Define and communicate policies and procedures to ensure that its products, system components, systems, and services comply with its cybersecurity and SCRM requirements. This recommendation includes:
- Identification and prioritization of externally provided systems (new and legacy), components, and services.
- How HUD maintains awareness of its upstream suppliers.
- The integration of acquisition processes tools, and techniques to use the acquisition process to protect the supply chain.
- Contract tools or procurement methods to confirm that contractors are meeting their obligations (derived from OIG FISMA metric 14).
Status
The Office of the Chief Information Officer (OCIO) estimated it would complete corrective action for this recommendation by August 2023. In May 2024, HUD OIG reviewed the Office of the Chief Information Officer’s (OCIO) progress in closing this recommendation as part of the FY 2024 FISMA evaluation. At that time, OCIO provided its draft SCRM Policy, SCRM Procedures, SCRMES Charter, and a SCRM Technical Roadmap. Additionally, HUD provided agency-specific clauses. As of November 2024, the guidance had not yet been finalized.
Analysis
To fully address this recommendation, HUD must establish that it has defined and communicated policies and procedures to ensure that its products, system components, systems, and services comply with its cybersecurity and SCRM requirements.
Implementation of this recommendation will result in HUD continuing to mature in supply chain risk management, establishing and defining the policies and procedures of SCRM requirements as it relates to systems and system components.
Publication Report
2021-OE-0001 | February 17, 2022
Fiscal Year 2021 Federal Information Security Modernization Act (FISMA) Evaluation Report
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