Systems Processing Economic Impact Payments Performed Well and the Get My Payment Application Security Vulnerabilities Are Being Remediated
Summary
Treasury Inspector General for Tax Administration (TIGTA) final audit report 2021-26-006, Systems Processing Economic Impact Payments Performed Well and the Get My Payment Application Security Vulnerabilities Are Being Remediated, issued December 28, 2020. It finds that the 16 IRS tax systems involved in delivering Economic Impact Payments under the CARES Act performed well, though a coding issue affected the Individual Master File, which the IRS restored within approximately 24 hours. TIGTA determined that 463 (99 percent) of 470 required baseline security controls were implemented for the Get My Payment application, but that the IRS failed to timely remediate 17 critical and 169 high security vulnerabilities.
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TREASURY INSPECTOR GENERAL FOR TAX ADMINISTRATION
Systems Processing Economic Impact
Payments Performed Well and the Get My
Payment Application Security Vulnerabilities
Are Being Remediated
December 28, 2020
Report Number: 2021-26-006
TIGTACommunications@tigta.treas.gov | www.treasury.gov/tigta | 202-622-6500
To report fraud, waste, or abuse, please call us at 1-800-366-4484 1
HIGHLIGHTS: Systems Processing Economic Impact
Payments Performed Well and the Get My Payment
Application Security Vulnerabilities Are Being Remediated
Final Audit Report issued on December 28, 2020
Report Number 2021-26-006
Why TIGTA Did This Audit What TIGTA Found
This audit was initiated to review Overall, the 16 IRS tax systems involved in delivering Economic
the effectiveness of IRS systems Impact Payments to individuals performed well. However, a coding
security and operations related to issue in the software developed to process the payments affected the
processing the Coronavirus Aid, Individual Master File’s performance. The IRS fully restored the
Relief, and Economic Security Act system within approximately 24 hours and the affected payments
Economic Impact Payments. were processed the following business day.
Impact on Taxpayers TIGTA determined that 463 (99 percent) of 470 required baseline
security controls and control enhancements were implemented for
On March 27, 2020, the
the Get My Payment application. The security controls not
Coronavirus Aid, Relief, and
implemented related to vulnerability scanning, flaw remediation,
Economic Security Act, which is
information input validation, cryptographic protection, and
the largest economic rescue
information system component inventory. In response to these
package in U.S. history, was
findings, the Applications Development function opened a Plan of
signed into law. The Act directed
Action and Milestones to address each deficiency. However, the IRS
the IRS to deliver Economic
failed to timely remediate 17 critical (four unique) and 169 high (five
Impact Payments to eligible
unique) security vulnerabilities that were identified in the Get My
individuals, in addition to
Payment application database.
containing numerous tax-related
provisions for both individuals Lastly, the IRS assessed the Get My Payment application’s
and businesses. The Act appropriate identity and authenticator assurance levels at level two,
appropriated $750.7 million in higher than the currently implemented level one. Although the IRS
additional funding to the IRS to implemented identity and authenticator assurance levels below the
administer and oversee these assessed level, TIGTA found that the Digital Identity Acceptance
provisions. Statement met the National Institute of Standards and Technology
and agency requirements by including a detailed implementation
On April 10, 2020, the IRS issued
and rationale, compensating controls and risk mitigation factors, a
more than 81.4 million payments
description of risk acceptance, and a plan of action.
totaling more than $147.6 billion.
As of September 25, 2020, the IRS What TIGTA Recommended
issued more than 165 million
Economic Impact Payments The Chief Information Officer should ensure that critical and high
totaling more than $276 billion. security vulnerabilities are timely remediated based on
agency-defined timelines, and Plans of Action and Milestones
associated with the Get My Payment application are completed
timely based on agency defined timelines and processes.
The IRS agreed with both recommendations. The IRS plans to
remediate the critical and high vulnerabilities as well as the Plans of
Action and Milestones identified in the audit.
U.S. DEPARTMENT OF THE TREASURY
WASHINGTON, D.C. 20220
TREASURY INSPECTOR GENERAL
FOR TAX ADMINISTRATION
December 28, 2020
MEMORANDUM FOR: COMMISSIONER OF INTERNAL REVENUE
M. Weir for
FROM: Michael E. McKenney
Deputy Inspector General for Audit
SUBJECT: Final Audit Report – Systems Processing Economic Impact Payments
Performed Well and the Get My Payment Application Security
Vulnerabilities Are Being Remediated (Audit # 202020626)
This report presents the results of our review to review the effectiveness of Internal Revenue
Service (IRS) systems security and operations related to the Coronavirus Aid, Relief, and
Economic Security Act Economic Impact Payment processing. This review is part of our Fiscal
Year 2021 Annual Audit Plan and addresses the major management and performance challenge
of Responding to the COVID-19 Pandemic.
Management’s complete response to the draft report is included as Appendix II.
Copies of this report are also being sent to the IRS managers affected by the report
recommendations. If you have any questions, please contact me or Danny R. Verneuille,
Assistant Inspector General for Audit (Security and Information Technology Services).
