CMS-10877 Security and Privacy Assessment Reports (SARs) template

Supporting Statement for Direct Enrollment Entities (CMS-10877)

CMS-10877 - Appendix_B_NEE-EDE-SAR-Template

OMB: 0938-1463

Document [pdf]
Download: pdf | pdf
OMB Control #: 0938-NEW
Expiration Date: XX/XX/20XX

Sensitive and Confidential Information – For Official Use Only

Non-Exchange Entity Name (Acronym)

Security and Privacy Assessment Report of the


As performed by 

SAR Version 0.1
Report Publication Date
CMS SAR Template v 3.2

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 Brittany.Cain@cms.hhs.gov.

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

Security and Privacy Assessment Report
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 SAR

Author


















SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

i
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

Table of Contents
1. Executive Summary ..................................................................................................... 1
2. Introduction and Purpose ........................................................................................... 1
2.1
2.2

Applicable Laws, Regulations, and Standards..................................................................1
Scope.................................................................................................................................2

3. System Overview .......................................................................................................... 5
3.1
3.2

System Description ...........................................................................................................5
Purpose of System.............................................................................................................5

4. Summary Report.......................................................................................................... 6
4.1
4.2

Summary of Findings........................................................................................................6
Summary of Recommendations........................................................................................8

5. Detailed Findings Report ............................................................................................ 8
5.1

Detailed Findings Table..................................................................................................11

Appendix A. Infrastructure Scan Results ..................................................................... 15
A.1 Infrastructure Scans: Raw Scan Results .........................................................................15
A.2 Infrastructure Scans: Total Findings Discovered............................................................15
A.3 Infrastructure Scans: False Positive Reports...................................................................16

Appendix B. Database Scan Results .............................................................................. 17
B.1
B.2
B.3
B.4

Database Scans: Inventory of Databases Scanned..........................................................17
Database Scans: Raw Scan Results.................................................................................17
Database Scans: Findings Discovered ............................................................................18
Database Scans: False Positive Reports..........................................................................18

Appendix C. Web Application Scan Results................................................................. 20
C.1
C.2
C.3
C.4

Web Applications Scans: Inventory of Web Applications Scanned...............................20
Web Applications Scans: Raw Scan Results ..................................................................20
Web Application Scans: Findings Discovered ...............................................................21
Web Applications Scans: False Positive Reports ...........................................................21

Appendix D. Penetration Test Report ........................................................................... 22
D.1 Penetration Test Report: Findings Discovered ...............................................................22

Appendix E. Penetration Test and Scan Results Summary ........................................ 24


SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

ii
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

List of Tables
Table 1. Executive Summary of Risks............................................................................................ 1
Table 2. Personnel Interviews......................................................................................................... 4
Table 3. Summary Findings Table.................................................................................................. 8
Table 4. Assessment Results......................................................................................................... 10
Table 5. Detailed Findings Table.................................................................................................. 13
Table 6. Summary of CIS Top 18 Controls .................................................................................. 13
Table 7. Summary of OWASP Top 10 ......................................................................................... 14
Table 8. Raw Scan Results by Infrastructure Scanner.................................................................. 15
Table 9. Findings Discovered by Infrastructure Scanner.............................................................. 16
Table 10. False Positive Reports by Infrastructure Scanner ......................................................... 16
Table 11. Database Inventory Scan Results.................................................................................. 17
Table 12. Raw Scan Results.......................................................................................................... 17
Table 13. Findings Discovered by Database Scanner................................................................... 18
Table 14. False Positives Generated by the Database Scanner..................................................... 18
Table 15. Inventory of Web Applications Scanned ...................................................................... 20
Table 16. Raw Scan Results.......................................................................................................... 20
Table 17. Findings Discovered by Web Application Scanner...................................................... 21
Table 18. False Positive Reports by Web Applications Scanner.................................................. 21
Table 19. IP Addresses and URLs for In-Scope Systems............................................................. 22
Table 20. Findings Discovered by Penetration Testing ................................................................ 22
Table 21. Summary of Scan Results ............................................................................................. 24
Table 22. Total Risk Findings from Penetration and Scan Testing .............................................. 24


SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

iii
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

1. Executive Summary
The primary purpose of this document is to provide a Security and Privacy Assessment Report
(SAR) for  for the purpose of making risk-based decisions.
A Security and Privacy Assessment of  was conducted between . The assessment was conducted in accordance with the approved Security and
Privacy Assessment Plan (SAP), dated , .
Table 1 represents the aggregate risks identified from the assessment. This table should reflect all
findings reported in the Detailed Findings Table.
Table 1. Executive Summary of Risks
Risk Category

Number of Risks

Critical

0

High

0

Moderate

0

Low

0

Total Risks

0

2. Introduction and Purpose
The Patient Protection and Affordable Care Act (ACA) program requires a Non-Exchange Entity
(NEE) to use an independent third-party Auditor to perform security and privacy assessment
testing and to develop a Security and Privacy Assessment Report (SAR) based on the outcomes
of the assessment. Enhanced Direct Enrollment (EDE) Entities are considered NEEs. The <
Auditor Name> performed security and privacy testing for 
in accordance with the  Security and Privacy Controls
Assessment Test Plan (SAP), , .
This SAR provides the  ISSO, SOP, and the AOs with the results of the assessment
completed for the . The SAR describes risks associated with
the vulnerabilities identified during the  independent
security and privacy assessment and serves as the risk summary report as referenced in the
Framework for Independent Assessment of Security and Privacy Controls for NEEs Entities and
NIST SP 800-37 Revision 2, Risk Management Framework for Information Systems and
Organizations: A System Life Cycle Approach for Security and Privacy.

2.1

Applicable Laws, Regulations, and Standards

By interconnecting with the CMS network and the CMS information system, the EDE Entity
agrees to be bound by the EDE Interconnection Security Agreement (ISA) and the use of the

SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

1
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

CMS network and information system in compliance with the ISA. Concurrently, by
interconnecting with the CMS network and the CMS information system, NEEs that are
participating in the classic Direct Enrollment program only (e.g., Web-Brokers not participating
in the EDE program), agree to be bound by the terms of Agreement between Web-Broker and
CMS for the Federally-Facilitated Exchanges and State-Based Exchanges on the Federal
Platform. The following applicable laws, regulations, and standards apply (the NEE may also
add state laws, regulations, and standards as applicable):
 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 of 2010
 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
 National Institute of Standards and Technology (NIST) Special Publication (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

2.2

Scope

The Auditor analyzed all assessment results to provide the  Information System Security
Officer (ISSO), Senior Official for Privacy (SOP), and the Authorizing Officials (AO) with an
assessment of the security and privacy controls that safeguard the confidentiality, integrity, and
availability (CIA) of data hosted by the system as described in the  System Security and Privacy Plan (SSP).
This document consists of a SAR for   as required by . This SAR presents the results
of a security and privacy test and evaluation of the  and is
provided to support the   program goals, efforts, and activities
necessary to achieve compliance with the necessary security and privacy requirements.
The  engaged < Auditor Name > to perform an onsite security and privacy controls
assessment (SCA) of the  to determine:
 If the system is in compliance with the CMS security and privacy standards described in
the EDE SSP;
 If the underlying infrastructure supporting the system is secure;

SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

2
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

 If the system and data are securely maintained; and
 If proper configuration associated with the database and file structure storing the data are in
place.
The SCA consisted of system components and documentation reviews. The following
components were tested during this assessment:
Instruction: Provide a list of components (e.g., hardware, software, etc.) that
were planned to be tested and those that were actually tested during the
assessment. These components may be items identified in the SAP, Section 2.
Include additional documents as necessary.


Example: Operating system(s): Windows, Linux and version



Example: Database and version #



Example: Information System, and sub-components



Example: Web Applications and URLs

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, at a minimum, the following required documents for
assessment Additional documents or supporting artifacts may be reviewed as
necessary. Please ensure the document file name includes version number and
date (e.g. Configuration Management Plan v2.2 07/21/2022).
[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 as well as agreements to collect, use, and disclose Personally
Identifiable Information (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; and

SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

3
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

 Documentation describing the organization’s privacy risk assessment process and
documentation of privacy risk assessments performed by the organization.
The assessor interviewed business, information technology, and support personnel to ensure
effective implementation of operational and managerial security and privacy controls across all
support areas. Interviews were customized to focus on control assessment procedures that apply
to individual roles and responsibilities and assure proper implementation and/or execution of
security and privacy controls.
Table 2 describes the personnel selected to be interviewed and their respective roles.
Table 2. 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]

Contingency
Planning Manager

[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]


SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

4
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

Title

Name of Person

Date of Interview

Comments

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]

3. System Overview
3.1

System Description
Instruction: In this subsection, insert a general description of the information
system. The description should be consistent with the description found in the
SSP. The description in this subsection may differ only if additional information is
included that is not available in the SSP or if the description in the SSP is not
accurate.
[Delete this instruction and all other instructions from your final version of this
document.]

[Click here and type text.]

3.2

Purpose of System
Instruction: Insert the purpose of the information system. The purpose must be
consistent with the SSP.
[Delete this instruction and all other instructions from your final version of this
document.]

[Click here and type text.]


SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

5
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

4. Summary Report
The Auditor has complied with the terms articulated in the SAP and the assessment is complete
and comprehensive. Appendices A through C provides the infrastructure, database, web
application scan results. Appendix D provides the penetration test report which includes test
results for all components within scope of the information system. Appendix E provides the
summary results of all scans.

4.1

Summary of Findings
Instruction: Provide a narrative summary of the findings relating to the security
and privacy control families. Complete the summary findings Table 3 for ALL
findings from the assessment regardless type of test.
The Auditor must provide a total of number system risks that were identified for
the information system. The Auditor must identify the number of High risks,
Moderate risks, and Low risks for all findings, including but not limited to, scan
results, penetration test results, interviews, and control test results. Priority levels
are based on the type of vulnerability identified.
Examples of findings fall into the following areas:


Access Control: An access control addresses purpose, scope, roles,
responsibilities, management commitment, coordination among organizational
entities, and compliance.



Account Management: Review information system account types include, for
example, individual, shared, group, system, guest/anonymous, emergency,
developer/manufacturer/vendor, temporary, and service.



Application Security: Enforces approved authorizations for logical access to
information and system resources.



Auditing and Monitoring: The organization monitors for evidence of unauthorized
disclosure of organizational information.



Configuration Management: Describes how to move changes through change
management processes, how to update configuration settings and baselines, how
to maintain information system component inventories, how to control
development, test, and operational environments, and how to develop, release,
and update key documents.



Database Management: Determines the types of changes to the database that are
configuration-controlled.



Documentation Updates: Addresses the establishment of policy and procedures
for the effective implementation of selected security controls and control
enhancements.



Identification and Authentication: The information system uniquely identifies and
authenticates organizational users.


SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

6
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)



Security Management: Verifies the identity of the individual, group, role, or
device receiving the authenticator.



Software Maintenance: Uses software and associated documentation in
accordance with contract agreements and copyright laws.



System and Information Integrity: Addresses purpose, scope, roles,
responsibilities, management commitment, coordination among organizational
entities, and compliance.



Authority and Purpose: Determines the legal authority that permits the collection,
use, maintenance, and sharing of PII, either generally or in support of a specific
program or information system need.



Accountability, Audit, and Risk Management: The organization has a designated
privacy official who is accountable for developing, implementing, and
maintaining governance and a strategic privacy program to ensure compliance
with all applicable laws and regulations regarding the collection, use,
maintenance, sharing, and disposal of PII by programs and information systems.



Data Quality and Integrity: The organizations take reasonable steps to confirm the
accuracy and relevance of PII. Such steps may include editing and validating
addresses as they are collected or entered into information systems using
automated address verification look-up application programming interfaces (API).



Data Minimization and Retention: The organization identifies the minimum PII
elements that are relevant and necessary to accomplish the legally authorized
purpose of collection.



Individual Participation and Redress: The organization provides means, where
feasible and appropriate, for individuals to authorize the collection, use,
maintaining, and sharing of PII prior to its collection.



Security: The organization establishes, maintains, and updates, within every 365
days, an inventory that contains a listing of all programs and information systems
identified as collecting, using, maintaining, or sharing PII.



Transparency: Provides effective notice, by virtue of its clarity, readability, and
comprehensiveness, enables individuals to understand how an organization uses
PII generally and, where appropriate, to make an informed decision prior to
providing PII to an organization.



