffic incoming from the Internet to CMS unless it is explicitly
permitted; and

•

Install a firewall between the perimeter (demarcation point) of the Non-CMS
Organization’s network and CMS’s network if deemed necessary by CMS CCIIO Hub
team.

The Non-CMS Organization shall:
•

Maintain responsibility for configuring all Non-CMS Organization network perimeter
firewalls in accordance with a policy at least as stringent as CMS IS policy as reflected in
this ISA; and

•

Provide to the CMS CCIIO Hub team a list of Non-CMS Organization authorized web
HTTP, File Transfer Protocol (FTP), and Simple Mail Transport Protocol (SMTP)
servers (identified individually as HTTP, FTP, and/or SMTP) on the Non-CMS
Organization’s network.

11.6 Penetration Test
The Non-CMS Organization shall:
•

Execute a Rules of Engagement with their penetration testing team;

•

Not target IP addresses used for the CMS and Non-CMS Organization connection;

•

Conduct penetration testing in the lower environment that mirrors the production
environment;

•

Not conduct penetration testing in the production environment;

•

Notify CMS designated technical counterparts on their annual penetration testing
schedule; and

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•

Provide the following information to CMS a minimum of 5 business days prior to
initiation of testing:
– Period of testing performance (specific times for all testing should be contained in
individual test plans);
– Target environment resources to be tested (IP addresses, Hostname, URL); and
– Any restricted hosts, systems, or subnets that are not to be tested.

12. Incident Prevention, Detection, and Response
12.1 Incident Handling
CMS shall:
•

Handle and report incidents in accordance with the CMS Risk Management Handbook
(RMH) Chapter 08: Incident Response. 18
17F

The Non-CMS Organization shall:
•

Implement Breach and Incident Handling procedures that are consistent with CMS’s
Incident and Breach Notification Procedures and incorporate these procedures in the
Non-CMS Organization’s own written policies and procedures.

•

Implement specifications. Such policies and procedures would:
– Identify the Non-CMS Organization’s Designated Security and Privacy Official(s), if
applicable, and/or identify other personnel authorized to access PII and responsible
for reporting to CMS and managing Incidents 19 or Breaches 20;
– Provide details regarding the identification, response, recovery, and follow-up of
Incidents and Breaches, which should include information regarding the potential
need for CMS to immediately suspend or revoke access to the Hub for containment
purposes; 21 and
18F

19F

20F

Located at the CMS IS webpage, available at: https://www.cms.gov/Research-Statistics-Data-andSystems/CMS-Information-Technology/InformationSecurity/Info-Security-Library-Items/RMH-Chapter-08Incident-Response.
OMB Memorandum M-17-12 defines “incident” or “security incident” as an occurrence that (1) actually or
imminently jeopardizes, without lawful authority, the integrity, confidentiality, or availability of information or an
information system; or (2) constitutes a violation or imminent threat of violation of law, security policies, security
procedures, or acceptable use policies. OMB Memorandum M-17-12, Preparing for or Responding to A Breach
of Personally Identifiable Information, January 3, 2017. Located at:
http://www.osec.doc.gov/opog/privacy/Memorandums/OMB_M-17-12.pdf.
OMB Memorandum M-17-12 defines “breach” as the loss of control, compromise, unauthorized disclosure,
unauthorized acquisition, or any similar occurrence where (1) a person other than an authorized user accesses
or potentially accesses Personally Identifiable Information or (2) an authorized user accesses or potentially
accesses Personally Identifiable Information for anything other than an authorized purpose.
Please refer to RMH Chapter 08 Incident Response Appendix K - Incident Report Template located at:
https://www.cms.gov/Research-Statistics-Data-and-Systems/CMS-InformationTechnology/InformationSecurity/Info-Security-Library-Items/RMH-Chapter-08-Incident-Response-Appendix-KIncident-Report-Template.

