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Non-Exchange Entity Name (Acronym)
Security and Privacy Controls
Assessment Test Plan of the
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Security and Privacy Controls Assessment Test Plan
Prepared by:
Organization Name: .
Street Address:
Suite/Room/ Building:
City, State Zip:
Prepared for:
Organization Name: .
Street Address:
Suite/Room/ Building:
City, State Zip:
Revision History
Date
Description
Version
of SAP
Author
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Instruction
(Delete page when draft plan is completed.)
The assessment test plan must be jointly completed and agreed to before the start
of the assessment by both the Enhanced Direct Enrollment (EDE) Entity and the
Auditor. To expedite the process, this may be done during an assessment kickoff
meeting.
It is strongly recommended that Non-Exchange Entities (NEE) that are not EDE
Entities contract with a third-party auditor that has experience conducting
information system privacy and security audits to perform the assessment. This
Security and Privacy Controls Assessment Test Plan (SAP) provides the template
that the auditor should use for the assessment.
The goal of the kickoff meeting is to obtain the necessary information for the
scope of the assessment not included in the contract statement of work. The
Auditor must obtain this to accurately complete the assessment plan.
The NEE should be prepared to bring the necessary resources to the kickoff
meeting or ensure the availability of resources to expedite the process during the
meeting. After this plan has been completed, the Auditor must meet again with the
NEE to present the draft security assessment plan and make necessary changes
before finalizing the plan. This Security and Privacy Controls Assessment Test
Plan (SAP) must be submitted to CMS for review prior to the assessment.
[Delete this and all other instructions from your final version of this document.]
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Table of Contents
1. Introduction ................................................................................................................... 1
1.1
1.2
Applicable Laws, Regulations, and Standards..................................................................1
Purpose ..............................................................................................................................2
2. Scope ............................................................................................................................... 2
2.1
2.2
2.3
2.4
2.5
2.6
2.7
2.8
2.9
2.10
System or Application Name ............................................................................................2
IP Addresses Slated for Testing ........................................................................................3
Roles Slated for Testing ....................................................................................................4
Applications Slated for Testing ........................................................................................4
Web Applications Slated for Testing ................................................................................5
Infrastructure and Network Slated for Testing .................................................................5
Databases Slated for Testing.............................................................................................6
Documentation Review.....................................................................................................6
NEE SSP Controls to Be Tested .......................................................................................7
Assumptions / Limitations ................................................................................................9
3. Methodology................................................................................................................. 10
4. Test Roles ..................................................................................................................... 13
4.1
4.2
Security and Privacy Assessment Team .........................................................................13
Provider Testing Points of Contact .................................................................................13
5. Test Schedule ............................................................................................................... 14
6. Rules of Engagement................................................................................................... 16
6.1
6.2
6.3
6.4
6.5
6.6
6.7
Disclosures ......................................................................................................................16
Security Testing Scenarios..............................................................................................16
Test Inclusions ................................................................................................................17
Test Exclusions ...............................................................................................................18
End of Testing .................................................................................................................18
Communication of Test Results ......................................................................................18
Signatures........................................................................................................................18
Appendix A. Test Case Procedures................................................................................. 20
Appendix B. Penetration Testing and Methodology ..................................................... 21
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List of Tables
Table 1. Information System Name and Description...................................................................... 3
Table 2. Information System Components ..................................................................................... 3
Table 3. IP Addresses Slated for Testing ........................................................................................ 4
Table 4. Roles Slated for Testing.................................................................................................... 4
Table 5. Applications ...................................................................................................................... 5
Table 6. Web Applications Slated for Testing ................................................................................ 5
Table 7. Infrastructure and Network Components Slated for Testing ............................................ 6
Table 8. Databases Slated for Testing............................................................................................. 6
Table 9. Assessed Controls ............................................................................................................. 8
Table 10. System/Application Configuration ............................................................................... 11
Table 11. Scanning Tools ............................................................................................................. 11
Table 12. Personnel Interviews ..................................................................................................... 11
Table 13. Manual Testing Procedures .......................................................................................... 12
Table 14. Security and Privacy Assessment Team........................................... 13
Table 15. Provider Testing Points of Contact ............................................................................... 14
Table 16. Test Schedule ................................................................................................................ 14
Table 17. Schedule of Activities and Participation....................................................................... 15
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1. Introduction
The () will be assessed by
, the Auditor. This Security and Privacy Controls Assessment Test Plan (SAP)
must be submitted to the Centers for Medicare & Medicaid Services (CMS) for review prior to
the assessment. Both EDE Entities 1 and Non-Exchange Entities (NEEs) participating in the
classic Direct Enrollment program only (e.g., Web-Brokers not participating in the EDE
program) should have a fully completed and implemented System Security and Privacy Plan
(SSP) prior to starting the security and privacy audit.
