U.S. OFFICE OF PERSONNEL MANAGEMENT
OFFICE OF THE INSPECTOR GENERAL
OFFICE OF AUDITS
Final Audit Report
AUDIT OF THE INFORMATION SYSTEMS
GENERAL AND APPLICATION CONTROLS AT
BLUE CROSS BLUE SHIELD OF NEBRASKA
Report Number 1A-10-53-17-042
April 17, 2018
EXECUTIVE SUMMARY
Audit of the Information Systems General and Application Controls at
Blue Cross Blue Shield of Nebraska
Report No. 1A-10-53-17-042 April 17, 2018
Why Did We Conduct the Audit? What Did We Find?
Blue Cross Blue Shield of Nebraska Our audit of the IT security controls of BCBSNE determined that:
(BCBSNE) contracts with the U.S.
Office of Personnel Management as x BCBSNE has established an adequate security management
part of the Federal Employees program.
Health Benefits Program (FEHBP).
x BCBSNE has adequate physical access controls for its facilities and
data centers. Furthermore, BCBSNE has adequate logical access
The objectives of this audit were to
controls protecting sensitive data in its network environment.
evaluate controls over the
confidentiality, integrity, and
x BCBSNE does not have adequate security controls in place within its
availability of FEHBP data internal network to manage traffic between .
processed and maintained in
BCBSNE’s information technology x BCBSNE does not conduct routine vulnerability scanning of its web
(IT) environment. application. Furthermore, BCBSNE does not have a formal process
to ensure that vulnerabilities identified from vulnerability scanning
What Did We Audit? are remediated in a timely manner.
The scope of this audit centered on x BCBSNE has not documented security configuration standards for
the information systems used by all of the operating platforms in its network environment.
BCBSNE to process and store data Furthermore, BCBSNE’s subsidiary, , does not maintain
security configuration standards for the mainframe that hosts
related to insurance claims for
BCBSNE’s claims processing system.
FEHBP members.
x BCBSNE has not tested the connection with ’s backup data
center in the event that the ’s primary data center becomes
unavailable to process FEHBP claims.
x BCBSNE has implemented many controls in its claims adjudication
process to ensure that FEHBP claims are processed accurately.
______________________
Michael R. Esser
Assistant Inspector General
for Audits
i
ABBREVIATIONS
BCBSND Blue Cross Blue Shield of North Dakota
BCBSNE Blue Cross Blue Shield of Nebraska
CFR Code of Federal Regulations
FEHBP Federal Employees Health Benefits Program
FEP Federal Employee Program
FISCAM Federal Information Security Controls Audit Manual
GAO U.S. Government Accountability Office
IT Information Technology
LAN Local Area Network
NIST SP National Institute of Standards and Technology’s Special Publication
OIG Office of the Inspector General
OMB U.S. Office of Management and Budget
OPM U.S. Office of Personnel Management
ii
TABLE OF CONTENTS
Page
EXECUTIVE SUMMARY ........................................................................................ i
ABBREVIATIONS ..................................................................................................... ii
I. BACKGROUND ..........................................................................................................1
II. OBJECTIVES, SCOPE, AND METHODOLOGY ..................................................2
III. AUDIT FINDINGS AND RECOMMENDATIONS.................................................5
A. Security Management .............................................................................................5
B. Access Controls .......................................................................................................5
C. Network Security .....................................................................................................6
D. Configuration Management .....................................................................................9
E. Contingency Planning............................................................................................12
F. Claims Adjudication ..............................................................................................13
APPENDIX: BCBSNE’s February 5, 2018, response to the draft audit report, issued
December 13, 2017.
REPORT FRAUD, WASTE, AND MISMANAGEMENT
I. BACKGROUND
IV. MAJOR CONTRIBUTORS TO THIS REPORT
This final report details the findings, conclusions, and recommendations resulting from the audit
of general and application controls over the information systems responsible for processing
Federal Employees Health Benefits Program (FEHBP) data by Blue Cross Blue Shield of
Nebraska (BCBSNE).
The audit was conducted pursuant to FEHBP contract CS 1039; 5 U.S.C. Chapter 89; and 5 Code
of Federal Regulations (CFR) Chapter 1, Part 890. The audit was performed by the U.S. Office
of Personnel Management’s (OPM) Office of the Inspector General (OIG), as established by the
Inspector General Act of 1978, as amended.