Use Limitation: The organization uses PII internally only for the authorized
purpose(s) identified in the Privacy Act and/or in public notices.



If N/A is provided, please provide a detailed explanation as to why.

[Delete this instruction and all other instructions from your final version of this
document.]


SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

7
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

Table 3. Summary Findings Table
Row
#

4.2

Weakness

Risk Level

Control #

POA&M
Reference #

Summary of Recommendations

For each finding, the Auditor developed detailed recommendations for improvements that
address the findings and the business and system risks. Most of the recommendations in this
document fall into the following areas:
Instruction: While all findings must be addressed, findings representing a high
business risk should be mitigated or closed immediately to reduce the risk
exposure. The following example list of findings areas should be modified based
on the SCA results:


Block Unused Ports and Protocols:



Perform Security and Privacy Monitoring:



Strengthen Database Access Controls:



Update Documentation:
Provide a summary of recommendations grouped by families, if possible.
Identify which corrective actions can mitigate large groups of findings.
For example: The Access Control (AC) and most of the Configuration
Management (CM) findings can be remediated if the database is upgraded
to the latest version of the software, and necessary hot fixes and patches
are applied.

[Delete this instruction and all other instructions from your final version of this
document.]
[Click here and type text.]

5. Detailed Findings Report
Instruction: Provide a descriptive analysis of the vulnerabilities identified
through the comprehensive SCA process. Include findings from all scans and
tests. For each vulnerability, provide the following:


Explanation of the vulnerability



Identification of specific risks to the continued operations of the system


SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

8
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)



Analysis of impact of each risk



Suggested corrective actions for closing or reducing the impact of each
vulnerability

Auditors must test for the Concurrent Session Control and Remote Access use
cases as documented in the EDE Auditor Guidelines and document results in
Table 4.


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.



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 instruction and all other instructions from your final version of this
document.]
Table 4 provides a summary of the assessment results by control family. Progress on satisfying
any previously identified weaknesses must be actively monitored. Details of this review
including any management comments are provided in the  Security
and Privacy Assessment Worksheet.
Instruction: Add the numbers in Table 4.
SAMPLE Assessment Results
Total
Controls

Met

Partially Met

Not Met

6

2

3

1

Concurrent Session Testing:
AC-2: Account Management

1

1

Concurrent Session Testing:
AC-10 Concurrent Session Control

1

Security Controls
AC – Access Control


SAR Version 0.1

1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

9
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

Security Controls
Remote Access Testing:
AC-17: Remote Access

Total
Controls

Met

Partially Met

Not Met

1

1

AT – Awareness and Training

4

2

1

1

AU – Audit and Accountability

7

3

2

2

[Delete this instruction, including the foregoing table, and all other instructions
from your final version of this document.]
Table 4. Assessment Results
Security Controls

Total
Controls

Met

Partially Met

Not Met

AC – Access Control
Concurrent Session Testing:
AC-2: Account Management
Concurrent Session Testing:
AC-10 Concurrent Session
Control
Remote Access Testing:
AC-17: Remote Access
AT – Awareness and Training
AU – Audit and Accountability
CA – Security Assessment and
Authorization
CM – Configuration Management
CP – Contingency Planning
IA – Identification and
Authentication
IR – Incident Response
MA – Maintenance
MP – Media Protection
PE – Physical and Environmental
Protection
PL – Planning
PM – Program Management
PS – Personnel Security
RA – Risk Assessment
SA – System and Services
Acquisition
SC – System and Communications
Protection
SI – System and Information
Integrity

SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

10
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

Security Controls

Total
Controls

Met

Partially Met

Not Met

AP – Authority and Purpose
AR – Accountability, Audit, and
Risk Management
DI – Data Quality
DM – Data Minimization and
Retention
IP – Individual Participation and
Redress
SE – Security
TR – Transparency
UL – Use Limitation
TOTAL CONTROLS

5.1

Detailed Findings Table
Instructions: This subsection provides a description of the columns in the
Detailed Findings Table (Table 5).

Row Number
Each finding has a row number included to provide easy reference for briefings
and cross-referencing.