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– Require reporting any Breach of PII to the CMS IT Service Desk by telephone at
(410) 786-2580 or 1-800-562-1963 or via email notification at
[email protected] within 24 hours from knowledge of the Breach.
Incidents must be reported to the CMS IT Service Desk by the same means as
Breaches within 72 hours from knowledge of the Incident.

12.2 Intrusion Detection
Both parties shall:
•

Monitor intrusion detection activities and disseminate intrusion detection alerts to their
respective BO counterparts for all networks within the scope of this ISA 22;
21F

•

Report to both CMS and the Non-CMS Organization’s BO any security incident that
occurs on either organization’s network within the scope of this ISA; and

•

Block inbound and outbound access for any CMS or Non-CMS Organization information
systems on the network within the scope of this ISA that are the source of unauthorized
access attempts, or the subject of any security events, until the risk is remediated.

12.3 Disasters and Other Contingencies
Both parties shall:
•

Promptly notify their designated counterparts as defined in the information system
contingency plan in the event of a disaster or other contingency that disrupts the normal
operation of one or both connected networks.

13. Notice
Both parties shall:
•

Provide notice to all persons specifically required under this ISA in writing and shall be
delivered as follows:

If to Non-CMS Organization:

If to CMS:
Centers for Medicare & Medicaid Services (CMS)
Center for Consumer Information & Insurance Oversight (CCIIO)
Room 739H 200 Independence Avenue, SW
Washington, DC 20201
Notices sent by hand or overnight courier service, or mailed by certified or registered mail, shall
be deemed to have been given when received, provided that notices not given on a business day
22

Intrusion detection audit logs must be kept for purposes of forensic investigation in the case of an incident.

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(i.e., Monday – Friday excluding federal holidays) between 9:00 a.m. and 5:00 p.m. local time
where the recipient is located shall be deemed to have been given at 9:00 a.m. on the next
business day for the recipient. Either party to this Agreement may change its contact information
for notices and other communications by providing thirty (30) days’ written notice of such
change in accordance with this provision.

14. Modifications
If any personnel changes occur involving the POCs listed in this ISA, the terms of this ISA shall
remain in full force and effect, unless formally modified by both parties. Any modifications that
materially change the security posture of the portion of the information system related to this
ISA shall be in writing and agreed and approved in writing by both parties.

15. Compliance
Non-compliance with the terms of this ISA by either party or unmitigated security risks in
violation of this ISA may lead to termination of the interconnection. CMS may block network
access for the Non-CMS Organization if the Non-CMS Organization does not implement
reasonable precautions to prevent the risk of security incidents spreading to CMS’s network.
CMS is authorized to audit the security of Non-CMS Organization’s Network periodically by
requesting that Non-CMS Organization provide documentation of compliance with the security
requirements in this ISA (please refer to Section 22, Records). The Non-CMS Organization shall
provide CMS reasonable access to its IT resources impacted by this ISA for the purposes of
audits, subject to applicable legal requirements and policies.

16. Termination
Termination of this ISA will result in termination of the functionality and electronic
interconnection(s) covered by this ISA. The termination of EDE Agreement and/or Issuer
Agreement and/or Web-broker Agreement will result in termination of this ISA. Termination of
any of the agreements referenced in this provision will result in termination of DE Entity’s
ability of to use the EDE Pathway as allowed by this ISA.

17. Cost Considerations
Both parties agree to be responsible for their own systems and costs of the interconnecting
mechanism and/or media. No financial commitments to reimburse the other party shall be made
without the written concurrence of both parties. Modifications to either system that are necessary
to support the interconnection are the responsibility of the respective system/network owners’
organization. This ISA neither authorizes, requires, nor precludes any transfer of funds without
the agreement of both parties.

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18. Timeline
This Agreement becomes effective on the date the last of the two parties executes this
Agreement and ends the day before the first day of the annual open enrollment period (OEP) for
the benefit year beginning January 1, 2024.