The FEHBP was established by the Federal Employees Health Benefits Act, enacted on
September 28, 1959. The FEHBP was created to provide health insurance benefits for Federal
employees, annuitants, and qualified dependents. The provisions of the Act are implemented by
OPM through regulations codified in Title 5, Chapter 1, Part 890 of the CFR. Health insurance
coverage is made available through contracts with various carriers that provide service benefits,
indemnity benefits, or comprehensive medical services.
This was our first audit of BCBSNE’s information technology (IT) general and application
controls. All BCBSNE personnel that worked with the auditors were helpful and open to ideas
and suggestions. They viewed the audit as an opportunity to examine practices and to make
changes or improvements as necessary. Their positive attitude and helpfulness throughout the
audit was greatly appreciated.
1 Report No. 1A-10-53-17-042
II.
IV. OBJECTIVES, SCOPE, ANDTO
MAJOR CONTRIBUTORS METHODOLOGY
THIS REPORT
OBJECTIVES
The objectives of this audit were to evaluate controls over the confidentiality, integrity, and
availability of FEHBP data processed and maintained in BCBSNE’s IT environments. We
accomplished these objectives by reviewing the following areas:
x Security management;
x Access controls;
x Network security;
x Configuration management;
x Contingency planning; and
x Application controls specific to BCBSNE’s claims processing system.
SCOPE AND METHODOLOGY
This performance audit was conducted in accordance with generally accepted government
auditing standards issued by the Comptroller General of the United States. Accordingly, we
obtained an understanding of BCBSNE’s internal controls through interviews and observations,
as well as inspection of various documents, including information technology and other related
organizational policies and procedures. This understanding of BCBSNE’s internal controls was
used in planning the audit by determining the extent of compliance testing and other auditing
procedures necessary to verify that the internal controls were properly designed, placed in
operation, and effective.
The scope of this audit centered on the information systems used by BCBSNE to process
medical insurance claims and/or store the data of FEHBP members. The business processes
reviewed are primarily located in Omaha, Nebraska and Fargo, North Dakota.
BCBSNE’s claims processing application is hosted by , a jointly-owned subsidiary of
BCBSNE and Blue Cross Blue Shield of North Dakota (BCBSND). is responsible for
maintaining the mainframe on which the claims processing application resides. The operations
of were considered within the scope of this audit.
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The onsite portion of this audit was performed in June and July of 2017. We completed
additional audit work before and after the on-site visits at our office in Washington, D.C. The
findings, recommendations, and conclusions outlined in this report are based on the status of
information system general and application controls in place at BCBSNE as of July 2017.
In conducting our audit, we relied to varying degrees on computer-generated data provided by
BCBSNE. Due to time constraints, we did not verify the reliability of the data used to complete
some of our audit steps, but we determined that it was adequate to achieve our audit objectives.
However, when our objective was to assess computer-generated data, we completed audit steps
necessary to obtain evidence that the data was valid and reliable.
In conducting this review we:
x Gathered documentation and conducted interviews;
x Reviewed BCBSNE’s business structure and environment;
x Performed a risk assessment of BCBSNE’s information systems environment and
applications, and prepared an audit program based on the assessment and the U.S.
Government Accountability Office’s (GAO) Federal Information System Controls Audit
Manual (FISCAM); and
x Conducted various compliance tests to determine the extent to which established controls and
procedures are functioning as intended. As appropriate, we used judgmental sampling in
completing our compliance testing.
Various laws, regulations, and industry standards were used as a guide to evaluating BCBSNE’s
control structure. These criteria include, but are not limited to, the following publications:
x Title 48 of the Code of Federal Regulations;
x U.S. Office of Management and Budget (OMB) Circular A-130, Appendix III;
x OMB Memorandum 07-16, Safeguarding Against and Responding to the Breach of
Personally Identifiable Information;
x Control Objectives for Information and Related Technologies 5: A Business Framework for
the Governance and Management of Enterprise IT;
3 Report No. 1A-10-53-17-042
x GAO’s FISCAM;
x National Institute of Standards and Technology’s Special Publication (NIST SP) 800-12,
Revision 1, An Introduction to Information Security;
x NIST SP 800-14, Generally Accepted Principles and Practices for Securing Information
Technology Systems;
x NIST SP 800-30, Revision 1, Guide for Conducting Risk Assessments;
x NIST SP 800-34, Revision 1, Contingency Planning Guide for Federal Information Systems;
x NIST SP 800-41, Revision 1, Guidelines on Firewalls and Firewall Policy;
x NIST SP 800-44, Version 2, Guidelines on Securing Public Web Servers;
x NIST SP 800-53, Revision 4, Security and Privacy Controls for Federal Information Systems
and Organizations; and
x NIST SP 800-61, Revision 2, Computer Security Incident Handling Guide.