0F
The use of an independent assessment team reduces the potential for conflicts of interest that
could occur in verifying the implementation status and effectiveness of the security controls.
National Institute of Standards and Technology (NIST) Special Publication (SP) 800-39,
Managing Information Security Risk states:
Assessor independence is an important factor in: (i) preserving the impartial and
unbiased nature of the assessment process; (ii) determining the credibility of the
security assessment results; and (iii) ensuring that the authorizing official receives
the most objective information possible in order to make an informed, risk-based,
authorization decision.
An Auditor is independent if there is no perceived or actual conflict of interest involving the
developmental, operational, and/or management chain associated with the system and the
determination of security and privacy control effectiveness. The Auditor’s role is to provide an
independent assessment of the compliance of the enhanced direct enrollment pathway and to
maintain the integrity of the audit process. The Auditor is required to attest to their independence
and objectivity in completing the audit, and that neither the NEE nor the Auditor took any
actions that might impair the objectivity of the findings in the audit in Section 6.7.
1.1
Applicable Laws, Regulations, and Standards
By interconnecting with the CMS network and CMS information system, the
agrees to be bound by the Interconnection Security Agreement (ISA) and the use of the CMS
network and information system in compliance with the ISA. Laws, regulations, and standards
that apply include the following:
1
•
Federal Information Security Management 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 1966 P.L. 104-191
•
Patient Protection and Affordability Care Act (“PPACA”) of 2010
Enhanced Direct Enrollment (EDE) Entities are considered NEEs and will be referred to as NEEs in this document.
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•
HHS Regulation 45 CFR §155.260 – Privacy and Security of Personally Identifiable
Information
•
HHS Regulation 45 CFR §155.280 – Oversight and monitoring of privacy and security
requirements
•
NIST SP 800-53, Revision 4, Security and Privacy Controls for Federal Information
Systems and Organizations
•
NIST SP 800-53A, Assessing Security and Privacy Controls in Federal Information
Systems and Organizations
1.2
Purpose
This Security and Privacy Controls Assessment Test Plan documents all testing to be conducted
during the assessment to validate the security and privacy controls for . It has been completed by for the benefit of .
NIST SP 800-39, Managing Information Security Risk states:
The information system owner and common control provider rely on the security
expertise and the technical judgment of the assessor to: (i) assess the security
controls employed within and inherited by the information system using
assessment procedures specified in the security assessment plan; and (ii) provide
specific recommendations on how to correct weaknesses or deficiencies in the
controls and address identified vulnerabilities.
2. Scope
2.1
System or Application Name
Instruction: Complete Table 1 with the name of the system(s) and/or
application(s) that are scheduled for testing. Briefly describe the system
components. The description can be copied from the description in the System
Security and Privacy Plan (SSP).
Complete Table 2 with the geographic location of all the components that will be
tested.
Include additional rows as necessary to the tables.
If N/A is provided, please provide a detailed explanation as to why.
[Delete this and all other instructions from your final version of this document.]
[Click here and type text.]
Table 1 describes the information system(s) and/or application(s) scheduled for testing.
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Table 1. Information System Name and Description
Information System Name
Information System Description
[Insert system name]
[Insert system description]
Table 2 describe the physical locations of all components that will be tested.
Table 2. Information System Components
Login URL* Data Center Site Name
[Insert Login URL* Data Center Site name]
Description of
Components
Address
[Insert address]
[Insert component
description]
* Uniform Resource Locator (URL)
2.2
IP Addresses Slated for Testing
Instruction: List the IP addresses of all system components that will be tested.
You will need to obtain this information from the SSP and the organization. Note
that the IP addresses found in the SSP must be consistent with the boundary. If
additional IP addresses are discovered that were not included in the SSP and
Privacy Plan, note a finding and advise the organization to update the inventory
and boundary information in the SSP. IP addresses can be listed by network
ranges and Classless Inter-Domain Routing (CIDR) blocks. If the network is a
large network, test a subset of the IP addresses. Include additional rows to the
table as necessary.