19. Order of Precedence
In the event of an inconsistency between the terms and conditions of this ISA and the terms and
conditions of any other agreement, memorandum of understanding, or acquisition between CMS
and Non-CMS Organization, the terms and conditions of the EDE Agreement shall have
precedence over this ISA. If the terms and conditions at issue are not otherwise covered in the
EDE Agreement, the parties agree that the ISA will have precedence.

20. Confidentiality
Subject to applicable statutes and regulations, including the Freedom of Information Act, the
parties agree that the terms and conditions (any proprietary information) of this ISA shall not be
disclosed to any third party outside of the Government without the prior written consent of the
other party.
Both parties may disclose the terms, conditions, and content of this ISA as reasonably necessary
to their respective auditors, counsel, and other oversight agencies to respond to a properly
authorized civil, criminal judicial process or regulatory investigation or subpoena or summons,
issued by a federal or state authority having jurisdiction over either party for examination,
compliance, or other purposes, as authorized by law. Any such disclosure may only be made
after giving prior notice to the other party of the potential disclosure as soon as reasonably
practical before such disclosure is required to be made. Either party, as a condition of its consent
to disclosure, may require the other party to take sufficient measures to protect against the
disclosure of information that could present significant risk to the security posture of the parties’
systems, including the exposure of vectors of attack. Such measures include, but are not limited
to, obtaining a protective order from a court of competent jurisdiction, disclosing the ISA in
redacted form, or disclosing the ISA subject to a non-disclosure agreement, as appropriate under
the circumstances and applicable law.

21. Survival
The Non-CMS Organization’s duty to protect and maintain the privacy and security of PII, as
well as the confidentiality requirements under Section 20, shall survive the termination of this
ISA.

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22. Records
The Non-CMS Organization shall maintain all records that it may create in the normal course of
its business in connection with activity under this ISA for the term of this ISA and for at least ten
(10) years after the date this ISA terminates or expires in accordance with 45 C.F.R. §§
155.220(c)(3)(i)(E) or 156.705(c), as applicable. Subject to applicable legal requirements and
reasonable policies, such records shall be made available to CMS to ensure compliance with the
terms and conditions of this ISA. The records shall be made available during regular business
hours at Non-CMS Organization offices, and CMS’s review shall not interfere unreasonably with
the Non-CMS Organization business activities.

23. Assignment and Severability
This ISA may not be assigned to another party without the specific written consent of the other
party. If any term or condition of this ISA becomes inoperative or unenforceable for any reason,
such circumstances shall not have the effect of rendering the term or condition in question
inoperative or unenforceable in any other case or circumstances, or of rendering any other term
or condition contained in this ISA to be invalid, inoperative, or unenforceable to any extent
whatsoever. The invalidity of a term or condition of this ISA shall not affect the remaining terms
and conditions of this ISA.

24. Warranty
CMS does not warrant that Non-CMS Organization interconnection to the CMS network under
this ISA will meet Non-CMS Organization requirements, expectations, or even the stated
expected benefit of Non-CMS Organization interconnection to CMS (please refer to Provision 6,
Statement of Requirements). Non-CMS Organization bears the entire risk regarding the quality
and performance of its interconnection with the CMS, and Non-CMS Organization’s exclusive
remedy is to terminate this ISA in accordance with the terms and conditions herein.
CMS EXPRESSLY DISCLAIMS ALL WARRANTIES OF ANY KIND, EXPRESS OR
IMPLIED, INCLUDING BUT NOT LIMITED TO THE IMPLIED WARRANTIES OF
MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE WITH REGARD
TO NON-ORGANIZATION’S INTERCONNECTION TO THE CMS.

25. Limitation of Liability
UNDER NO CIRCUMSTANCES AND UNDER NO LEGAL THEORY, WHETHER TORT
(INCLUDING NEGLIGENCE), CONTRACT, OR OTHERWISE, SHALL CMS BE LIABLE
TO NON-CMS ORGANIZATION OR ANY OTHER PERSON FOR ANY INDIRECT,
SPECIAL, INCIDENTAL, OR CONSEQUENTIAL DAMAGES OF ANY CHARACTER
INCLUDING, WITHOUT LIMITATION, DAMAGES FOR LOSS OF GOODWILL, WORK
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COMMERCIAL DAMAGES OR LOSSES, EVEN IF SUCH PARTY SHALL HAVE BEEN
INFORMED OF THE POSSIBILITY OF SUCH DAMAGES.

