Software development

The ABCs of CGM: Implementing Continuous Glucose Monitoring

It can be a key component of carrying out the quantitative judgment part of an organization’s overall enterprise risk management. Customize security-specific assessment procedures to closely match the operating environment (and utilizing supplemental guidance in the NIST Security Controls Catalog to establish an intent of the security control). Each agency (there is roughly 100 command/service/agencies) has their own interpretation of continuous monitoring. Start with looking at the specific agencies document structure (font/headings/etc.) to develop a template then tailor it.

We ask that CSPs review this document in its entirety before beginning the FedRAMP Connect process. This quick guide outlines steps and guidance to help agencies quickly and efficiently reuse authorized cloud products within the FedRAMP Marketplace. This document provides 3PAOs with guidance on how best to utilize the Readiness Assessment Report (RAR).

continuous monitoring tools

It should be filled out and submitted with every monthly continuous monitoring submission by the CSP or their 3PAO. The FedRAMP Annual Assessment Controls Selection Worksheet provides a matrix to assist CSPs, 3PAOs, and Federal Agencies in assessing and tracking control their annual assessment. The purpose of this document is to outline the criteria by which CSPs are prioritized to work with the JAB toward a P-ATO, the JAB prioritization process, and the Business Case requirements for FedRAMP Connect.

This document provides CSPs guidance for developing the authorization boundary for their offering(s) which is required for their FedRAMP authorization package. Personal CGM became available to many more patients this past spring when Medicare expanded coverage criteria, in line with growing evidence supporting its use and updated standards of care. Now any Medicare beneficiary with diabetes whose therapy includes insulin (even basal insulin) can qualify, as can those who have problematic hypoglycemia but do not use insulin.

Continuous Monitoring Types

The FedRAMP PMO works with DHS to incorporate DHS’s guidance into the FedRAMP program guidance and documents. Effective corporate governance requires directors and senior management to oversee the organization with a broader and deeper perspective than in the past. Organizations must demonstrate they are not only profitable but also ethical, in compliance with a myriad of regulations, and are addressing sustainability. Identify areas where assessment procedures can be combined and consolidated to maximize cost savings without compromising quality.

Security control assessments performed periodically validate whether stated security controls are implemented correctly, operating as intended, and meet FedRAMP baseline security controls. Security status reporting provides federal officials with information necessary to make risk-based decisions and provides assurance to existing customer agencies regarding the security posture of the system. Once the continuous monitoring plan’s development is complete, the authorizing official or a designated representative reviews the plan for completeness, noting any deficiencies. If, however, there are significant deficiencies, the AO can return the plan to the information system owner or common control provider for corrections. Based on this authorization, the level of continuous monitoring and frequency for each control is defined, allowing the system developers and engineers to begin incorporating the monitoring plan into the system development and O&M plan. The program should define how each control in the SCTM will be monitored and the frequency of the monitoring.

FedRAMP Security Assessment Plan (SAP) Template notifies the AO with a minimum of 30 days before implementing any planned major significant changes, including an analysis of the potential security impact. Collaboration Groups provide a means for Agencies to join together and support one another in a forum for the performance of Continuous Monitoring with a CSP. These groups should be comprised primarily of Agencies leveraging a common cloud service, as well as the CSP.

We encourage you to give CGM a try, perhaps with just one patient if you’re unsure about adopting it at the practice level. Data continues to demonstrate clinical, psychosocial and behavioral benefits of CGM, and broadening insurance coverage is making it available to more and more patients. Instead of trying to piece together a handful of fingerstick data points or fasting glucose readings, we now see a full picture and important patterns. It can be a powerful tool to adjust the therapeutic inertia that is known to be prevalent in primary care. It’s crucial not to let your implicit biases affect which patients you have these conversations with or to make assumptions about which ones will be interested in the technology. We have seen that even patients who face insurance barriers may want to use CGM intermittently to assess medication effects or behavior changes.

To do this, you’ll need to know your IT environment well and understand the practical needs and cost limits. Consulting closely with all relevant teams’ stakeholders will help you understand their needs and expectations. The goal is to eliminate any possibility of a critical yet unmonitored system going offline. But there should also be no surprises when an unexpected tech bill reaches the accounting team.

The initial information in the SAR and POA&M should not be deleted but simply updated to reflect the current status of the system. In the POA&M, corrected deficiencies should remain; however, the correction should be noted, the finding that was documented as corrected closed out, and information on the independent assessor who validated the correction noted. These steps ensure transparency, maintain accountability, and can be used to track growing threats and trends that develop. Continuous monitoring can use logs, metrics, traces, and events as its data sources for each domain.

The scope of the program should be designed to address the sufficiency in security-related information to support risk-based decisions. This can be accomplished by defining metrics and frequencies38 of monitoring and assessment that produce the needed information. The development of a Continuous Monitoring Plan39 facilitates the implementation of the CM program. The Continuous Monitoring Plan also addresses the integration of CM activities and metrics to support the CM strategy through the identification of security controls necessary for monitoring to ensure their effectiveness40 over time.

Continuous monitoring plan

Again, it is important that the updated information does not remove findings documented earlier in the POA&M, to ensure that the audit trail remains intact. The system owner also ensures that the systems security plan is updated to reflect the current security posture of the system and details the manner in which the required security controls are implemented. The updated SSP, SAR, and POA&M are presented to the authorizing official or the official’s designated representative for review. The AO, with the assistance of the risk executive (function), determine the impact of the deficiency to the organization and whether the deficiency will create a situation that will invalidate the information system’s ATO. Although more tactically focused, the organization’s CM program facilitates the implementation of the CM strategy.

  • The effectiveness of’s continuous monitoring capability supports ongoing authorization and reauthorization decisions.
  • After identifying the most critical systems, the monitoring scope should identify and include the most important metrics and events.
  • The information provided by the continuous monitoring program allows leadership, including the authorizing official, to remain aware of the risk posture of the information system as it impacts the risk status for the organization.
  • The sooner you spot errors, the earlier you can begin the root cause analysis and the subsequent remediation process.
  • A continuous monitoring plan can protect your business from cyber attacks by providing insight into its IT infrastructure.

This acceptance criterion applies to all documents FedRAMP reviews that do not have special checklists or acceptance criteria predefined for them. The FedRAMP Risk Exposure Table Template is designed to capture all security weaknesses and deficiencies identified during security assessment testing. Both Cloud Service Providers (CSPs) and Federal Agencies play a role in Continuous Monitoring. FedRAMP Authorized CSPs are required to perform Continuous Monitoring to maintain a sufficient security posture. Federal Agencies are obligated to review a CSP’s Continuous Monitoring artifacts to determine if an Authority-to-Operate (ATO) is appropriate over the life of the system.

It’s known as a “continuous monitoring plan” because it requires “continuous” updating. As your business’s IT infrastructure changes, it may be introduced to new vulnerabilities. For an effective continuous monitoring plan, you’ll need to include these new vulnerabilities.

Continuous monitoring plan

Updates can be done with output from the continuous monitoring program and input from the risk executive (function). In addition to scheduled assessments conducted by independent assessors, the system owner can conduct self-assessments at any time, based on the system’s continuous monitoring plan, to evaluate the status of a security control or set of controls. Under approval from the configuration control board, the system may be modified in minor or significant ways. The results of these self-assessments and modifications require that the system’s documentation, including the security plan, be updated as these changes occur. It is important to note that the system’s self-assessments cannot be used to update the POA&M or SAR. For these documents to be updated, the organization’s independent assessors must reassess the deficient controls and validate that they are working as designed and providing the required level of protection.

Leave a Reply

Your email address will not be published.