COMPLIANCE WITH LAWS AND REGULATIONS
In conducting the audit, we performed tests to determine whether BCBSNE’s practices were
consistent with applicable standards. While generally compliant with respect to the items tested,
BCBSNE was not in complete compliance with all standards, as described in section III of this
report.
4 Report No. 1A-10-53-17-042
III. AUDIT FINDINGS AND RECOMMENDATIONS
A. SECURITY MANAGEMENT
The security management component of this audit involved an
examination of the policies and procedures that are the foundation of BCBSNE maintains a
BCBSNE’s overall IT security program. We evaluated BCBSNE’s series of thorough IT
ability to develop security policies, manage risk, assign security- security policies and
related responsibility, and monitor the effectiveness of various procedures.
system-related controls.
BCBSNE has documented policies that outline its enterprise security management framework.
BCBSNE has developed an adequate risk management methodology and creates remediation
plans to address weaknesses identified in risk assessments. BCBSNE also has implemented
human resources policies and procedures related to hiring, training, transferring, and
terminating employees.
Nothing came to our attention to indicate that BCBSNE does not have an adequate security
management program.
B. ACCESS CONTROLS
Access controls are the policies, procedures, and techniques used to prevent or detect
unauthorized physical or logical access to sensitive resources.
We examined the physical access controls at BCBSNE’s facilities and data centers.
Additionally, we reviewed physical access and environmental controls at data center
that hosts BCBSNE’s claims processing application. We also examined the logical access
controls protecting sensitive data in BCBSNE’s network environment and claims processing
related applications.
The access controls observed during this audit included, but were not limited to:
x Procedures for appropriately granting, adjusting, and removing physical access to facilities
and data centers;
5 Report No. 1A-10-53-17-042
x Procedures for appropriately granting, adjusting, and removing logical access to information
systems; and
x Robust physical and environmental controls within BCBSNE’s and BCBSND’s data centers.
Nothing came to our attention to indicate that BCBSNE does not have adequate access controls.
C. NETWORK SECURITY
Network security includes the policies and controls used to prevent or monitor unauthorized
access, misuse, modification, or denial of a computer network and network-accessible resources.
We evaluated BCBSNE’s controls related to network design, data protection, and systems
monitoring. We also reviewed the results of several automated vulnerability scans performed
during this audit.
We observed the following controls in place:
x Preventive controls at the network perimeter;
x Security event monitoring throughout the network; and
x A documented incident response program.
The following sections document several opportunities for improvement related to BCBSNE’s
network security controls.
1) Internal Network Segmentation
Firewalls are used at key locations on BCBSNE’s network in
order to control connections with systems outside of its BCBSNE does not have
network. Virtual LANs are used to internally segment adequate security controls
portions of BCBSNE’s network. However, virtual LAN’s to segregate
alone are not an adequate security control to manage traffic segments.
between different portions of a network.
NIST SP 800-41, Revision 1, advises that, “Focusing attention solely on external threats
leaves the network wide open to attacks from within. These threats may not come directly
from insiders, but can involve internal hosts infected by malware or otherwise compromised
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by external attackers. Important internal systems should be placed behind internal firewalls.”
Failure to segregate segments increases the risk that a system could
be compromised and allow access to sensitive servers and data.
Recommendation 1
We recommend that BCBSNE implement security controls (e.g., firewalls) within its internal
network in order to adequately segregate sensitive resources from systems.
BCBSNE Response:
“BCBSNE agrees with the recommendation. Steps have been taken to create a roadmap to
further separate sensitive resources from systems. This initiative will be
completed by June 30, 2019.”
OIG Comment:
As a part of the audit resolution process, we recommend that BCBSNE provide OPM’s
Healthcare and Insurance Audit Resolution Group with evidence when it has fully
implemented this recommendation. This statement applies to subsequent recommendations
in this audit report that BCBSNE agrees to implement.