26. Force Majeure
Non-CMS Organization’s failure to comply with any term or condition of this ISA as a result of
conditions beyond its fault, negligence, or reasonable control (such as, but not limited to, war,
strikes, floods, governmental restrictions, riots, fire, other natural disasters, or similar causes
beyond Non-CMS Organization control) shall not be deemed a breach of this ISA.

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27. Signatures
Both parties agree to work together to ensure the joint security of the connected networks and the
data they store, process, and transmit, as specified in this ISA. Each party certifies that its
respective network is designed, managed, and operated in compliance with this ISA, and all
relevant federal laws, regulations, policies and the EDE System Security and Privacy Plan
document. Each party attests that the information provided in this ISA is true, correct, and
complete to the best of their knowledge. Each party also certifies that its respective network has
been certified and accredited in accordance with NIST guidance.
By signing below, the parties agree to the terms and conditions of this ISA.
This “CMS INTERCONNECTION SECURITY AGREEMENT (ISA) BETWEEN CENTERS
FOR MEDICARE & MEDICAID SERVICES (CMS) AND ENHANCED DIRECT
ENROLLMENT ENTITY” has been signed and executed by:

FOR EDE ENTITY
The undersigned is an authorized official of EDE Entity who is authorized to represent and
bind EDE Entity for purposes of this ISA.
Authorized Official for

Chief Information Security Officer /
Senior Officer of Privacy (equivalent) for

(Signature)
(Date)

(Signature)

(Date)

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FOR CMS
The undersigned are officials of CMS who are authorized to represent and bind CMS for
purposes of this ISA.

(Signature)

(Date)

Kevin Allen Dorsey
Senior Information Security Officer
Center for Consumer Information and Insurance Oversight (CCIIO)
Centers for Medicare & Medicaid Services (CMS)

(Signature)

(Date)

Marc Richardson
Director of Marketplace Information Technology Group (MITG)
Center for Consumer Information and Insurance Oversight (CCIIO)
Centers for Medicare & Medicaid Services (CMS)

(Signature)

(Date)

Jeffrey D. Grant
Deputy Director for Operations
Center for Consumer Information and Insurance Oversight (CCIIO)
Centers for Medicare & Medicaid Services (CMS)

(Signature)

(Date)

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Robert Wood
Director Information Security and Privacy Group (ISPG)
Chief Information Security Officer (CISO)
Office of Information Technology (OIT)
Centers for Medicare & Medicaid Services (CMS)

(Signature)

(Date)

George C. Hoffmann
Deputy Chief Information Officer (Dep. CIO)
Office of Information Technology (OIT)
Centers for Medicare & Medicaid Services (CMS)

(Signature)

(Date)

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Appendix A. Responsible Parties
Instruction: Appendix A is a list of the responsible parties for each system. Appendix A
will be updated whenever necessary. Updating Appendix A does not require either party
to re-sign this ISA. It is the responsibility of each respective approving authority to
ensure the timely updating of Appendix A and to notify the alternate party of such
changes; each party will use reasonable efforts to do so within thirty (30) days of any
material personnel change. [Delete this instruction.]
[Click here and type text here]

A.1 Authorizing Official
Instruction: The Authorizing Official is the official designated by the EDE Entity
organization, which is responsible for the security and privacy of this system. [Delete
this instruction.]
[Click here and type text here]
Table 1. System Authorizing Official
System Authorizing
Official Information

Detail

Name

Title

Company / Organization

Address

Phone Number

<555-555-5555>

Email Address

A.2 Other Designated Contacts
Instruction: AOs should use the following section to identify points of contact who
understand the technical implementations of the identified system. Add more tables as
needed.
Note: If you add more tables, be sure to update the Table Caption field to ensure the
correct, sequential table numbering; update the cross-reference fields for the tables; and
update the List of Tables in the front matter. If you copy a table, paste it at an insertion
point styled as “Normal” and use the following command: Paste/Paste Special/Formatted
Text (RTF) where Track Changes is turned off. [Delete these instructions.]
Table 2 and Table 3 identify the following individual(s) who possess in-depth knowledge of this
system and/or its functions and operation.

