Chairman Tauzin

Prepared Witness Testimony

The House Committee on Energy and Commerce

W.J. "Billy" Tauzin, Chairman

Link to Committee Tip Line:  Fight Waste, Fraud and Abuse
   

 

 

How Secure is Private medical Information? A Review of Computer Security at the Health Care Financing Administration and Its Medicare Contractors.

Subcommittee on Oversight and Investigations
May 23, 2001
10:00 AM
2322 Rayburn House Office Building 

 

 
 

Mr. Michael Neuman
President and Lead Programer
En Garde Systems, Incorporated
4848 Tramway Ridge Drive, NE
Suite 122
Albuquerque, NM, 87111

0. Summary

Penetration testing is a critical tool in ensuring the security of everything from an individual software application to an entire network. Unfortunately, security is far too complex to provide any sense of absolutes. Add to that the fact that dozens (if not hundreds) of new vulnerabilities are discovered every week, and the need to continuously test the security of a system is obvious.

We have provided services, similar to those we provided HCFA, to hundreds of companies, and are intricately aware of the “industry standard” state of security. During our tenure providing security services to HCFA, we found both extremely positive and disturbing issues. Major recommendations include:

Technical Oversight: HCFA is lacking the specially trained personnel to oversee their and their contractors’ activities and verify the work for security consistent with policy and best practices..

Third-Party Verification: It should be unacceptable for service providers to certify themselves as secure. Any vendor of network services to HCFA should readily accept 3rd party verification of security and have regular testing a part of their contract performance requirements.

Security Specified in Contracts: The security expectations and requirements should explicitly be laid out in contracts with network service providers.

More Testing is Required: It’s necessary to independently verify the security features of everything from applications to WWW servers to networks and to do so on a recurring basis.

1. Background

En Garde Systems (EGS) provided a variety of security services to the Health Care Financing Administration (HCFA) between December 1997 and June 2000. During that time, EGS performed a number of penetration tests and assisted HCFA in devising network security protections. Specifically, EGS has performed:

  •  External Penetration Tests (4). As an average outsider connected to the Internet, we attempted to gain access to internal HCFA resources.

  • Internal Penetration Tests (2). Given a connection to HCFA’s internal network, we attempted to gain access to internal HCFA resources.

  • Wardialing. Given a prototype phone number (for example 786-xxxx), we dial every phone number looking for computer modems. When a computer answers, we attempt to gain access.

  • Architecture Review and Design. Given a complete map of network resources, we spent extensive time understanding the various applications HCFA provides and the security needs of each. We then formulated network architecture changes that would build security into the fabric of the network.

  • Test of Internet services hosted by IBM Global Services. At the time we tested, HCFA outsourced its internal and external web servers to IBM.

  • NT Desktop Review. For Y2K, HCFA moved to a Windows NT desktop system. We were provided with a prototypical NT desktop prior to deployment to find security vulnerabilities.

  •  HCFA Insider test. We were given a standard user’s desktop computer and asked to gain access to HCFA internal resources. In this case, we were not allowed to bring in our own software, floppies, or PC—only what we could retrieve using HCFA’s network.

  • Intrusion Detection System Review. HCFA ran a “bake-off” of several competing Intrusion Detection Systems and asked us to perform a variety of tests to determine their efficacy.

  •  Security Training. We provided classes over a several day period covering everything from good password choice to Intrusion Investigation and Response.

 2. Approach

Penetration testing is a critical tool in ensuring the security of everything from an individual software application to an entire network. Unfortunately, security is far too complex to provide any sense of absolutes. Turning on one network service may result in dozens being turned in non-obvious ways. Connecting a trusted partner to your network often means you not only trust him, but everyone he trusts as well. Add to that the fact that dozens (if not hundreds) of new vulnerabilities are discovered every week, and the need to continuously test the security of a system is obvious.

Our approach to testing is almost exclusively “manual”. We rarely use automated tools, as our experience has shown they are generally only effective in an extremely small number of cases. Instead, we learn about the network and create new attacks on the fly. In doing so, we are doing exactly what a hacker does.

Proposing solutions to vulnerabilities is perhaps the most complex part of our work. Before we recommend any solution, we need to determine the:

1)       Value of the organization’s data. If the data is simply pricing and personnel information, it is far less valuable to a hacker than Privacy Act data, for example.

2)       Threat to the organization. A government agency will attract far more interest from the malevolent than a small computer company, for example.

