Bureau of the Public Debt
Areas for Improvement in Information Security Controls
Gao ID: GAO-06-522R March 16, 2006
In connection with fulfilling our requirement to audit the financial statements of the U.S. government, we audited and reported on the Schedules of Federal Debt Managed by the Bureau of the Public Debt (BPD) for the fiscal years ended September 30, 2005 and 2004. As part of these audits, we performed a review of the general and application information security controls over key BPD financial systems. This report presents the issues identified during our fiscal year 2005 testing of the general and application information security controls that support key BPD automated financial systems relevant to BPD's Schedule of Federal Debt. This report also includes the results of our follow-up on the status of BPD's corrective actions to address recommendations that were contained in our prior years' audits and open as of September 30, 2004. We also assessed the general and application information security controls over key BPD financial systems that the Federal Reserve Banks (FRB) maintain and operate on behalf of BPD. We will issue a separate report to the Board of Governors of the Federal Reserve System on the results of such testing.
Our fiscal year 2005 audit procedures identified opportunities to strengthen certain information security controls that support key BPD automated financial systems relevant to BPD's Schedule of Federal Debt. Specifically, our audit procedures identified 11 new general information security control issues that relate to access controls and system software. In the Limited Official Use Only report, we made nine recommendations to address these issues. Our follow-up on the status of BPD's corrective actions to address nine open recommendations related to eight general and application information security control issues identified in prior years' audits for which actions were not complete as of September 30, 2004, identified the following: (1) as of September 30, 2005, corrective action on seven of the nine recommendations had been completed; and (2) corrective action was in progress as of September 30, 2005, on the two remaining open recommendations, which relate to access controls and application controls.
Recommendations
Our recommendations from this work are listed below with a Contact for more information. Status will change from "In process" to "Open," "Closed - implemented," or "Closed - not implemented" based on our follow up work.
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GAO-06-522R, Bureau of the Public Debt: Areas for Improvement in Information Security Controls
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March 16, 2006:
The Honorable Van Zeck:
Commissioner, Bureau of the Public Debt:
Subject: Bureau of the Public Debt: Areas for Improvement in
Information Security Controls:
Dear Mr. Zeck:
In connection with fulfilling our requirement to audit the financial
statements of the U.S. government,[Footnote 1] we audited and reported
on the Schedules of Federal Debt Managed by the Bureau of the Public
Debt (BPD) for the fiscal years ended September 30, 2005 and
2004.[Footnote 2] As part of these audits, we performed a review of the
general and application information security controls over key BPD
financial systems.
As we reported in connection with our audit of the Schedules of Federal
Debt for the fiscal years ended September 30, 2005 and 2004, BPD
maintained, in all material respects, effective internal control
relevant to the Schedule of Federal Debt related to financial reporting
and compliance with applicable laws and regulations as of September 30,
2005, that provided reasonable assurance that misstatements, losses, or
noncompliance material in relation to the Schedule of Federal Debt
would be prevented or detected on a timely basis. We found matters
involving information security controls that we do not consider to be
reportable conditions[Footnote 3] but that nevertheless warrant BPD
management's attention and action. BPD mitigates the potential effect
of such issues with physical security measures, a program of monitoring
user and system activity, and compensating management and
reconciliation controls.
This report presents the results of our fiscal year 2005 testing of the
general and application information security controls that support key
BPD automated financial systems relevant to BPD's Schedule of Federal
Debt and the results of our follow-up on the status of BPD's corrective
actions to address recommendations that were contained in our prior
years' audits and open as of September 30, 2004. In a separately issued
Limited Official Use Only report, we communicated detailed information
regarding our findings to BPD management. We also assessed the general
and application information security controls over key BPD financial
systems that the Federal Reserve Banks (FRB) maintain and operate on
behalf of BPD. We will issue a separate report to the Board of
Governors of the Federal Reserve System on the results of such testing.
Results in Brief:
Our fiscal year 2005 audit procedures identified opportunities to
strengthen certain information security controls that support key BPD
automated financial systems relevant to BPD's Schedule of Federal Debt.
Specifically, our audit procedures identified 11 new general
information security control issues that relate to access controls and
system software. In the Limited Official Use Only report, we made nine
recommendations to address these issues.