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Table 2. Information System Management Point of Contact
Information System
Management POC

Detail

Name

Title

Company / Organization

Address

Phone Number

<555-555-5555>

Email Address

Table 3. Information System Technical Point of Contact
Technical POC

Detail

Name

Title

Company / Organization

Address

Phone Number

<555-555-5555>

Email Address

A.3 Assignment of Security and Privacy Responsibility
The EDE Entity Information System Security Officer (ISSO) or equivalent, identified in Table 4,
has been appointed in writing and is deemed to have significant cyber and operational role
responsibilities.
Table 4. EDE Entity Name Internal ISSO (or Equivalent) Point of Contact
EDE Internal ISSO

Detail

Name

Title

Company / Organization

Address

Phone Number

<555-555-5555>

Email Address

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The EDE Entity Information System Official for Privacy, identified in Table 5, has been
appointed in writing and is deemed to have significant privacy operational role responsibilities.
Table 5. EDE Entity Internal Official for Privacy (or Equivalent) Point of Contact
EDE Internal Official for
Privacy POC

Detail

Name

Title

Company / Organization

Address

Phone Number

<555-555-5555>

Email Address

Table 6 names the CMS Information System Security Officer responsible for providing
assistance to the EDE Entity security and privacy officers.
Table 6. CMS ISSO Point of Contact
CMS ISSO POC

Detail

Name

CMS ISSOs

Title

ISSO

Company / Organization

CMS/Center for Consumer Information and Insurance
Oversight/Marketplace IT Group

Address

7500 Security Blvd., Baltimore, MD 21244-1850

Email Address

[email protected]

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Appendix B. Primary EDE Entities Connection and Data Sharing
with Upstream EDE Entities
Instruction: Appendix B is a description of the data connections, functionality, and
systems between a primary EDE Entity and its upstream EDE Entities. Primary EDE
Entities will need to complete this form (all sections: B.1 through B.4) annually and when
onboarding a new upstream EDE Entity as part of the Interconnection Security
Agreement (ISA) and Information Security and Privacy Continuous Monitoring (ISCM)
Strategy Guide. Updating Appendix B does not require the re-signing of the ISA by
either party. It is the responsibility of each respective approving authority to ensure the
timely updating of Appendix B and for the notification of such changes to the alternate
party within thirty (30) days of any personnel change.
A primary EDE Entity must complete this Appendix and return it via the CCC-SFTP to
CMS. Please contact DE Support ([email protected]) with any questions.
[Delete this instruction.]

B.1 Upstream EDE Entities Overview
Instructions: Populate Table 7 for each upstream EDE Entity, regardless of the upstream
EDE Entity’s current go-live status (i.e., live or onboarding). [Delete this instruction.]
Table 7 contains the following fields:
•

Upstream EDE Entity: Document all known or unexpected EDE Entities and/or system
name (if applicable).

•

Entity Type: Document the Entity Type (e.g., issuer, web-broker, agent/broker). 23

•

Partner ID(s): Provide the Partner ID(s) for the upstream EDE Entity.

22F

Table 7. Upstream EDE Entity Overview
Upstream EDE Entity

Entity Type

Partner ID(s)

Definitions of each entity type are available in 45 C.F.R. § 155.20.

