For states that did not establish a marketplace, PPACA required the  federal government to establish and operate a marketplace for that state,  referred to as the federally facilitated marketplace. The CMS Center for Consumer Information and Insurance Oversight has  overall responsibilities for federal systems supporting the federally  facilitated marketplace and for overseeing state marketplaces. Marketplace Enrollment Is Facilitated by Data Exchanges among Many Interconnected Systems and Partners

The process of enrolling for insurance through Healthcare.gov is  facilitated by a number of major systems managed by CMS. Federal Data Services Hub: This system acts as a single portal for  exchanging information between the FFM system and other systems or  external partners, which include other federal agencies, state-based  marketplaces, other state agencies, other CMS systems, and issuers of  qualified health plans. In addition, CMS relies on a variety of federal, state, and private-sector  entities to support Healthcare.gov-related activities, and these entities  exchange information with CMS’s systems:
Federal agencies such as the Social Security Administration (SSA),  Department of Homeland Security (DHS), and Internal Revenue  Service (IRS), along with Equifax, Inc. (a private-sector credit agency  under contract with CMS) provide or verify information used in making  determinations of a person’s eligibility for coverage and financial  assistance. The Department of Defense (DOD), Office of Personnel Management  (OPM), Peace Corps, and Department of Veterans Affairs (VA) assist  in determining whether a potential applicant has alternate means for  obtaining minimum essential coverage. In addition to accessing the plan management and financial  management modules of the FFM, issuers of qualified health plans  receive information from the system when an individual completes the  application process. CMS Established a Security and Privacy Program for Healthcare.gov and Related Systems, but Actions Are Needed to Resolve Weaknesses

While CMS has security and privacy-related protections in place for  Healthcare.gov and related systems, weaknesses exist that put the  personal information these systems collect, process, and maintain at risk  of inappropriate modification, loss, or disclosure. CMS established security-related policies and procedures for  Healthcare.gov. Specifically, it assigned overall responsibility for securing the agency’s information  and systems to appropriate officials, including the agency CIO and  Chief Information Security Officer, and designated information system  security officers to assist in certifying particular CMS systems; documented information security policies and procedures to  safeguard the agency’s information and systems; developed a process for planning, implementing, evaluating, and  documenting remedial actions to address identified information  security deficiencies; and established interconnection security agreements with the federal  agencies with which it exchanges information, including DOD, DHS,  IRS, SSA, and VA; these agreements identify the requirements for the  connection, the roles and responsibilities of each party, the security  controls protecting the connection, the sensitivity of the data to be  exchanged, and the required training and background checks for  personnel with access to the connection. Without complete system security plans, agency  officials will be hindered in making fully informed judgments about the  risks involved in operating those systems. Security Control Weaknesses Could Threaten Healthcare.gov Information and Systems

CMS did not effectively implement or securely configure key security  controls on the systems supporting Healthcare.gov. Collectively, these weaknesses put Healthcare.gov systems and the  information they contain at increased and unnecessary risk of  unauthorized access, use, disclosure, modification, and loss. CMS Had Not Established a Shared Understanding of How Security Was to Be Implemented for Healthcare.gov-Related Systems

The security weaknesses we identified occurred in part because CMS did  not ensure that the multiple parties contributing to the development of the  FFM system had a shared understanding of how security controls were to  be implemented. CMS Should Act to Improve Security and Privacy Protections for Healthcare.gov

In our September 2014 report, we made the following six  recommendations aimed at improving the management of the security of  Healthcare.gov:  1. 2. Ensure that all privacy risks associated with Healthcare.gov are  analyzed and documented in privacy impact assessments. 6. In its comments on our draft reports, HHS concurred with 3 of the 6  recommendations to fully implement its information security program,  partially concurred with the remaining 3 recommendations, and concurred  with all 22 of the recommendations to resolve technical weaknesses in  security controls, describing actions it had under way or planned related  to each of them. While CMS has taken important  steps to apply security and privacy safeguards to Healthcare.gov and its  supporting systems, significant weaknesses remain that put these  systems and the sensitive, personal information they contain at risk of  compromise. Given the complexity of the systems and the many  interconnections among external partners, it is particularly important to  analyze privacy risks, effectively implement technical security controls,  comprehensively test the security controls over the system, and ensure  that an alternate processing site for the systems is fully established.
Why GAO Did This Study

PPACA requires the establishment of health insurance marketplaces in each state to assist individuals in comparing, selecting, and enrolling in health plans offered by participating issuers. CMS is responsible for overseeing these marketplaces, including establishing a federally facilitated marketplace in states that do not establish their own. These marketplaces are supported by an array of IT systems, including Healthcare.gov, the website that serves as the consumer portal to the marketplace.
This statement is based on two September 2014 reports examining the security and privacy of the Healthcare.gov website and related systems. The specific objectives of this work were to (1) describe the planned exchanges of information between the Healthcare.gov website and other organizations and (2) assess the effectiveness of programs and controls implemented by CMS to protect the security and privacy of the information and IT systems supporting Healthcare.gov.

What GAO Found

Enrollment through Healthcare.gov is supported by the exchange of information among many systems and entities. The Department of Health and Human Services' (HHS) Centers for Medicare & Medicaid Services (CMS) has overall responsibility for key information technology (IT) systems supporting Healthcare.gov. These include, among others, the Federally Facilitated Marketplace (FFM) system, which facilitates eligibility and enrollment, plan management, and financial management, and the Federal Data Services Hub, which acts as the single portal for exchanging information between the FFM and other systems or external partners. CMS relies on a variety of federal, state, and private-sector entities to support Healthcare.gov activities. For example, it exchanges information with the Department of Defense, Department of Homeland Security, Department of Veterans Affairs, Internal Revenue Service, Office of Personnel Management, Peace Corps, and the Social Security Administration to help determine applicants' eligibility for healthcare coverage and/or financial assistance. Healthcare.gov-related systems are also accessed and used by CMS contractors, issuers of qualified health plans, state agencies, and others.
While CMS has security and privacy-related protections in place for Healthcare.gov and related systems, weaknesses exist that put these systems and the sensitive personal information they contain at risk. Specifically, CMS established security-related policies and procedures for Healthcare.gov, including interconnection security agreements with the federal agencies with which it exchanges information. It also instituted certain required privacy protections, such as notifying the public of the types of information that will be maintained in the system. However, weaknesses remained in the security and privacy protections applied to Healthcare.gov and its supporting systems. For example, CMS did not
ensure system security plans contained all required information, which makes it harder for officials to assess the risks involved in operating those systems;
analyze privacy risks associated with Healthcare.gov systems or identify mitigating controls;
fully establish an alternate processing site for Healthcare.gov systems to ensure that they could be recovered in the event of a disruption or disaster.
In addition, a number of weaknesses in specific technical security controls jeopardized Healthcare.gov-related systems. These included certain systems supporting the FFM not being restricted from accessing the Internet and inconsistent implementation of security patches, among others.
An underlying reason for many of these weaknesses is that CMS did not establish a shared understanding of security roles and responsibilities with all parties involved in securing Healthcare.gov systems. Until these weaknesses are addressed, the systems and the information they contain remain at increased risk of unauthorized use, disclosure, modification, or loss.

What GAO Recommends

In its September 2014 reports GAO made 6 recommendations to HHS to implement security and privacy controls to enhance the protection of systems and information related to Healthcare.gov. In addition, GAO made 22 recommendations to resolve technical weaknesses in security controls. HHS agreed with 3 of the 6 recommendations, partially agreed with 3, agreed with all 22 technical recommendations, and described plans to implement them.