The Auditor must ensure that the inventory is current before testing and that the
inventory and components to be tested are in agreement with the NEE. In lieu of
filling out this table, the Auditor may embed a separate file as long as all required
information is included. In addition, the Auditor may use any unique identifier
(e.g., MAC address or hostname), instead of the IP address.
If N/A is provided, please provide a detailed explanation as to why.
[Delete this and all other instructions from your final version of this document.]
Table 3 identifies the IP addresses and network range of the system that will be tested.
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Table 3. IP Addresses Slated for Testing
No.
[#]
2.3
Item
(Manufacturer
and Model)
IP
Address(s)
or Range
Machine
/Hostname
Operating
System/Software
and Version
[Insert item
manufacturer #]
[Insert IP
address or
range]
[Insert
machine or
hostname]
[Insert software
and version]
Function
[Insert IP
function]
Item Physical
location
[Insert description of
physical
network/system?
location]
Roles Slated for Testing
Instruction: Roles to be tested should correspond to those roles listed in the
SSP. Role testing will be performed to test
the authorization restrictions for each role. The Auditor will access the system
while logged in as different user types and attempt to perform restricted functions
as unprivileged users.
If N/A is provided, please provide a detailed explanation as to why.
[Delete this and all other instructions from your final version of this document.]
For this assessment, staff names have been associated with the specific roles
and corresponding responsibilities.
Table 4 identifies the roles slated for testing.
Table 4. Roles Slated for Testing
NEE Role
Name
NEE Test User ID/Credential
Auditor Staff Name
Auditor Staff Associated
Responsibilities
[Ex.
Anonymous
Consumer
Shopper]
[Ex. No Account Created]
[Ex. Jane Doe
[Ex. Account Creation]
[Ex. Agent /
Broker Account]
[Ex. ABTest1]
[Ex. John Doe
[Ex. System Updates]
2.4
Applications Slated for Testing
Instruction: List all the application that will be tested. You will need to obtain
this information from the SSP and the organization.
If N/A is provided, please provide a detailed explanation as to why.
[Delete this and all other instructions from your final version of this document.]
Table 5 below indicates the list of applications to be tested.
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Table 5. Applications
Vendor
[Insert Vendor name]
2.5
Product Name
Version
[Insert product name]
[Insert version #]
Web Applications Slated for Testing
Instruction: The Auditor must test for the most current Open Web Application
Security Project (OWASP) Top Ten Most Critical Web Application Security
Risks. 2 Provide any web application URL and components that will be in scope
for this assessment in the following table.
1F
If N/A is provided, please provide a detailed explanation as to why.
[Delete this and all other instructions from your final version of this document.]
Table 6 identifies the web applications slated for testing.
Table 6. Web Applications Slated for Testing
Login URL for
the Application
[Insert login URL]
2.6
Web Application Name
[Insert web application name]
Function / Description
[Insert description of web
application and function]
Infrastructure and Network Slated for Testing
Instruction: Identify all infrastructure components that will be in scope for this
assessment in the following table.
If N/A is provided, please provide a detailed explanation as to why.
[Delete this and all other instructions from your final version of this document.]
Table 7 identifies the infrastructure and/or network components of the system that will be tested.
2
The OWASP Top Ten Most Critical Web Application Security Risks are located at:
https://www.owasp.org/index.php/Category:OWASP_Top_Ten_Project
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Table 7. Infrastructure and Network Components Slated for Testing
Unique
ID
[#]
[Ex. 12]
2.7
NetBIOS Name
MAC Address
[If available, state
the NetBIOS
name of the
inventory item.
This can be left
blank if one does
not exist, or it is a
dynamic field.]
[If available, state
the MAC Address
of the inventory
item. This can be
left blank if one
does not exist, or
it is a dynamic
field.]
[Ex. DC-53-6066-C0-92]
[Ex. N/A]
OS Name and
Version
Hardware
Make / Model
Asset Type
[Operating
System Name
and Version
running on the
asset.]
[Simple
description of the
asset's function
(e.g., Router,
Storage Array,
and DNS Server)]
[Ex. CentOS 5.1]
[Ex. Web Server]
[Name of the
hardware product
and model.]
[Ex. Acme
Server]
Databases Slated for Testing
Instruction: Provide information about databases and instances that will be in
scope for this assessment in the following table.
If N/A is provided, please provide a detailed explanation as to why.
[Delete this and all other instructions from your final version of this document.]
Table 8 identifies the system database(s), instances, and/or tables that will be tested.
Table 8. Databases Slated for Testing
Unique
ID
[#]
[Name of Software or
Database vendor.]