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B.2 Data Connections
Instructions: During the annual EDE Agreement Renewal submission of the ISA,
Primary EDE Entities must document all approved upstream EDE Entity relationships in
Table 8. After the annual EDE Agreement Renewal submission, primary EDE Entities
must submit a new Table 8 documenting each new upstream EDE Entity relationship.
Note: If you insert a new Table 8, be sure to update the Table Caption field to ensure the
correct, sequential table numbering; update the cross-reference fields for the tables; and
update the List of Tables in the front matter. If you copy a table, paste it at an insertion
point styled as “Normal” and use the following command: Paste/Paste Special/Formatted
Text (RTF) where Track Changes is turned off. [Delete these instructions.]
Note: A primary EDE Entity adding any EDE Entity relationships must also follow the
Change Notification Procedures for Enhanced Direct Enrollment Entity Information
Technology Systems process including performing a Security Impact Analysis (SIA), a
Business Impact Analysis (BIA), and potentially updating the Privacy Impact Assessment
(PIA) based on the analysis of the SIA to determine the impact that changes will have on
the Entity’s IT systems. [Delete this instruction.]
Table 8 contains the following fields:
•

ID: Unique identifier for the row item to track items between Table 8 and Table 9, as
applicable.

•

Information System Name: IT system environment name for the EDE Environment
Provider.

•

Upstream EDE Entity Organization Name: Document all known or expected upstream
entities and/or system name (if applicable).

•

Information Being Transmitted: For example, personally identifiable information (PII)
data elements, enrollment information, eligibility information, and 834s.

•

Data Sharing Agreement in Place: Briefly describe terms of the Agreement (e.g.,
Memorandum of Understanding [MOU)] and Business Agreement), parties to the
agreement, data covered, and protection requirements for the data.

•

Connection Type/Data Direction: IPSec VPN, SSL, Secure File Transfer,
API/Incoming, outgoing, or both.

•

Comments: Any additional comments to describe the data connection.

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Table 8. Interconnections and Data Exchange Between EDE Environment Provider and Upstream Entities
ID

Information System
Name

Upstream EDE Entity
Organization Name

Information Being
Transmitted 24
23F

Data Sharing
Agreement in Place

Connection / Data
Direction

Comments

1
2
3
4
5
6
7
8
9

Note: A primary EDE Entity adding any EDE Entity relationships must also follow the Change Notification Procedures for the Enhanced Direct Enrollment
Entity Information Technology Systems process.

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B.3 Additional Functionality or Systems
Instructions: During the annual EDE Agreement Renewal submission of the ISA,
Primary EDE Entities must document all approved upstream EDE Entity relationships in
Table 9. After the annual EDE Agreement Renewal submission, primary EDE Entities
must submit a new Table 9 for each new upstream EDE Entity. If you insert a new Table
9, be sure to update the Table Caption field to ensure the correct, sequential table
numbering; update the cross-reference fields for the tables; and update the List of Tables
in the front matter. If you copy a table, paste it at an insertion point styled as “Normal”
and use the following command: Paste/Paste Special/Formatted Text (RTF) where Track
Changes is turned off. [Delete this instruction.]
Note: A primary EDE Entity adding any EDE Entity relationships must also follow the
Change Notification Procedures for Enhanced Direct Enrollment Entity Information
Technology Systems process including performing a Security Impact Analysis (SIA), a
Business Impact Analysis (BIA), and potentially updating the Privacy Impact Assessment
(PIA) based on the analysis of the SIA to determine the impact that changes will have on
the Entity’s IT systems. [Delete this instruction.]
Table 9 contains the following fields:
•

ID: Unique identifier for the row item to track items between Table 8 and Table 9, as
applicable.

•

Information System Name: IT system environment name for the EDE Environment
Provider.

•

Upstream EDE Entity Organization Name: Document all known or expected upstream
entities and/or system name (if applicable).

•

NEW: SSO Implementation: If an EDE arrangement will involve SSO, the entity must
describe the SSO implementation, including, at a minimum, the following information:
which users will use the SSO implementation (i.e., consumers, agents, and brokers) and
the process to and entity responsible for conducting identity proofing of consumers,
agents, and brokers.