POA&M Reference #
Verify that the findings are identified in the Plan of Action and Milestones
(POA&M).

Weakness
The Weakness column provides a brief description of the security and privacy
vulnerability.

Risk Level
Each finding is considered a business risk and assigned a risk level rating of high,
moderate, or low. The rating provides an assessment of the magnitude of the
finding and helps establish a priority for addressing the vulnerability. The
following table defines the Risk levels.1

1

These risk levels are aligned NIST SP 800-30 Rev. 1.


SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

11
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

Definition of Risk Levels
Rating

Definition of Risk Rating

Critical

A threat event could be expected to have multiple severe or catastrophic adverse effects on
organizational operations, organizational assets, individuals, or other organizations.

High

A threat event could be expected to have a severe or catastrophic adverse effect on
organizational operations, organizational assets, individuals, or other organizations.

Moderate

A threat event could be expected to have a serious adverse effect on organizational
operations, organizational assets, individuals, or other organizations.

Low

A threat event could be expected to have a limited adverse effect on organizational
operations, organizational assets, individuals, or other organizations.

Control Number
The Control Number column identifies the EDE security and privacy control
family and control number that is affected by the vulnerability, for example,
(AC)-1: Access Control.

Center for Internet Security (CIS) Top 18 Control
State whether the control falls under a CIS Top 18 control area. 2

Open Web Application Security Project (OWASP) Top 10
State whether the finding falls under one of the OWASP Top 10 most critical web
application security risks.3

Affected Systems
The systems, URLs, IP addresses, etc., affected by the weakness, are documented
in the Affected Systems column. For example: SQL Server:master, or
http://127.0.0.1

Finding
A detailed description of the finding provides information on how the actual test
results fail to meet the security and privacy requirement. The first line of this
description with the date of the SAR is used to prepare the Plan of Action and
Milestone(s) and provides easy reference to the SAR for additional information.

Failed Test Description
The column for Failed Test Description documents the control’s weakness that
resulted in the finding. This description provides specific information from the
security and privacy policy, requirements, guidance, test objective, or published
industry best practices that was not provided with the controls implementation.

2
3

See https://www.cisecurity.org/controls/cis-controls-list/.
See https://owasp.org/www-project-top-ten/.


SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

12
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

Actual Test Results
The Actual Test Results provide specific information on the observed failure of
the test objective, policy, or guidance. This may also contain output from a test
performed on the system revealing non-compliance.

Corrective Actions
The Corrective Actions column presents the recommended actions to resolve the
vulnerability. The Auditor provides these suggestions to present guidance on a
potential fix.

POA&M Reference #
Identify the corresponding POA&M reference number. All findings listed must
have a POA&M reference number or state if the finding was remediated during
the assessment.

Status
The Status column provides status information, which includes when the
vulnerability was identified, actions being taken, or resolution of the weakness or
vulnerability.
If N/A is provided for any column, please provide a detailed explanation as to
why.
[Delete this instruction and all other instructions from your final version of this
document.]
Complete Table 5, Table 6, and Table 7. For Table 5, please complete the standalone Excel file
entitled, “Detailed Findings Table_SAR Template,” to input findings.
Table 5. Detailed Findings Table

Table 6. Summary of CIS Top 18 Controls
Assessment Results

Count

Partially Met

0

Not Met

0

TOTAL

0


SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

13
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

Table 7. Summary of OWASP Top 10
Assessment Results

Count

Partially Met

0

Not Met

0

TOTAL

0


SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

14
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

Appendix A. Infrastructure Scan Results
Infrastructure scans include scans of operating systems, networks, routers, firewalls, domain
name servers (DNS), domain servers, network information security (NIS) masters, and other
devices that keep the network running. These scans can include both physical and virtual Host
and devices. The  was used to scan the  infrastructure.  percent of the inventory was scanned. For the
remaining inventory, the Auditor performed a manual review of configuration files to analyze for
existing vulnerabilities. Any findings found as the result of the scans were documented in the
SAR’s Detailed Findings Table (Table 5).