[Ex. 13]
2.8
Software / Database
Vendor
Software / Database
Name and Version
[Name of Software or
Database product and
version number.]
[Ex. Oracle]
[Ex. Oracle 10g]
Patch Level
[If applicable.]
[Ex.
2018.1.1.0000a]
Function
[For Software or
Database, the function
provided by the Software
or Database for the
system.]
[Ex. Testing Data]
Documentation Review
Instruction: Security and privacy documentation will be reviewed for
completeness and accuracy. Through this process, the Auditor will gain insight to
determine if all controls are implemented as described. The Auditor’s review also
augments technical control testing.
The Auditor must review the following required documents as a minimum for the
assessment. Additional documents or supporting artifacts may be reviewed as
necessary.
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If any document is removed, please provide an alternative document or
explanation as to why.
[Delete this and all other instructions from your final version of this document.]
The following documents will be assessed:
•
Business Agreement with Data Use Agreement (DUA)
•
Configuration Management Plan (CMP)
•
Contingency Plan (CP) and Test Results
•
Plan of Action and Milestones (POA&M)
•
System Security and Privacy Plan (SSP), Final
•
Incident Response Plan (IRP) and Incident/Breach Notification and Test Plan
•
Privacy Impact Assessment (PIA) and other privacy documentation. including, but not
limited to, privacy notices and agreements to collect, use, and disclose PII and Privacy
Act Statements
•
Security Awareness Training (SAT) Plan and Training Records
•
Interconnection Security Agreements (ISA)
•
Information Security Risk Assessment (ISRA)
•
Governance documents and privacy policy
2.9
NEE SSP Controls to Be Tested
Instruction: The Auditor must test all security and privacy controls in the NEE
SSP workbook to ensure the effectiveness of the implemented controls. The
Auditor’s testing will complement the document review.
Note: Auditors must test the Concurrent Session Control and Remote Access use
cases as documented in the EDE Auditor Guidelines.
•
Concurrent Session Control: The information system must prohibit
agent/broker use of concurrent sessions by FFE user ID.
Review Standard: The Auditor must validate the EDE Entity is able to
effectively block the creation of an additional account where the account
creation is attempted using the same FFE User ID; and that the EDE
environment effectively prohibits concurrent sessions.
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•
Remote Access: Access to the FFEs and SBE-FPs. EDE Entity and its
assignees or subcontractors—including, employees, developers, agents,
representatives, or contractors—cannot remotely connect or transmit data to
the FFE, SBE-FP or its testing environments, nor remotely connect or
transmit data to EDE Entity’s systems that maintain connections to the FFE,
SBE-FP or its testing environments, from locations outside of the United
States of America or its territories, embassies, or military installations. This
includes any such connection through VPN.
Review Standard: The Auditor must validate and document in the SAR that
existence of automated mechanisms to monitor and control remote access
methods. The Auditor must verify automated mechanism block IP addresses
located outside of the United States of America or its territories, embassies,
or military installations attempting to access the EDE environment.
[Delete this and all other instructions from your final version of this document.]
The controls implemented for the can be found documented
in the SSP.
[Instructions: The assessor must evaluate the following list of NEE security and
privacy controls to ensure the effectiveness of the implementation according to
the NEE SSP workbook. The assessor’s evaluation will complement the document
review.
The assessor must address the following criteria:
What controls are tested by the assessor?
Which NEE guidance version is used for testing?
[Delete this and all other instructions from your final version of this document.]
The assessor will complete a [full/partial] assessment of the security and privacy controls,
using NEE plan year [Insert year].
[Instructions: In the case of a partial assessment, complete the table below (Table
X. Assessed Controls), indicating which controls were assessed, matching the
Security and Privacy Assessment Worksheet in Appendix A. Then change font
color to black. Ensure to add a table caption with a table number and update all
subsequent tables as well as the List of Tables on page iii.
In the case of a full assessment, delete the table below.
[Delete this and all other instructions from your final version of this document.]
Table 9. Assessed Controls
Control Number
Control Name
[AC-1]
[Access Control (AC) Policy and Procedure]
[AC-2]
[Automated System Account Management]
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Control Number
Control Name
The controls implemented for the [System Acronym] are documented in the [System Acronym]
SSP.
2.10 Assumptions / Limitations
Instruction: The assumptions listed are default assumptions. The Auditor must
edit these assumptions as necessary for each unique engagement. The Auditor
may add more assumptions as necessary.