3)       Path of least resistance. It makes no sense to spend a great deal of effort protecting a network connection to a partner if the “front door” is wide open. These relative threats are determined before any solution is recommended.

4)      Cost in man-hours and equipment expenditures. We often make several recommendations based upon the amount of money the customer wishes to spend.

3. Findings

We have provided services, similar to those we provided HCFA, to hundreds of companies, and are intricately aware of the “industry standard” state of security. During our tenure providing security services to HCFA, we found both extremely positive and disturbing issues.

3.1 Positive

3.1.1. There is a healthy approach to security from HCFA management. Whereas many other organizations believe that all security problems can be solved by writing a policy, HCFA has taken significant steps to not only inscribe the virtues of security, but to ensure they practice what they preach.

 

3.1.2. When we first arrived at HCFA, we found them to be operating with significant and obvious vulnerabilities. These problems were fixed within hours of our reports. Over the course of the years, HCFA has become significantly more secure than the industry standard.

 

3.1.3. Beyond simply patching vulnerabilities that were found, HCFA has made significant efforts to find the systemic causes of their vulnerabilities and fix them wherever possible.

3.2 Negative

3.2.1. Contractors

By far, HCFA’s biggest security problems have been the direct result of the action or inaction of contractors. In general, we have found HCFA’s contractors to be outright obstructive to providing sound security. Compounding these errors was HCFA’s inability to catch or prevent them.

a.        HCFA lacked the technical oversight of their contractors to verify the contractor was actually implementing the security measures they claimed. The managerial oversight had no ability to ask relevant questions.

b.       HCFA’s contracts had no mention of security expectations of a contractor. As a result, the contractors were free to implement (or not implement) any measures they felt as appropriate, regardless of HCFA’s requests.

c.        We discovered during our first test that a HCFA contractor ignored change control, bypassed the firewall policy group, and installed his own filter rules directly onto HCFA’s primary firewall without anyone’s knowledge. These filter rules made the entire HCFA network vulnerable to a variety of serious attacks. After bringing the firewall problem to HCFA’s attention, the contractor was directed to remove the rule and instructed about the use of change control. One year later, we tested and found the contractor installed the same rule again without HCFA’s knowledge.

d.       On several occasions, we witnessed HCFA contractors argue against improving security stating that changes HCFA asked for were “difficult” or “impossible” when, in fact, they were not.

e.        During our architecture review, we discovered that the HCFA contractors responsible for network operations could not provide a complete list of all network connections external to HCFA. In fact, we spoke to over a dozen groups, and each would make us aware of another undocumented connection from HCFA to another organization.

f.        Contractors have made extremely poor password and configuration decisions, violating the most basic security principals and completely invalidating other security measures put into place.

 

3.2.2. IBM

HCFA relied on IBM to provide secure network connectivity (via a product called “SecureNet”) to MDCN partners as well as for both external and internal WWW servers. We were contracted to evaluate the architecture and determine potential risks.

During a meeting with HCFA management (up to CIO level), IBM’s security staff and management responsible for the HCFA contract, and ourselves, we were told by IBM that we didn’t need to test because they had taken every imaginable security precaution. They described how:

  •  Administrators can only connect from a physically secure administrative network

  • WWW administration is done through an encrypted management connection

  • Patches are installed immediately after a vulnerability is announced

  •  They would be happy to share their firewall’s access control lists with us

  • They perform penetration testing every week

  • They have a custom designed IDS along with 24/7 response

  • The firewalls only allow WWW access through

  • Upon extensive questioning from ourselves and HCFA’s CIO, it we learned from IBM that:

  • Administrators can also dial-in from home into a generic “SecureNet” modem bank, that all other customers use, and administer machines.

  • WWW administration can be encrypted, but they haven’t enabled that feature, and probably won’t because it’s difficult to do so.

  •  Patches are only installed when an administrator gets around to it, which is usually in a “week or two”.

  •  They would not share their access control lists because, “If EGS found a vulnerability in HCFA, they would find a vulnerability in all IBM customers.”

Because HCFA relies so much on the security of IBM to provide everything from secure connectivity for the MDCN to managed web hosting, we proposed performing three distinct tests:

1)       External test against the web servers hosted by IBM

2)       Tests from a HCFA partner connected to the MDCN directed at HCFA and other partners on the MDCN.

3)       Tests from a non-MDCN customer of IBM directed towards HCFA.