A.1 Infrastructure Scans: Raw Scan Results
Instruction: Provide all - infrastructure scan results generated by the scanner in a
readable format. Bundle all scan results into one zip file. Do not insert files that
require a scan license to read the file.
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 lists the files that are included.
Table 8. Raw Scan Results by Infrastructure Scanner
Title of the Document

Description

File Name
(Includes Extension)

A.2 Infrastructure Scans: Total Findings Discovered
Instruction: Summarize the Infrastructure scan assessment results in the
following table. Ensure that the scanner severity level is appropriately mapped to
the risk level ratings.
The number of reported findings from the scan results should match the combined
number of findings in Table 9 and Table 10.
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.]


SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

15
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

Table 9. Findings Discovered by Infrastructure Scanner
Risk Level

Infrastructure Scans

Critical
High
Moderate
Low
Total

A.3 Infrastructure Scans: False Positive Reports
Instruction: Use the summary table to identify false positives that were generated
by the scanner. For each false positive reported, add an explanation as to why that
finding is a false positive. Use a separate row for each false positive reported. If
one IP address has multiple false positive reports, give each false positive its own
row. Add as many rows as necessary. The “FP” in the identifier number refers to
“False Positive” and the “IS” in the identifier number refers to “Infrastructure
Scan.”
[Delete this and all other instructions from your final version of this document.]
Table 10 identifies false positives that were generated by the infrastructure scanner.
Table 10. False Positive Reports by Infrastructure Scanner
ID #

Page and
IP Address

Scanner Severity
Level

Finding

False Positive
Explanation

1-FP-IS
2-FP-IS


SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

16
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

Appendix B. Database Scan Results
The  was used to scan the  databases.  % percent of all databases were scanned.

B.1 Database Scans: Inventory of Databases Scanned
Instruction: Indicate the databases that were scanned. For “Function,” indicate
the function that the database plays for the system (e.g., database image for enduser development, database for authentication records). Add additional rows as
necessary.
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 11 presents the database inventory scan results.
Table 11. Database Inventory Scan Results
IP Address

Hostname

Software /
Version

Function

Comment

B.2 Database Scans: Raw Scan Results
Instruction: Provide all database scan results generated by the scanner in a
readable format. Bundle all scan results into one zip file. Do not insert files that
require a scan license to read the file.
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 12 lists the files that are included.
Table 12. Raw Scan Results
Title of Document


SAR Version 0.1

Description

File Name
(Includes Extension)

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

17
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

Title of Document

File Name
(Includes Extension)

Description

B.3 Database Scans: Findings Discovered
Instruction: Summarize the Database scan assessment results in the following
table. Ensure that the scanner severity level is appropriately mapped to the risk
level ratings.
The number of reported findings from the scan results should match the combined
number of findings in Table 13 and Table 14.
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 13. Findings Discovered by Database Scanner
Risk Level

Database Scans

Critical
High
Moderate
Low
Total:

B.4 Database Scans: False Positive Reports
Instruction: Use the summary table to identify false positives that were generated
by the scanner. Use a separate row for each false positive reported. If one IP
address has multiple false positive reports, give each false positive its own row.
For each false positive reported, add an explanation as to why that finding is a
false positive. Add as many rows as necessary. The “FP” in the identifier number
refers to “False Positive” and the “DS” in the identifier number refers to
“Database Scan.”
[Delete this and all other instructions from your final version of this document.]
Table 14 identifies false positives that were generated by the database scanner.
Table 14. False Positives Generated by the Database Scanner
ID #

IP Address

Scanner Severity
Level

Finding

False Positive
Explanation

1-FP-DS
2-FP-DS


SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

18
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

ID #

IP Address

Scanner Severity
Level

Finding

False Positive
Explanation

3-FP-DS


SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

19
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

Appendix C. Web Application Scan Results
The  was used to scan the  web applications.  % of all web applications was scanned.
Instruction: Indicate the web applications that were scanned. For “Function,”
indicate the function that the web-facing application plays for the system (e.g.,
control panel to build virtual machines). Add additional rows as necessary.
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.]

C.1 Web Applications Scans: Inventory of Web Applications Scanned
Table 15 lists the web applications that were scanned and the function that the webapplication performs for the system.