Our follow-up on the status of BPD's corrective actions to address nine
open recommendations related to eight general and application
information security control issues identified in prior years' audits
for which actions were not complete as of September 30, 2004,
identified the following:
As of September 30, 2005, corrective action on seven of the nine
recommendations had been completed.
Corrective action was in progress as of September 30, 2005, on the two
remaining open recommendations, which relate to access controls and
application controls. We reaffirm our prior years' recommendations
related to these issues.
BPD provided comments on the detailed findings and recommendations in
the separately issued Limited Official Use Only report. In those
comments, the Commissioner of the Bureau of the Public Debt stated that
of the 11 recommendations, which include 2 from prior years, 5 have
been completely resolved, and the remaining 6 are in progress. The
Commissioner also stated that BPD intends to fully implement the
remaining recommendations before the end of this fiscal year.
Background:
The Department of the Treasury (Treasury) is authorized by Congress to
borrow money on the credit of the United States to fund federal
operations. Treasury is responsible for prescribing the debt
instruments and otherwise limiting and restricting the amount and
composition of the debt. BPD, an organizational entity within the
Fiscal Service of the Department of the Treasury, is responsible for
issuing and redeeming debt instruments, paying interest to investors,
and accounting for the resulting debt. In addition, BPD has been given
the responsibility for issuing Treasury securities to trust funds for
trust fund receipts not needed for current benefits and expenses.
As of September 30, 2005 and 2004, federal debt managed by BPD totaled
about $7.9 trillion and $7.4 trillion, respectively, for moneys
borrowed to fund the government's operations. These balances consisted
of approximately (1) $4.6 trillion and $4.3 trillion of debt held by
the public as of September 30, 2005 and 2004, respectively; and (2)
$3.3 trillion and $3.1 trillion of intragovernmental debt holdings as
of September 30, 2005 and 2004, respectively. Total interest expense on
federal debt managed by BPD for fiscal years 2005 and 2004 was about
$355 billion and $322 billion, respectively.
BPD relies on a number of interconnected financial systems and
electronic data to process and track the money that is borrowed and to
account for the securities it issues. Many of the FRBs provide fiscal
agent services on behalf of BPD, which primarily consist of issuing,
servicing, and redeeming Treasury securities held by the public and
handling the related transfers of funds. The FRB uses a number of
financial systems to process debt-related transactions throughout the
country.
Objectives, Scope, and Methodology:
Our objectives were to evaluate and test the general and application
information security controls over key financial management systems
maintained and operated by BPD relevant to the Schedule of Federal Debt
and to determine the status of corrective actions taken in response to
the recommendations in our prior years' reports for which actions were
not complete as of September 30, 2004. We use a risk-based, rotation
approach for testing general information security controls. Each
general information security control area is subjected to a full-scope
review, including testing, at least every 3 years. The general
information security control areas we review are defined in the Federal
Information System Controls Audit Manual[Footnote 4]. Areas considered
to be of higher risk are subject to more frequent review. Each key
application is subjected every year to a full-scope review.
To evaluate general and application information security controls, we
identified and reviewed BPD's information system general and
application information security control policies and procedures,
observed controls in operation, conducted tests of controls, and held
discussions with officials at the BPD data center to determine whether
controls were in place, adequately designed, and operating effectively.
The scope of our work for fiscal year 2005 as it relates to general
information security controls included following up on open
recommendations from our prior years' reports and reviewing entitywide
security program planning and management, access controls, and system
software controls. In addition, we performed certain testing of the BPD
distributed computing environment.
We performed full-scope application information security control
reviews of six key BPD applications to determine whether the
applications are designed to ensure that:
* access privileges (1) establish individual accountability and proper
segregation of duties, (2) limit the processing privileges of
individuals, and (3) prevent and detect inappropriate or unauthorized
activities;
* data are authorized, converted to an automated form, and entered into
the application accurately, completely, and promptly;
* data are properly processed by the computer and files are updated
correctly;
* erroneous data are captured, reported, investigated, and corrected;
and:
* files and reports generated by the application represent transactions
that actually occur and accurately reflect the results of processing,
and reports are controlled and distributed only to authorized users.
We performed a limited application information security control review
of one key BPD application to expand our understanding of this new
application. The scope of our work as it relates to application
information security controls also included following up on open
recommendations from our prior year's report for which actions were not
complete as of September 30, 2004. We also reviewed the application
information security control audit documentation from the work
performed by the Treasury Office of Inspector General's contractor on
another key BPD application.