It took IBM and HCFA a year of negotiation to come to terms to allow just the external test against the web servers. We were given several severe restrictions that made the results of the test unrealistic. Specifically:

1)       We were not allowed to test the firewalls or any other infrastructure on the IBM network. They did provide us with an extremely limited subset of filter rules that IBM said were installed on their firewalls.

2)       We were not allowed to touch any IBM system other than HCFA’s web server. This included administrative systems, other customer servers, or any infrastructure.

3)       We were not allowed to route traffic through any other IBM network.

These restrictions meant that we could only test the controls in place on the web server. We could not check for configuration errors in access control lists, vulnerabilities in firewalls or routers, or transitive trust issues (i.e. if we can break into the IBM administrative network, or another customer’s web server, what can we do then?).

In the end, the restrictions ended up being irrelevant. Using an extremely old, very well known vulnerability in the WWW server software, we were able to gain access to HCFA’s web server without any more technical expertise than it takes to point and click. Because of the way HCFA’s web server was configured, and an error made in the firewall rules set up by IBM, we were then able to access HCFA’s internal network resources. IBM’s other claims were then shown either false or useless:

  • If they performed a penetration test every week, they would have discovered this blatant vulnerability

  • They provided us with the IDS logs collected during the course of our attack, and we had gone completely unnoticed, despite us making no effort to hide our tracks.

  • The firewalls allowed not only WWW access through but also another protocol that allowed us unfettered access to HCFA’s internal network.

 3.2.3. Third Party trust

HCFA has a need to connect with a variety of insurance companies, doctors, and so forth. Network connections were provided both through the MDCN and by direct connectivity to other companies. These connections were configured such that there was no protection of either HCFA from the company or the companies from each other. Essentially, HCFA was trusting these companies completely. As a result, HCFA is subject to whatever security policies and protections are in place by the trusted company. So, if HCFA trusts company A and company A trusts company B, then HCFA trusts company B. Without any control over or auditing of the partner’s network, HCFA should not trust that it’s secure.

In addition to threatening HCFA, there is a potential for these competing insurance companies to use HCFA as a means to attack one another. HCFA provides the unsecured communications mechanism, and a company simply uses that to get into another’s network. 

4. Recommendations

4.1. Technical Oversight

HCFA is lacking the specially trained personnel to oversee their and their contractors’ activities and verify the work for security consistent with policy and best practices. This position should be solely technical—it should not have any policy development duties associated with it. The position should be independent of any contractors and should be associated with the security policy group. Essentially, the role is to be the “security implementer” of the organization.

The goal is to have an independent and informed person who can ensure that the security of the organization is not simply some high-level goals or a policy on paper. In HCFA’s case, such a person would have prevented the vast majority of vulnerabilities introduced by either HCFA or HCFA’s contractors. Beyond our experience with HCFA, such a position is direly needed in most organizations.

4.2. Third-Party Verification

It should be unacceptable for service providers to certify themselves as secure. Recently, it’s become popular for service providers to get an outside certification of their networks or services and provide that as evidence of their security. In our experience, these too are insufficient, as the certifiers do not reveal their methodology or extent of their certification.

Any vendor of network services to HCFA should readily accept 3rd party verification of security and have regular testing a part of their contract performance requirements. 

4.3. Security Specified in Contracts

The security expectations and requirements should explicitly be laid out in contracts with network service providers. Without such clauses, HCFA was essentially powerless to require the use of broadly accepted industry security standards.

4.4. More Testing is Required

Security is such a complex field, with new vulnerabilities being discovered daily, that it’s impossible for the average Information Technology professional to keep up. As a result, it’s necessary to independently verify the security features of everything from applications to WWW servers to networks and to do so on a recurring basis. In HCFA’s case, thoroughly testing the security of the MDCN is critical to its continued operation and information integrity. As it stands, there’s no way to know if it’s really secure or not. Whenever a new application or service is provided to the public, a new network connection is established, or a new modem installed, these need to be tested for proper operation.

5. Conclusion

We believe HCFA has done more to identify and remedy security problems than is common. Despite this, they have experienced a substantial set of serious vulnerabilities over the course of our provision of security services to them. Their reliance upon contractors to operate makes them particularly susceptible to the types of vulnerabilities we have described within this document. 

There is always more work to do, however. Security is not a one-time fix—it’s something that must be integrated into the business of an organization. It must be continually reinforced, reanalyzed, and redesigned as circumstances dictate. New services, applications, and networks need to be tested before deployment. 

 

 
 

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