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FISMA Corrective action plans. OVERVIEW. Background Components and Guidelines Frequently Asked Questions. BACKGROUND. Corrective Action Plans (CAPs) are a requirement of FISMA. CAPs make FISMA an ongoing process. Ensures risks are corrected, not just identified.
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FISMA Corrective action plans
OVERVIEW • Background • Components and Guidelines • Frequently Asked Questions
BACKGROUND • Corrective Action Plans (CAPs) are a requirement of FISMA. • CAPs make FISMA an ongoing process. Ensures risks are corrected, not just identified. • They cover a period of time, not a point in time.
COMPONENTS • Include all risks where action has not been fully implemented. • Describe the action taken so far. • Describe additional action to be taken. • State when additional action will be implemented.
GUIDELINES • There is no required format. • Plan must be UPDATED every six months. • Last year’s risks are not required to be included in the new action plan.
QUESTION #1 What are the consequences if our department does not complete these CAPs?
ANSWER #1 • The same as not submitting a FISMA Report. • Department will be posted to the non-compliers list • Finance representative may contact the department for follow-up • Program Budget Managers may be notified • BCPs may be declined
QUESTION #2 Where should I send my CAPs?
ANSWER #2 CAPs are required to be sent to FISMAhotline@dof.ca.gov
QUESTION #3 I’m unclear when the first CAP is supposed to be submitted.
ANSWER #3 6 months from REPORT DATE FISMA Report Dated 2nd CAP Due 3rd CAP Due 12/31/11 6/30/12 12/31/12 Jun Dec Dec Jan 1/30/12 CAP due 30 days from REPORT DATE ONLY IF it was not included with the report
QUESTION #4 Is the CAP required to be posted to the Transparency website?
ANSWER #4 No. Only the FISMA Report is required to be posted.
QUESTION #5 If there are risks not fully mitigated/corrected by the end of the FISMA period, do they have to be included in the next FISMA report?
ANSWER #5 Only if management still considers them a risk. Prior risks should be considered in the subsequent risk assessment process.
QUESTION #6 Some of our corrective actions have an “ongoing” completion date. Even if all other corrective action is complete, do I have to continue submitting CAPs?
ANSWER #6 Likely no. Corrective action is established to be an ongoing thing. Usually when corrective action indicates an “ongoing” completion date, the action has already been taken.
QUESTION #7 Part of our department’s corrective action was contingent upon a Budget Change Proposal (BCP). What do we do if it has been denied?
ANSWER #7 BCPs are not considered corrective action for FISMA purposes. Government Code §13407 states the provisions of FISMA should be carried out using existing resources; this includes the establishment and maintenance of internal controls.