2) Web Application Scanning
BCBSNE maintains a public-facing member web portal. When the application was first
developed, BCBSNE performed an automated scan on the web application to test for
vulnerabilities. BCBSNE recently implemented a policy requiring a vulnerability scan after
any significant change is made to the web application. However, if there are no changes, the
web application is not subject to any additional security testing.
NIST SP 800-44, Version 2, states that “Periodic security testing of public Web servers is
critical.” NIST SP 800-44, Version 2, also states that “Vulnerability scanning assists a Web
server administrator in identifying vulnerabilities and verifying whether the existing security
measures are effective.” Failure to periodically test a web application for vulnerabilities
increases the risk that unidentified weaknesses could be exploited.
7 Report No. 1A-10-53-17-042
Recommendation 2
We recommend that BCBSNE update its scanning process to ensure that credentialed
vulnerability scans are routinely conducted on web applications.
BCBSNE Response:
“BCBSNE agrees with this recommendation. BCBSNE has reviewed and updated its
policy and procedure, verifying that credentialed vulnerability scanning occurs on a
quarterly basis, and/or after significant changes to the environment on October 31, 2017.”
OIG Comment:
In response to the draft audit report, we received an updated Vulnerability Assessment
Procedure that mandates quarterly vulnerability scans on web applications. We also
reviewed the results of a recent web application vulnerability scan. No further action is
required.
3) Vulnerability Management Program
BCBSNE conducts credentialed vulnerability scans on all servers in its network environment
on a routine basis. Although the results of the scans are reviewed by security personnel,
BCBSNE does not have a process in place to track the status of vulnerabilities identified by
the scans to ensure they are remediated in a timely manner.
FISCAM states that, “When weaknesses are identified, the related risks should be reassessed,
appropriate corrective or remediation actions taken, and follow-up monitoring performed to
make certain that corrective actions are effective.” Additionally, NIST SP 800-53, Revision
4, states that organizations must remediate legitimate vulnerabilities identified in information
systems and hosted applications.
Failure to remediate vulnerabilities in a timely manner increases the risk that bad actors could
exploit system weaknesses for malicious purposes.
Recommendation 3
We recommend that BCBSNE implement a process to ensure that vulnerabilities identified
from vulnerability scanning are remediated in a timely manner.
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BCBSNE Response:
“BCBSNE agrees with this recommendation. BCBSNE will formalize the processes to
identify, coordinate, and track remediation of vulnerabilities identified during vulnerability
scanning. The target date for completion is June 30, 2018.”
D. CONFIGURATION MANAGEMENT
Configuration management involves the policies and procedures
BCBSNE and
used to ensure that systems are configured according to a
do not have documented
consistent and approved risk-based standard. We evaluated
security configuration
BCBSNE’s management of the configuration of its servers and
standards for all
databases. Our review found the following controls in place:
operating platforms in
use.
x Documented configuration management policies;
x System configuration changes are documented; and
x A formal change approval process.
The sections below document areas for improvement related to BCBSNE’s configuration
management controls.
1) Security Configuration Standards
BCBSNE has documented security configuration standards for most of its network
environment. The security configuration standards were developed using Center for Internet
Security benchmarks as guidance. However, approved configuration standards have not been
documented for all of the operating platforms in BCBSNE’s network environment.
Furthermore, BCBSNE’s subsidiary, , does not maintain configuration standards for
the mainframe that hosts the BCBSNE claims processing system.
NIST SP 800-53, Revision 4, states that an organization should establish and document
“configuration settings for information technology products employed within the information
system . . . that reflect the most restrictive mode consistent with operational
requirements . . . .”
In addition, NIST SP 800-53, Revision 4, states that an organization must develop,
document, and maintain a current baseline configuration of the information system.
9 Report No. 1A-10-53-17-042
Failure to establish approved system configuration settings increases the risk that the system
may not be configured in a secure manner.
Recommendation 4
We recommend that BCBSNE document approved security configuration standards for all
operating system platforms and databases deployed in its technical environment.
BCBSNE Response:
“BCBSNE agrees with this recommendation. Security configuration standards have been
updated, approved, and implemented for technical assets used on BCBSNE enterprise
networks, to include Operating System (OS) platforms and databases deployed throughout
the technical environment as of December 31, 2017.”
OIG Comment:
In response to the draft audit report, we received approved security configuration standards
for all but one operating system. We recommend that BCBSNE provide OPM’s Healthcare
and Insurance Audit Resolution Group with the approved security configuration standard for
the remaining operating system in BCBSNE’s network environment.