[Delete this and all other instructions from your final version of this document.]
1. resources, including documentation and individuals with knowledge of
the systems, applications, and infrastructure and associated contact
information, will be available to assessment staff during the scheduled
assessment timeframe and testing activities in order to complete the assessment.
2. The will provide login account information/credentials necessary for
assessment staff to use with its testing devices to perform authenticated
scans of devices and applications.
3. The will permit assessment staff to connect testing
laptops to the > networks defined within the scope of this assessment.
4. The will permit communication from the Auditor testing appliances to
an internet-hosted vulnerability management service to permit the analysis of
vulnerability data.
5. Security controls that have been identified as “Not Applicable” in the SSP must be
accompanied with an explanation and will be verified as such; further testing will not be
performed on these security controls.
6. Significant upgrades or changes to the infrastructure and components of the system
undergoing testing will not be performed during the security assessment period.
7. For onsite control assessment, personnel will be available should the
assessment staff determine that either after hours work or weekend
work is necessary to support the security assessment.
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3. Methodology
Instruction: The Auditor must describe the methodology and process for
conducting a complete and accurate security and privacy controls testing. The
Auditor must use NIST SP 800-53A which describes the appropriate assessment
testing procedure for each control. These test procedures include the test
objectives and associated test cases to determine if a control is effectively
implemented and operating as intended. The results of the testing will be recorded
in the Security and Privacy Assessment Report (SAR) along with information that
notes whether the control (or control enhancement) is satisfied or not.
The Auditor must identify the automated tools that will be used for the
assessment, including, but not limited to, tool name, vendor, version, and purpose
of the tool. The Auditor must identify the manual testing procedures by describing
what technical tests will be performed manually without the use of automated
tools and how it will be done. The Auditor must identify which security
configuration benchmarks, including version number, are used (e.g., DISA STIGs,
and USGCB).
Complete Table 10, Table 11, Table 12, and Table 13 as required.
The Auditor may edit this section as appropriate.
[Delete this and all other instructions from your final version of this document.]
will perform an assessment of the security
and privacy controls using the methodology described in NIST SP 800-53A.
will use test procedures to evaluate the security and privacy controls. The testing must include
the effectiveness of the most critical security controls implementation identified by the Center
for Internet Security. 3
2F
Data gathering activities will consist of the following:
•
Request required documentation
•
Request any follow-up documentation, files, or information needed that is not provided in
required documentation
•
Travel onsite as necessary to inspect system or applications and meet with staff
•
Obtain information using security testing tools
Security and privacy controls will be verified using one or more of the following assessment
methods:
•
3
Examine: The Auditor will review, analyze, inspect, or observe one or more assessment
artifacts as specified in the attached test cases in Appendix A.
Please refer to the most current CIS Top Twenty Controls located at: https://www.cisecurity.org/controls/. Also,
CMS has provided a mapping of the NEE SSP controls to the CIS Top Twenty Controls.
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•
Interview: The Auditor will conduct discussions with individuals within the organization
to facilitate assessor understanding, achieve clarification, or obtain evidence.
•
Technical Tests: The Auditor will perform technical tests, including penetration testing,
on system or application components using automated and manual methods.
[Instructions: The assessor must complete the following:
•
Test the application or system and the associated infrastructure
•
Perform a thorough assessment of the application or system
•
Conduct network-based scans of all in-scope network components to
determine ports, protocols, and services running on each component
•
Review the configurations
•
Complete Table 10, Table 11, Table 12, and Table 13 as required.
•
If N/A is provided, please provide a detailed explanation as to why.
[Delete this and all other instructions from your final version of this
document.]