Because the FRBs are integral to the operations of BPD, we assessed the
general information security controls over financial systems that the
FRBs maintain and operate relevant to the Schedule of Federal Debt. We
also evaluated application information security controls over six key
financial applications maintained and operated by the FRBs.
The evaluation and testing of certain information security controls
were performed by the independent public accounting (IPA) firm of
PricewaterhouseCoopers LLP. We agreed on the scope of the audit work,
monitored the IPA firm's progress, and reviewed the related audit
documentation to ensure that the findings were adequately supported. In
addition, our information systems auditors performed supplemental
testing of general and application information security controls at BPD
and followed up on the status of BPD corrective actions to address
certain open recommendations in our fiscal year 2004 report.
During the course of our work, we communicated our findings to BPD
management, who informed us that BPD has taken or plans to take
corrective action to address the control issues identified. We plan to
follow up on these matters during our audit of the fiscal year 2006
Schedule of Federal Debt.
We performed our work at the BPD data center from February 2005 through
October 2005. Our work was performed in accordance with U.S. generally
accepted government auditing standards. As noted earlier, we obtained
agency comments on the detailed findings and recommendations in a draft
of the separately issued Limited Official Use Only report. BPD's
comments are summarized in the Agency Comments and Our Evaluation
section of this report.
Assessment of BPD's Information Security Controls:
General information security controls are the structure, policies, and
procedures that apply to an entity's overall computer operations.
General information security controls establish the environment in
which application systems and controls operate. They include an
entitywide security management program, access controls, system
software controls, application software development and change
controls, segregation of duties, and service continuity controls. An
effective general information security control environment helps (1)
ensure that an adequate entitywide security management program is in
place; (2) protect data, files, and programs from unauthorized access,
modification, disclosure, and destruction; (3) limit and monitor access
to programs and files that control computer hardware and secure
applications; (4) prevent the introduction of unauthorized changes to
systems and applications software; (5) prevent any one individual from
controlling key aspects of computer-related operations; and (6) ensure
the recovery of computer processing operations in the event of a
disaster or other unexpected interruption.
Our fiscal year 2005 testing identified opportunities to strengthen
certain information security controls that support key BPD automated
financial systems relevant to BPD's Schedule of Federal Debt.
Specifically, our audit procedures identified 11 new general
information security control issues. Ten new general information
security control issues relate to access controls and one new general
information security control issue relates to system software. The
majority of the new issues involves controls pertaining to the
distributed computing environment.
Access controls are designed to limit or detect access to computer
programs, data, equipment, and facilities to protect these resources
from unauthorized modification, disclosure, loss, or impairment. Such
controls include logical access controls and physical access controls.
Logical access controls involve the use of computer hardware and
software to prevent or detect unauthorized access by requiring users to
input unique user identifications (ID), passwords, or other identifiers
that are linked to predetermined access privileges. Logical access
controls restrict the access of legitimate users to the specific
systems, programs, and files they need to conduct their work and
prevent unauthorized users from gaining access to computer resources.
Physical access controls involve the use of locks, guards, badges,
alarms, and similar measures (used alone or in combination) to prevent
intentional or unintentional loss or impairment to computer hardware
and software and to the buildings and rooms where they are housed.
System software coordinates and helps control the input, processing,
output, and data storage associated with all of the applications that
run on a system. System software includes operating system software,
system utilities, file maintenance software, security software, data
communications systems, and database management systems. Controls over
access to and modifications of system software are essential to protect
the overall integrity and reliability of information systems.
In a separately issued Limited Official Use Only report, we
communicated detailed information regarding our findings to BPD
management and made nine recommendations to address the access control
and system software issues.
Our follow-up on the status of BPD's corrective actions to address nine
open recommendations related to eight general and application
information security control issues identified in prior years' audits
for which actions were not complete as of September 30, 2004, found the
following:
As of September 30, 2005, corrective action on seven of the nine
recommendations had been completed.
Corrective action was in progress as of September 30, 2005, on the two
remaining open recommendations, which relate to access controls and
application controls. We reaffirm our prior years' recommendations
related to these issues.