•

Additional Functionality/Systems: For each applicable arrangement, indicate whether
the primary EDE Entity’s environment integrates with any functionality or systems
owned, controlled, managed, or accessed by the upstream EDE Entity that exists outside
of the boundaries of the audited, primary EDE Entity’s EDE environment. For any such
functionality or system, indicate the data transferred between the external environment
and the EDE environment (e.g., data regarding data matching issues, special enrollment
period verification issues, and enrollment status).
– In the following sub-bullets, CMS provides several, non-exhaustive examples of
potential additional functionality or systems:
♦ Example Scenario 1: An upstream EDE Entity collects initial data from a
consumer on its system for the purposes of completing an eligibility application or
to display health insurance options or QHPs (e.g., plan selection), and then may
redirect the consumer and/or their data to the primary EDE Entity for completing
the eligibility application or enrollment experience.

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♦

♦

Example Scenario 2: An upstream EDE Entity provides a plan selection and
enrollment process separate from the primary EDE Entity’s EDE environment.
Example Scenario 3: An upstream entity provides the agent/broker identity
proofing implementation on its own system. Agents and brokers then use the
primary EDE Entity’s EDE environment to assist consumers.
Example Scenario 4: An upstream entity retrieves, stores, transfers, or manages
consumer data obtained or collected through the primary EDE Entity’s EDE
environment on the upstream entity’s own system (e.g., data stored in a customer
relationship management software).
Example Scenario 5: An upstream entity implements a single sign-on solution
with the primary EDE Entity’s EDE Environment.

•

REVISED: QHP Display for EDE End-User Experience: For each arrangement,
indicate whether the primary EDE Entity or upstream EDE Entity provides the QHP
display for the EDE End-User Experience. If both the primary and upstream EDE Entity
provide the QHP display—such as at different parts of the EDE End-User Experience or
for different pathways (e.g., agent/broker and consumer), describe the details of the
arrangement for displaying QHPs in the End-User Experience for both agents/brokers
and consumers.
– For example, the upstream EDE Entity sends a selected QHP to the primary
EDE Entity before a user completes the eligibility application, and the primary
EDE Entity provides a post-application QHP shopping experience.
– Another example, the upstream EDE Entity hosts a pre-application QHP
display for agents/brokers and sends the QHP selection to the primary EDE
Entity. The primary EDE Entity hosts the QHP display for consumers.

•

Comments: Any additional comments to describe the data connection.

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Table 9. Additional Functionality or Systems
ID

Information System
Name

Upstream EDE Entity
Organization Name

SSO
Implementation 25
24F

Additional
Functionality 26
25F

QHP Display for EDE
End-User
Experience 27

Comments

26F

1
2
3
4
5

25
26
27

CMS has added this new field to Table 9. Please review the instructions above to provide an appropriate response to this field.
Note: A primary EDE Entity adding any EDE Entity relationships must also follow the Change Notification Procedures for Enhanced Direct Enrollment Entity
Information Technology Systems process.
CMS has revised the instructions for this field. Please carefully review the instructions above to provide an appropriate response to this field.

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B.4 Data Flow/Topological Diagram
Instructions: Describe the flow of data in and out of the Primary EDE Environment and
Additional Systems/Functionality system boundaries and insert a data flow/topological
diagram. Describe protections implemented at all entry and exit points in the data flow. If
necessary, include multiple data flow/topological diagrams.
To insert a figure object, style the insertion point as “Figure” and paste the object as a
Picture (Enhanced Metafile) or .png. [Delete this instruction.]
Figure 2 represents the data flow in and out of the Primary EDE Environment and Additional
Systems/Functionality system boundaries.
Figure 2. Data Flow/Topological Diagram

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File Type	application/pdf
File Title	Interconnection Security Agreement (ISA) Template
Subject	Enhanced Direct Enrollment Entity, EDE, Interconnection Security Agreement, ISA, CCIIO, Center for Consumer Information and Insu
Author	Centers for Medicare & Medicaid Services (CMS)
File Modified	2023-10-29
File Created	2023-10-11