Recommendation 5
We recommend that BCBSNE ensure that document approved security
configuration standards for its mainframe.
BCBSNE Response:
“BCBSNE agrees with this recommendation. has developed a security
configuration standard based on a Defense Information Systems Agency (DISA)
Mainframe Product Security Requirements Guide as of January 15, 2018.”
2) Security Configuration Auditing
As noted above, BCBSNE and have not documented approved security
configuration standards for all operating platforms and databases deployed in their technical
environments. Without approved security configuration standards BCBSNE and
10 Report No. 1A-10-53-17-042
cannot effectively audit their system’s security settings (i.e., there are no approved settings to
which to compare the actual settings).
NIST SP 800-53, Revision 4, states that an organization must monitor and control “changes
to the configuration settings in accordance with organizational policies and procedures.”
FISCAM requires “Current configuration information [to] be routinely monitored for
accuracy. Monitoring should address the … baseline and operational configuration of the
hardware, software, and firmware that comprise the information system.” Failure to
implement a configuration compliance auditing program increases the risk that servers and
the mainframe are not configured appropriately and left undetected can create a potential
gateway for unauthorized access or malicious activity.
Recommendation 6
We recommend that BCBSNE implement a process to routinely audit the configuration
settings of servers to ensure they are in compliance with the approved configuration
standards. Note – this recommendation cannot be implemented until the controls from
Recommendation 4 are in place.
BCBSNE Response:
“BCBSNE agrees with this recommendation. BCBSNE will implement technical solutions
and complementary procedures to allow for scanning of the BCBSNE technical
environment to confirm adherence to accepted security configuration standards. The
target date for completion is June 30, 2018.”
Recommendation 7
We recommend that BCBSNE ensure that implement a process to routinely audit
the configuration settings of the mainframe to ensure it is in compliance with the approved
configuration standards. Note – this recommendation cannot be implemented until the
controls from Recommendation 5 are in place.
BCBSNE Response:
“BCBSNE agrees with this recommendation. has completed the purchase and
the implementation of a compliance monitoring software application as of January 31,
2018. The software will be utilized by to assess the security of the mainframe
11 Report No. 1A-10-53-17-042
environment and compare compliance to the mainframe security configuration standard
noted in the response for recommendation 6.”
E. CONTINGENCY PLANNING
Contingency planning includes the policies and procedures that BCBSNE and
ensure adequate availability of information systems, data, and have not tested the
business processes. We reviewed the following elements of connection with the
BCBSNE’s contingency planning program to determine whether disaster recovery site for
controls are in place to prevent or minimize interruptions to its claims processing
business operations when disruptive events occur: application.
x Disaster recovery plan (e.g., recovery of hardware and software infrastructure);
x Business continuity plan (e.g., people and business processes);
x Contingency plan tests; and
x Emergency response procedures.
We determined that the contingency planning documentation contained the critical elements
suggested by NIST SP 800-34, Revision 1, “Contingency Planning Guide for Federal
Information Systems.” BCBSNE has identified and prioritized the systems and resources that
are critical to business operations, and has developed detailed procedures to recover those
systems and resources. However, we noted one opportunity for improvement related to
BCBSNE’s contingency planning program.
1) Alternative Processing Site Connection
As mentioned in the scope and methodology section of this report, hosts the claims
processing application that BCBSNE uses to process FEHBP claims. contracts
with another vendor, , to host a recovery site for the claims processing application in
the event that ’s facility and resources are unavailable. A network connection has
been established between and BCBSNE in the event that is unavailable.
However, the network connection between BCBSNE and has not been tested in order
to ensure that BCBSNE has the ability to process Federal Employee Program (FEP) claims in
the event that a network connection to becomes unavailable.
12 Report No. 1A-10-53-17-042
NIST SP 800-53, Revision 4, states, “The organization prepares the alternate processing site
so that the site is ready to be used as the operational site supporting essential missions and
business functions.” Furthermore, NIST SP 800-53, Revision 4, states, “The organization
includes a full recovery and reconstitution of the information system to a known state as part
of contingency plan testing.”
Failure to test the connection between BCBSNE and increases the risk that BCBSNE
will not meet its recovery time objectives for critical business functions if ’s facility
and resources become unavailable.