Table 15. Inventory of Web Applications Scanned
Login URL

IP Address of
Login Host

Function

Comment

C.2 Web Applications Scans: Raw Scan Results
Instruction: Provide all web application scans results generated by the scanner in
a readable format. Bundle all scan results into one zip file. Do not insert files that
require a scan license to read the file.
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 lists the files that are included.
Table 16. Raw Scan Results
Title of Document


SAR Version 0.1

Description

File Name
(Includes Extension)

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

20
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

C.3 Web Application Scans: Findings Discovered
Instruction: Summarize the Web Application scan assessment results in the
following table. Ensure that the scanner severity level is appropriately mapped to
the risk level ratings.
The number of reported findings from the scan results should match the combined
number of findings in Table 13 and Table 14.
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 17. Findings Discovered by Web Application Scanner
Risk Level

Web Application Scans

Critical
High
Moderate
Low
Total:

C.4 Web Applications Scans: False Positive Reports
Instruction: Use the summary table to identify false positives that were generated
by the scanner. Use a separate row for each false positive reported. If one IP
address has multiple false positive reports, give each false positive its own row.
For each false positive reported, add an explanation as to why that finding is a
false positive. Add as many rows as necessary. The “FP” in the identifier number
refers to “False Positive” and the “WS” in the identifier number refers to “Web
Application Scan.”
[Delete this and all other instructions from your final version of this document.]
Table 18 identifies each false positive that was generated by the web applications scanner.
Table 18. False Positive Reports by Web Applications Scanner
ID #

IP Address

Scanner Severity
Level

Finding

False Positive
Explanation

1-FP-WS
2-FP-WS
3-FP-WS


SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

21
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

Appendix D. Penetration Test Report
Instruction: The results reported in this appendix should be components
identified in Section 2 of the Security and Privacy Controls Assessment Test Plan
and should include the OWASP Top 10 results specified in subsection 2.4.
If penetration test is completed by a separate assessment organization, the primary
security assessment organization must complete all sections of the SAR.
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 scope of this assessment was limited to the  solution,
including  components. The Auditor conducted testing of  activities from
the  via an attributable Internet connection.
Table 19 provides IP addresses and uniform resource locators (URL) for all the in-scope systems
at the beginning of the assessment.
Table 19. IP Addresses and URLs for In-Scope Systems
Application

IP/URL

OWASP Top 10

Penetration Test
Results

D.1 Penetration Test Report: Findings Discovered
Instruction: Summarize the Penetration Test results in the following table.
Ensure that the scanner severity level is appropriately mapped to the risk level
ratings.
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 20. Findings Discovered by Penetration Testing
Risk Level

Penetration Test Results

Critical
High
Moderate
Low

SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

22
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

Risk Level

Penetration Test Results

Total:


SAR Version 0.1

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

23
Report Publication Date

Sensitive and Confidential Information – For Official Use Only
Non-Exchange Entity Name (Acronym)

Appendix E. Penetration Test and Scan Results Summary
Instruction: Summarize the scan assessment results in the following table.
Ensure that the scanner severity level is appropriately mapped to the risk level
ratings.
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 21 is a summary of all scan assessment results appropriately mapped to the risk level
ratings.
Table 21. Summary of Scan Results
Risk Level

Infrastructure
Scans

Web Scans

DB Scans

Penetration
Test

Total

Critical
High
Moderate
Low
Total

Table 22 summarizes the total risk findings from penetration and scan testing.
Table 22. Total Risk Findings from Penetration and Scan Testing
Risk Level

Risks from Penetration and Scan Testing

Critical

Total Risks from Penetration
and Scan Testing

<#>

<#> (<#>% of Grand Total)

High

<#>

<#> (<#>% of Grand Total)

Moderate

<#>

<#> (<#>% of Grand Total)

Low

<#>

<#> (<#>% of Grand Total)

Total

<#>


SAR Version 0.1

<#>

CMS SAR Template v 3.2

Sensitive and Confidential Information – For Official Use Only

24
Report Publication Date


File Typeapplication/pdf
File TitleSecurity and Privacy Assessment Report Template
SubjectSecurity and Privacy Assessment Report, SAR, SAP, Security and Privacy, NEE, Non-Exchange Entity, CCIIO, Center for Consumer Inf
AuthorCenters for Medicare & Medicaid Services (CMS)
File Modified2023-10-27
File Created2023-10-13

© 2024 OMB.report | Privacy Policy