Table 10. System/Application Configuration
HW/SW Name
Version
Benchmark
Benchmark Version
[Insert system or
application name]
[Insert Version #]
[Ex. DISA, STIGs, or
USGCB]
[Insert Benchmark Version
#]
Table 11. Scanning Tools
Test Performed/Purpose
Tools or Procedure
What was Tested
[Ex. Operating System Scan
Ex. Nessus
Ex. Internal boundary complete network]
[Ex. Web Application scan
Ex. HP WebInspect
Ex. Websites]
[Ex. Web Application scan
Ex. Burp Suite
Ex. Applications]
[Ex. Open Ports scan
Ex. Zenmap, Nmap
Ex. Any open ports]
[Ex. Database scan
Ex. DbProtect
Ex. Database configuration]
Table 12. Personnel Interviews
Title
Name of Person
Date of Interview
Comments
Business Owner(s)
[Insert name of individual]
[Insert interview date]
[Identify any further
relevant information]
Application Developer
[Insert name of individual]
[Insert interview date]
[Identify any further
relevant information]
Configuration
Manager
[Insert name of individual]
[Insert interview date]
[Identify any further
relevant information]
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Title
Name of Person
Date of Interview
Comments
[Insert name of individual]
[Insert interview date]
[Identify any further
relevant information]
Database
Administrator
[Insert name of individual]
[Insert interview date]
[Identify any further
relevant information]
Data Center Manager
[Insert name of individual]
[Insert interview date]
[Identify any further
relevant information]
Facilities Manager
[Insert name of individual]
[Insert interview date]
[Identify any further
relevant information]
Firewall Administrator
[Insert name of individual]
[Insert interview date]
[Identify any further
relevant information]
Human Resources
Manager
[Insert name of individual]
[Insert interview date]
[Identify any further
relevant information]
Information System
Security Officer
[Insert name of individual]
[Insert interview date]
[Identify any further
relevant information]
Privacy Program
Manager
[Insert name of individual]
[Insert interview date]
[Identify any further
relevant information]
Privacy Officer
[Insert name of individual]
[Insert interview date]
[Identify any further
relevant information]
Media Custodian
[Insert name of individual]
[Insert interview date]
[Identify any further
relevant information]
Network Administrator
[Insert name of individual]
[Insert interview date]
[Identify any further
relevant information]
Program Manager
[Insert name of individual]
[Insert interview date]
[Identify any further
relevant information]
System Administrators
[Insert name of individual]
[Insert interview date]
[Identify any further
relevant information]
System Owner
[Insert name of individual]
[Insert interview date]
[Identify any further
relevant information]
Training Manager
[Insert name of individual]
[Insert interview date]
[Identify any further
relevant information]
Contingency Planning
Manager
Table 13. Manual Testing Procedures
Test
ID #
Test
Manual Testing Procedure
Comments
1
[Test]
[Insert testing procedure]
[Identify any further
relevant information]
2
[Test]
[Insert testing procedure]
[Identify any further
relevant information]
3
[Test]
[Insert testing procedure]
[Identify any further
relevant information]
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4. Test Roles
4.1
Security and Privacy Assessment Team
Instruction: List the members of the assessment team and the role each member
will play in the following table. Include team members’ contact information.
Security and privacy control assessors play a unique role in testing system or
application security and privacy controls. NIST SP 800-39, Managing
Information Security Risk states:
The security control assessor is an individual, group, or organization
responsible for conducting a comprehensive assessment of the
management, operational, and technical security controls employed within
or inherited by an information system to determine the overall
effectiveness of the controls (i.e., the extent to which the controls are
implemented correctly, operating as intended, and producing the desired
outcome with respect to meeting the security requirements for the system).
If N/A is provided, please provide a detailed explanation as to why.
[Delete this and all other instructions from your final version of this document.]
The security and privacy assessment team consists of individuals from , which
are located at the following address: < Address of Auditor>. Information about
can be found at the following URL: .
Table 14 presents the members of the Auditor assessment team.
Table 14. Security and Privacy Assessment Team
4.2
Name
Role
Contact Information
[Insert Assessor name]
[Insert role]
[Insert contact information]
Provider Testing Points of Contact
Instruction: The Auditor must obtain at least two points of contact to use for
testing communications.
If N/A is provided, please provide a detailed explanation as to why.
[Delete this and all other instructions from your final version of this document.]
Table 15 lists the points of contact that the testing team will use.
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Table 15. Provider Testing Points of Contact
Name
Role
Contact Information
[Insert POC name]
[Insert role]
[Insert contact information]
5. Test Schedule
Instruction: Insert the assessment testing schedule. The following table is a
sample and provides suggested tasks and milestones in the assessment process.
Assessment tasks may vary between assessments. Remove or add tasks as
necessary. This schedule must be presented to the NEE by the Auditor at the
kickoff meeting. The Information System Security Officer (ISSO) and Senior
Official for Privacy (SOP) must be invited to the meeting that presents the
schedule to the NEE. After the Auditor presents the testing schedule to the NEE at
the kickoff meeting, the Auditor must make any necessary updates to the schedule
and this document and send an updated version to the NEE, with copies to the
ISSO and the SOP.
If N/A is provided, please provide a detailed explanation as to why.
[Delete this and all other instructions from your final version of this document.]
