A proposed bill to establish the Chief Information Security Officer (CISO) as an organizational peer to the Chief Information Officer (CIO) at the Department of Health and Human Services (HHS) will drive cybersecurity concerns to the top of the list.  If the bill passes, the CISO would have clear separation of duties from the CIO and allow HHS to prioritize cybersecurity and avoid conflicts of interest, according to witnesses who testified before the House Energy and Commerce Committee’s Health Subcommittee.Reps. Doris Matsui (D-Calif.) and Billy Long (R-Mo.) introduced a bill in April to establish a separate office for the HHS CISO, in response to an investigation of the 2013 breach of the Food and Drug Administration’s information systems. The investigation revealed security weaknesses and recommended separating the agency’s CISO from its CIO.

“It seems a major part of the problem is the organizational structure in place at HHS that puts information security second to information operations,” Subcommittee Chairman Joseph Pitts (R-Pa.) said. “The official in charge of building complex information technology systems is also the official in charge of ultimately declaring those systems secure. This is an obvious conflict of interest.”

Pitts added that separating the two offices is “not novel or untested” in government or the private sector, and it would “better allow for internal checks and balances.”

“The trend toward elevating the CISO to be a peer of the CIO reflects the recognition that information security has evolved into risk management activity,” said Samantha Burch, senior director of congressional affairs at the Healthcare Information and Management Systems Society. “This recognition requires a reporting structure that creates a direct channel to the CEO, CFO, general counsel and board of directors to facilitate management of security risk in the context of business risk.”

Separating cybersecurity from information operations is consistent with best practices and standards across most critical infrastructure sectors.  Too many healthcare organizations are uninformed or unconcerned about the role cybersecurity plays in keeping patients safe, maximizing business operations securely, ensuring critical applications are available when needed, etc.

This move sets the stage and provides an example of how to get information risk management and cybersecurity on a level playing field with information operations within the healthcare sector and ensure a bona fide risk analysis can be conducted without bias.

Rich Curtiss

Rich Curtiss

Principal Consultant at Clearwater Compliance
Mr. Curtiss has over 35 years of diverse, executive IT experience across several verticals including Healthcare, Finance, Department of Defense, Intelligence Community and Consulting Services.Rich has served in executive information technology and cybersecurity positions as a CIO, CISO, Director and Program Manager. He's a member of the Clearwater consulting team.
Rich Curtiss