HUD OCIO should implement a process to consistently update and maintain its inventory of hardware assets and ensure that the inventory is consistent with the automated discovery scans used to perform vulnerability, configurations, and continuous diagnostics and mitigation scans and use this inventory to consistently remove unauthorized hardware assets from the HUD network (IG FISMA metrics 2, 20, and 21).

HUD OCIO should report at least 80 percent of its government-furnished equipment through the DHS CDM program (IG FISMA metric 2).

HUD OCIO should update its software inventory policies and procedures to account for critical software as defined by EO 14028 (IG FISMA metrics 3 and 21).

HUD OCIO should implement policies and procedures to maintain inventories of critical software and software licenses, critical software platforms, and all software installed on critical software platforms (both critical software and noncritical software) and use the inventory of critical software platforms and all software installed on them to ensure that only supported versions of software are used on those critical software platforms (IG FISMA metrics 3 and 21).

HUD OCIO should in coordination with the Chief Risk Officer (CRO), document cybersecurity risk management roles and responsibilities in a consolidated list and; define procedures to hold personnel accountable to their assigned roles in the consolidated list (IG FISMA metric 7)

HUD OCIO should consistently implement personnel accountability procedures to ensure that assigned cybersecurity risk management roles are being performed in an effective manner (IG FISMA metric 7).

HUD OCIO should ensure that external systems, such as cloud systems and cloud service providers, have and maintain configuration management plans that are consistent with HUD’s defined configuration management requirements (IG FISMA metric 19).

HUD OCIO should define and implement metrics to monitor the effectiveness of ICAM program activities and assist in identifying areas for improvement (IG FISMA metric 26).

HUD OCIO should develop a comprehensive ICAM policy, strategy, process, and technology solution roadmap, including milestones, budget estimates, and appropriate technology solution details (IG FISMA metric 27). This recommendation replaces FY 2020 FISMA recommendation 11.

HUD OCIO should define policies and guidance for the use of system-specific access agreements (IG FISMA metric 29).

HUD OCIO should develop a plan that includes milestones and funding requirements for implementing phishing-resistant MFA for all users in alignment with Federal requirements (IG FISMA metrics 30 and 31).

HUD OCIO, in coordination with other appropriate HUD offices, should define and communicate policies and procedures for use of MFA at HUD facilities (IG FISMA metrics 30 and 31).

HUD OCIO should implement procedures to ensure that digital identity risk assessments have been performed and documented in accordance with HUD’s defined procedures and Federal guidelines (IG FISMA metrics 30 and 31).

HUD OCIO should define a plan to meet the logging requirements at all event logging maturity levels (basic, intermediate, advanced) in accordance with OMB M-21-31. This plan should include logging sufficient to allow for reviewing privileged user activities (IG FISMA metrics 32 and 54).

HUD OCIO should develop and implement monitoring and enforcement procedures to ensure that non-GFE devices (for example, BYOD), such as those owned by contractors or HUD employees, are either: (a) prohibited from connecting to the HUD network; or (b) properly authorized and configured before connection to the HUD network (IG FISMA metrics 2, 21, and 33).

HUD OCIO should develop and implement procedures and contract terms to enforce forfeiture of non-GFE devices (for example, BYOD), to allow for analysis when security incidents occur (IG FISMA metrics 33 and 55).

HUD OCIO should develop and implement processes to monitor and analyze qualitative and quantitative performance measures for the effectiveness of its ISCM program (IG FISMA metric 47).

HUD OCIO should define a process and assign responsibility to evaluate the effectiveness of its incident response technologies and adjust configurations and toolsets to improve the incident response program (IG FISMA metric 58).

HUD OCIO should update its enterprisewide business impact prioritization analysis procedures to include system dependencies and the characterization of system components (IG FISMA metric 61).

HUD’s Office of the Chief Financial Officer (OCFO), in coordination with other appropriate program offices, should define and implement a risk-based process to assess and document IT risk management personnel resourcing needs and that those personnel are allocated effectively to support HUD’s risk management program (IG FISMA metric 7).

HUD OCFO, in coordination with other appropriate program offices, should define and implement a process to document and allocate non-personnel risk management resources in a risk-based manner, to include but not limited to funding, processes, and technology (IG FISMA metric 7).

HUD’s Office of Administration, in coordination with OCIO, should update and communicate its PII minimization plan. The plan should include detailed procedures to regularly review and remove unnecessary PII collections in accordance with OMB Circular A-130 (IG FISMA metric 35).