Table 16 presents the assessment testing schedule. All parties must agree on the tasks and
durations.
Table 16. Test Schedule
Task Name
Start Date
Finish Date
Hold Kickoff Meeting
[Insert start date]
[Insert completion date]
Develop Draft SAP
[Insert start date]
[Insert completion date]
Hold Meeting to Review SAP
[Insert start date]
[Insert completion date]
Finalize SAP
[Insert start date]
[Insert completion date]
Review Documentation
[Insert start date]
[Insert completion date]
Conduct Interviews of Staff
[Insert start date]
[Insert completion date]
Perform Testing
[Insert start date]
[Insert completion date]
Develop Draft SAR
[Insert start date]
[Insert completion date]
Draft SAR Delivered to NEE
[Insert start date]
[Insert completion date]
Hold Issue Resolution Meeting
[Insert start date]
[Insert completion date]
Finalize SAR
[Insert start date]
[Insert completion date]
Send Final Version of SAR to
[Insert start date]
[Insert completion date]
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Table 17 below is a suggested schedule of activities and participation for this assessment.
Table 17. Schedule of Activities and Participation
Schedule of Activities
Assessor Responsibilities
NEE Personnel
Responsibilities
• Attend Kickoff
• Review Draft Documents
• Review schedule and notify
assessment team
immediately of any
issues/conflicts
• Dates are provided for
availability for interviews
• Return SAP with completed
inventory and targets URLs
Planning
• Review SSP and other documents
provided
• Deliver SAP
• Conduct Kickoff Meeting
• Provide a project schedule
• Send invitations for agreed interview
and demo times
Interviews/Test Prep
Goals:
• All interviews, demos are
conducted
• Artifact Lists provided
• Connectivity to assets and
accounts are confirmed
• Conduct all interviews and
demonstrations
• Provide artifact request list after
each interview and within 1
business day of the last interview
• Finalize SAP and obtain signatures
• Test access to targets from source
IP
• Test accounts to ensure
authentication and proper account
privileges
• Work with NEE administrator to
meet goals
• Ensure proper individuals
are available for interview
• Begin to provide evidence
from interviews
• Full review and signed SAP
• Ensure access to all targets
from source IP
• Create and provide all test
accounts
• Work with testers to
troubleshoot connectivity
and access
Evidence Review/Testing
• Analysts analyze evidence
• Tester runs all automated scans
and any verification testing
• All evidence is returned by
date provided
• NEE tester POC is
available for any issues
(account reset, connectivity
loss, etc). Response time
should be within 2 hours.
• NEE personnel are
available for any follow up
questions
Reporting
• Assessment Team will be working
on the draft SAR
• Issue draft SAR by the end of the
week
• NEE personnel are
available for any follow up
questions
Finalization/Completion
• Answer any questions on the draft
SAR
• Schedule and attend debrief if
requested
• Update final SAR if necessary
• Review draft SAR and
provide any comments or
schedule debrief within 5
business days
• Obtain system owner
signature on final SAR
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Schedule of Activities
Assessor Responsibilities
• Ensure final SAR is issued within 5
business days of debriefing
NEE Personnel
Responsibilities
within 2 days of final
issuance
6. Rules of Engagement
Instruction: The RoE describes proper notifications and disclosures between the
owner of the systems or applications being tested and the Auditor. A RoE includes
information about automated scan targets and IP address origination information
of the automated scans (and other testing tools). The information provided in the
preceding sections of this document, along with the agreed-upon and signed RoE,
will serve as the RoE.
The Auditor must edit the Rules of Engagement (RoE) as necessary. The final
version of the RoE must be signed by both the Auditor and NEE must sign the
final version of the RoE.
If N/A is provided, please provide a detailed explanation as to why.
[Delete this and all other instructions from your final version of this document.]
[Click here and type text.]
6.1
Disclosures
Instruction: Edit and modify the disclosures as necessary. If testing will be
conducted from an internal location, identify at least one network port with access
to all subnets/segments to be tested. By identifying the IP addresses from where
the security testing will be performed, the NEE will understand that the rapid and
high-volume network traffic is not an attack and is part of the testing performed
by the Auditor.
If N/A is provided, please provide a detailed explanation as to why.
[Delete this and all other instructions from your final version of this document.]
Any testing will be performed according to terms and conditions designed to minimize risk
exposure that could occur during security testing. All scans will originate from the following IP
address(es): .