Recommendation 8
We recommend that BCBSNE, , and conduct a functional disaster recovery
test of the network connection between BCBSNE and to ensure that business
operations at BCBSNE can continue in the event that ’s claims processing
application is unavailable.
BCBSNE Response:
“BCBSNE, , and will conduct a functional disaster recovery test of the
network connection between BCBSNE and to ensure that business operations at
BCBSNE can continue in the event that ’s claims processing application is
unavailable. This test will be completed by April 30, 2018.”
F. CLAIMS ADJUDICATION
The following sections detail our review of the applications and business processes supporting
BCBSNE’s claims adjudication process. BCBSNE prices and adjudicates claims using a locally
operated claims processing system maintained by and then through the Blue Cross
Blue Shield Association’s nationwide FEP Direct claims processing system. We reviewed the
following processes related to the claims adjudication process: application configuration
management, claims processing, and provider debarment.
1) Application Configuration Management
We evaluated the policies and procedures governing application development and change
control of BCBSNE’s claims processing systems.
13 Report No. 1A-10-53-17-042
BCBSNE and have implemented policies and procedures related to application
configuration management, and have also adopted a system development life cycle
methodology that personnel follow during routine software modifications. We observed the
following controls related to testing and approval of software modifications:
x Policies and procedures that allow modifications to be tracked throughout the change
process;
x Unit, system, and user acceptance testing are conducted in accordance with a documented
testing strategy; and
x A group independent from the software developers moves code between development
and production environments to ensure separation of duties.
Nothing came to our attention to indicate that BCBSNE and have not implemented
adequate controls related to the application configuration management process.
2) Claims Processing System
We evaluated the business process controls associated with BCBSNE’s claims processing
system that ensure the completeness, accuracy, and confidentiality of transactions and data.
We determined that BCBSNE has implemented policies and procedures to help ensure that:
x Claims are properly input and tracked to ensure timely processing;
x Claims are monitored as they are processed through the system with real time tracking of
the system’s performance; and
x Claims scheduled for payment are actually paid.
Nothing came to our attention to indicate that BCBSNE has not implemented adequate
controls over its claims processing systems.
3) Debarment
BCBSNE has adequate procedures for updating its claims system with debarred provider
information. BCBSNE is notified by the Blue Cross Blue Shield Association that an update
14 Report No. 1A-10-53-17-042
to the OPM OIG debarment list is available. BCBSNE personnel review the list to determine
if any debarred providers have active contracts with BCBSNE. If an active provider is
determined to be debarred, the provider is flagged in the FEP Direct system, which will cause
any incoming claims to defer for further review. Furthermore, an email is sent to
to request termination of the debarred provider in the local claims processing system.
BCBSNE adheres to the OPM OIG debarment guidelines to include initial member
notification, a 15-day grace period, and then denial of subsequent claims.
Nothing came to our attention to indicate that BCBSNE has not implemented adequate
controls over the debarment process.
4) Application Controls Testing
We conducted a test of BCBSNE’s claims adjudication application to validate the system’s
processing controls. The exercise involved processing test claims designed with inherent
flaws and evaluating the manner in which BCBSNE’s system adjudicated the claims. Our
test results did not identify any issues.
15 Report No. 1A-10-53-17-042
APPENDIX
February 5, 2018
, Auditor-in-Charge
Claims & IT Audits Group,
U.S. Office of Personnel Management (OPM)
1900 E Street, Room 6400
Washington, D.C. 20415-1100 Federal Employee Program
1310 G Street, N.
Washington, D.C. 20005
202.942.1000
Fax 202.942.1125
Reference: OPM DRAFT IT AUDIT REPORT
Blue Cross Blue Shield of Nebraska (BCBSNE)
Audit Report Number 1A-10-53-17-042
(Dated December 13, 2017)
The following represents the Plan’s response as it relates to the recommendations
included in the draft report.
A. SECURITY MANAGEMENT
No recommendation noted.
B. ACCESS CONTROLS
No recommendation noted.
C. NETWORK SECURITY
1. Internal Network Segmentation
Recommendation 1
We recommend that BCBSNE segregate its internal network in order to separate
sensitive resources from systems.
Plan Response
BCBSNE agrees with the recommendation. Steps have been taken to create a
roadmap to further separate sensitive resources from systems. This
Report No. 1A-10-53-17-042
initiative will be completed by June 30, 2019.