None of our findings pose significant risks to the BPD financial
systems. In forming our conclusions, we considered the mitigating
effects of physical security measures, a program of monitoring user and
system activity, and reconciliation controls that are designed to
detect potential irregularities or improprieties in financial data or
transactions. Nevertheless, these findings warrant management's
attention and action to limit the risk of unauthorized access,
disclosure, loss, or impairment; modification of sensitive data and
programs; and disruption of critical operations.
Assessment of FRB Information Security Controls:
Because the FRBs are integral to the operations of BPD, we assessed the
general and application information security controls over key
financial systems maintained and operated by the FRBs on behalf of BPD.
We will issue a separate report to the Board of Governors of the
Federal Reserve System on the results of such testing.
Conclusion:
BPD has made significant progress in addressing open recommendations
from our prior years' audits and is taking corrective action to address
the two remaining unresolved issues. We therefore reaffirm our two
recommendations related to these issues.
Our fiscal year 2005 audit identified 11 new general information
security control issues that relate to access controls and system
software for which we are making 9 recommendations. BPD informed us
that it has taken or plans to take corrective action to address all
issues identified.
Recommendation for Executive Action:
We recommend that the Commissioner of the Bureau of the Public Debt
direct the appropriate BPD officials to implement the nine new detailed
recommendations set forth in the separately issued Limited Official Use
Only version of this report.
Agency Comments and Our Evaluation:
BPD provided comments on the detailed findings and recommendations in
the Limited Official Use Only version. In those comments, the
Commissioner of the Bureau of the Public Debt stated that of the 11
recommendations, which include 2 from prior years, 5 have been
completely resolved, and the remaining 6 are in progress. The
Commissioner also stated that BPD intends to fully implement the
remaining recommendations before the end of this fiscal year. We plan
to follow up on these matters during our audit of the fiscal year 2006
Schedule of Federal Debt.
In the separately issued Limited Official Use Only report, we noted
that the head of a federal agency is required by 31 U.S.C. 720 to
submit a written statement on actions taken on our recommendations to
the Senate Committee on Homeland Security and Governmental Affairs and
to the House Committee on Government Reform not later than 60 days
after the date of the Limited Official Use Only report. A written
statement must also be sent to the House and Senate Committees on
Appropriations with the agency's first request for appropriations made
more than 60 days after the date of that report. In the Limited
Official Use Only report, we also requested a copy of your responses.
We are sending copies of this report to the Chairmen and Ranking
Minority Members of the Senate Committee on Homeland Security and
Governmental Affairs; the Subcommittee on Federal Financial Management,
Government Information, and International Security, Senate Committee on
Homeland Security and Governmental Affairs; the Subcommittee on
Transportation, Treasury, the Judiciary, Housing and Urban Development,
and Related Agencies, Senate Committee on Appropriations; the House
Committee on Government Reform; the Subcommittee on Government
Management, Finance, and Accountability, House Committee on Government
Reform; and the Subcommittee on Transportation, Treasury, and Housing
and Urban Development, The Judiciary, District of Columbia, House
Committee on Appropriations. We are also sending copies of this report
to the Secretary of the Department of the Treasury, the Inspector
General of the Department of the Treasury, and the Director of the
Office of Management and Budget. Copies will also be made available to
others upon request. In addition, the report will be available at no
charge on GAO's Web site at http://www.gao.gov.
If you have any questions regarding this report, please contact me at
(202) 512-3406 or engelg@gao.gov. Other key contributors to this
assignment were David B. Hayes and Dawn B. Simpson, Assistant
Directors; and Angela M. Bell, Bruce E. Cain, and Mickie E. Gray.
Sincerely yours,
Signed by:
Gary T. Engel:
Director:
Financial Management and Assurance:
(198417):
FOOTNOTES
[1] 31 U.S.C. § 331(e).
[2] GAO, Financial Audit: Bureau of the Public Debt's Fiscal Years 2005
and 2004 Schedules of Federal Debt, GAO-06-169 (Washington, D.C.: Nov.
7, 2005).
[3] Reportable conditions are matters coming to our attention that, in
our judgment, should be communicated because they represent significant
deficiencies in the design or operation of internal control, which
could adversely affect the organization's ability to meet the
objectives of reliable financial reporting and compliance with
applicable laws and regulations.
[4] GAO, Federal Information System Controls Audit Manual, GAO/AIMD-
12.19.6 (Washington, D.C.: January 1999).