6.2
Security Testing Scenarios
Instruction: The following Vulnerabilities and Testing scenarios are provided by
CMS and their testing is required:
Test specifically for the following security vulnerabilities in addition to the
security controls provided:
1. SQL Injection
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2. Broken Authentication and Session Management
3. Sensitive Data Exposure
4. XML External Entity (XXE)
5. Broken Access Control
6. Security Misconfiguration
7. Cross-Site Scripting (XSS)
8. Insecure Deserialization
9. Using Components with Known Vulnerabilities
10. Insufficient Logging & Monitoring
For additional information, consult the OWASP Top Ten Most Critical Web
Application Security Risks. Please include additional testing scenarios in this
subsection response.
If an item is removed or N/A is provided, please provide a detailed explanation as
to why.
[Delete this and all other instructions from your final version of this document.]
[Click here and type text.]
6.3
Test Inclusions
Instruction: The Auditor must edit the bullets in this default list of test inclusions
to make it consistent with each unique system tested.
If an item is removed or N/A is provided, please provide a detailed explanation as
to why.
[Delete this and all other instructions from your final version of this document.]
Security testing may include the following activities:
•
Port scans and other network service interaction and queries
•
Network sniffing, traffic monitoring, traffic analysis, and host discovery
•
Attempted logins or other use of systems, with any account name/password
•
Attempted structured query language (SQL) injection and other forms of input parameter
testing
•
Use of exploit code for leveraging discovered vulnerabilities
•
Password cracking via capture and scanning of authentication databases
•
Spoofing or deceiving servers regarding network traffic
•
Altering running system configuration except where denial of service would result
•
Adding user accounts
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6.4
Test Exclusions
Instruction: The Auditor must edit the bullets in this default list of test exclusions
to make it consistent with each unique system tested. Insert additional test
exclusions here if applicable.
If an item is removed or N/A is provided, please provide a detailed explanation as
to why.
[Delete this and all other instructions from your final version of this document.]
Security testing will not include any of the following activities:
•
Changes to assigned user passwords
•
Modification of user files or system files
•
Telephone modem probes and scans (active)
•
Intentional viewing of staff email, Internet caches, and/or personnel
cookie files
•
Denial of service attacks
•
Exploits that will introduce new weaknesses to the system
•
Intentional introduction of malicious code (viruses, Trojans, worms, etc.)
•
[Insert additional test exclusions here if applicable]
6.5
End of Testing
will notify when security testing has been completed.
6.6
Communication of Test Results
Email and reports on all security testing will be encrypted according to
requirements. Security testing results will be sent and disclosed to the individuals at within days after security test has been completed.
The results of testing the security requirements will be summarized in the SAR.
The SAR will be reviewed to verify that each of the CMS requirements noted in the checklist is
included in the SAR and analyzed to determine if the information provided adequately addresses
the requirement.
6.7
Signatures
The following individuals at the and have been identified as
having the authority to agree to security testing of . The
Auditor attests to their independence and objectivity throughout the security and privacy
assessment.
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The following individuals acknowledge the foregoing Security and Privacy Assessment Plan and
Rules of Engagement and agree to the tests and terms set forth in the plan.
Representative
Representative
(Name)
(Name)
(Signature)
(Date) (Signature)
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Centers for Medicare & Medicaid Services
Appendix A. Test Case Procedures
Instruction: The Auditor must provide the test procedures containing the test
objectives and associated test cases to determine if a control is effectively
implemented and operating as intended. The Auditor can provide the test case
procedures in an Excel worksheet.
If N/A is provided, please provide a detailed explanation as to why.
[Delete this and all other instructions from your final version of this document.]
[Click here and type text.]
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Appendix B. Penetration Testing and Methodology
Instruction: The Auditor must attach a file containing the plan or include the plan
in this Appendix. The penetration testing must include, in part, the security testing
scenarios found in subsection 6.2. References to websites for their penetration
testing and methodology will not be accepted.
The NEE will understand that the rapid and high-volume network traffic is not an
attack and is part of the testing.
If N/A is provided, please provide a detailed explanation as to why.
[Delete this and all other instructions from your final version of this document.]
[Click here and type text.]
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| File Type | application/pdf |
| File Title | Security and Privacy Controls Assessment Test Plan Template |
| Subject | SAP, Security and Privacy, NEE, Non-Exchange Entity, CCIIO, Center for Consumer Information and Insurance Oversight, healthcare, |
| Author | Centers for Medicare & Medicaid Services (CMS) |
| File Modified | 2024-03-19 |
| File Created | 2023-10-11 |