2. Web Application Scanning
Recommendation 2
We recommend that BCBSNE update its scanning process to ensure that
credentialed vulnerability scans are routinely conducted on web applications.
Plan Response
BCBSNE agrees with this recommendation. BCBSNE has reviewed and updated its
policy and procedure, verifying that credentialed vulnerability scanning occurs on a
quarterly basis, and/or after significant changes to the environment on October 31,
2017.
3. Vulnerability Management Program
Recommendation 3
We recommend that BCBSNE implement a process to ensure that vulnerabilities
identified from vulnerability scanning are remediated in a timely manner.
Plan Response
BCBSNE agrees with this recommendation. BCBSNE will formalize the
processes to identify, coordinate, and track remediation of vulnerabilities
identified during vulnerability scanning. The target date for completion is June
30, 2018.
D. CONFIGURATION MANAGEMENT
1. Security Configuration Standards
Recommendation 4
We recommend that BCBSNE document approved security configuration standards
for all operating system platforms and databases deployed in its technical
environment.
Plan Response
BCBSNE agrees with this recommendation. Security configuration standards have
been updated, approved, and implemented for technical assets used on BCBSNE
Report No. 1A-10-53-17-042
enterprise networks, to include Operating System (OS) platforms and databases
deployed throughout the technical environment as of December 31, 2017.
Recommendation 5
We recommend that BCBSNE ensure that document approved security
configuration standards for its mainframe.
Plan Response
BCBSNE agrees with this recommendation. has developed a security
configuration standard based on a Defense Information Systems Agency (DISA)
Mainframe Product Security Requirements Guide as of January 15, 2018.
2. Security Configuration Auditing
Recommendation 6
We recommend that BCBSNE implement a process to routinely audit the
configuration settings of servers to ensure they are in compliance with the approved
configuration standards.
Note – this recommendation cannot be implemented until the controls from
Recommendation 5 are in place.
Plan Response
BCBSNE agrees with this recommendation. BCBSNE will implement technical
solutions and complementary procedures to allow for scanning of the BCBSNE
technical environment to confirm adherence to accepted security configuration
standards. The target date for completion is June 30, 2018.
Recommendation 7
We recommend that BCBSNE ensure that implement a process to
routinely audit the configuration settings of the mainframe to ensure it is in
compliance with the approved configuration standards.
Note – this recommendation cannot be implemented until the controls from
Recommendation 6 are in place.
Plan Response
BCBSNE agrees with this recommendation. has completed the purchase
and the implementation of a compliance monitoring software application as of
Report No. 1A-10-53-17-042
January 31, 2018. The software will be utilized by to assess the security of
the mainframe environment and compare compliance to the mainframe security
configuration standard noted in the response for recommendation 6.
E. CONTINGENCY PLANNING
1. Alternative Processing Site Connection
Recommendation 8
We recommend that BCBSNE, , and conduct a functional disaster
recovery test of the network connection between BCBSNE and to ensure that
business operations at BCBSNE can continue in the event that ’s claims
processing application is unavailable.
Plan Response
BCBSNE, , and will conduct a functional disaster recovery test of the
network connection between BCBSNE and to ensure that business
operations at BCBSNE can continue in the event that ’s claims processing
application is unavailable. This test will be completed by April 30, 2018.
F. Claims Adjudication
No recommendation noted.
We appreciate the opportunity to provide our response to each of the recommendations
in this report and request that our comments be included in their entirety and are made
a part of the Final Audit Report. If you have any questions, please contact me at
or at .
Sincerely,
Executive Director, FEP Program Integrity
cc: , OPM
, FEP
Report No. 1A-10-53-17-042
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and wasteful practices, fraud, and
mismanagement related to OPM programs
and operations. You can report allegations to
us in several ways:
By Internet: http://www.opm.gov/our-inspector-general/hotline-to-
report-fraud-waste-or-abuse
By Phone: Toll Free Number: (877) 499-7295
Washington Metro Area: (202) 606-2423
By Mail: Office of the Inspector General
U.S. Office of Personnel Management
1900 E Street, NW
Room 6400
Washington, DC 20415-1100
Audit of the Information Systems General and Application Controls at Blue Cross Blue Shield of Nebraska
Published by the Office of Personnel Management, Office of Inspector General on 2018-04-17.
Below is a raw (and likely hideous) rendition of the original report. (PDF)