Systems Processing Economic Impact Payments
Performed Well and the Get My Payment Application
Security Vulnerabilities Are Being Remediated
Table of Contents
Background .....................................................................................................................................Page 1
Results of Review .......................................................................................................................Page 2
Tax Systems Involved in Delivering Economic Impact
Payments to Individuals Generally Performed Well ...............................................Page 2
Most Required Baseline Security Controls Were
Implemented for the Get My Payment Application ................................................Page 2
Recommendations 1 and 2: .....................................................Page 7
The Digital Identity Acceptance Statement Met Both
Federal and Agency Security Requirements ..............................................................Page 7
Appendices
Appendix I – Detailed Objective, Scope, and Methodology ................................Page 10
Appendix II – Management’s Response to the Draft Report ..............................Page 12
Appendix III – Glossary of Terms....................................................................................Page 15
Appendix IV – Abbreviations ...........................................................................................Page 17
Systems Processing Economic Impact Payments
Performed Well and the Get My Payment Application
Security Vulnerabilities Are Being Remediated
Background
On March 27, 2020, the Coronavirus Aid, Relief, and Economic Security Act (CARES Act) 1 was
signed into law. The CARES Act is the largest economic rescue package in U.S. history and will
have a significant impact on the Internal Revenue Service (IRS) and Federal tax administration.
The CARES Act contains numerous tax-related provisions affecting individuals and businesses
and appropriated $750.7 million 2 in additional funding to the IRS to administer and oversee
these provisions. Figure 1 summarizes the CARES Act Provisions.
Figure 1: Highlights of the CARES Act Provisions
Source: Treasury Inspector General for Tax Administration analysis of the CARES Act.
With more than 56,000 IRS employees teleworking due to the closure of more than 90 percent
of all IRS facilities, the IRS faced significant challenges because of the Coronavirus-19 pandemic.
The IRS expedited its analysis and reprogramming of systems and educated taxpayers on
Economic Impact Payments. The IRS began issuing Economic Impact Payments on
April 10, 2020, just 14 days after the passage of the CARES Act; at the same time, the IRS was
closing its facilities in response to the Coronavirus-19 pandemic. In order to complete this task,
the IRS established a dedicated web page on IRS.gov to provide updated information related to
the issuance of Economic Impact Payments, including a continually evolving list of frequently
asked questions.
The IRS also coordinated with other Federal agencies to obtain program data that could
automatically send Economic Impact Payments to individuals who receive benefits from these
agencies and do not regularly interact with the IRS. For example, the IRS worked with the
Bureau of the Fiscal Service, 3 the Social Security Administration, and the Department of Veterans
Affairs to identify beneficiary recipients along with their direct deposit account numbers.
1
Pub. L. No. 116-136, 134 Stat. 281.
2
The IRS was appropriated $293.5 million for Taxpayer Services, $250 million to prevent, prepare for, and respond to
Coranavirus-19, including implementation of the CARES Act, $170 million for Operations Support, and $37.2 million
for Enforcement.
3
An agency of the U.S. Department of the Treasury that issues payments on behalf of the IRS.
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Performed Well and the Get My Payment Application
Security Vulnerabilities Are Being Remediated
As a result, the IRS issued more than 81.4 million payments totaling more than $147.6 billion on
April 10, 2020. As of September 25, 2020, the IRS issued more than 165 million Economic
Impact Payments totaling more than $276 billion.
Results of Review
Tax Systems Involved in Delivering Economic Impact Payments to Individuals
Generally Performed Well
The CARES Act provisions which provide economic relief to individuals include the issuance of
recovery rebates of $1,200 per eligible individual ($2,400 in the case of eligible individuals filing
a joint return) and $500 for each qualifying child. The Joint Committee on Taxation estimated
the cost of the rebate provision to be approximately $292.4 billion over Fiscal Years 2020
and 2021.4
To support these efforts, despite office closures and employees working remotely, the IRS
completed extensive computer programming and testing that was necessary to begin issuing
the Economic Impact Payments. This included developing computer programming
requirements to identify eligible individuals, compute their Economic Impact Payment amounts,
as well as modify the Individual Master File 5 to capture information related to the issuance of
the Economic Impact Payment in each individual’s tax account. In total, 16 IRS tax systems were
involved in the processing and delivery of the Economic Impact Payments to individual
taxpayers.
Of these 16 IRS tax systems, only the Individual Master File experienced a performance problem
due to a coding issue in the software developed to process the payments. The IRS fully restored
the system within approximately 24 hours and the Economic Impact Payments scheduled to be
delivered during the outage were processed the following business day.
By quickly restoring the Individual Master File functionality, the IRS was able to continue to
timely issue the Economic Impact Payments to individual taxpayers in accordance with the
CARES Act.
Most Required Baseline Security Controls Were Implemented for the Get My
Payment Application
The National Institute of Standards and Technology (NIST) provides guidelines 6 to select and
specify security controls for organizations and information systems, which support the executive
agencies of the Federal Government, to ensure that they meet the minimum requirements of
4
JCX-11-20 (March 26, 2020).
5
See Appendix III for a glossary of terms.
6
NIST Special Publication 800-53 Revision 4, Security and Privacy Controls for Federal Information Systems and
Organizations (Apr. 2013). Revision 5 of this publication was released in September 2020. We assessed the Get My
Payment application against the controls required during our audit fieldwork. Because we concluded our analysis in
August 2020, we used the criteria established in Revision 4.
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Security Vulnerabilities Are Being Remediated
the Federal Information Processing Standards. 7 These guidelines apply to all components of an
information system that process, store, or transmit Federal information.
The Internal Revenue Manual (IRM) 8 establishes the security framework for the development of
security control specific implementations defined in subordinate IRMs, IRS publications, and
other subordinate procedural guidance. The IRM also requires that all information systems be
assigned a Federal Information Processing Standards Security Impact-level Designator. 9 Federal
Information Processing Standards Security Impact-level Designators are:
• (L) – Applies to systems categorized as Impact-level LOW.
• (M) – Applies to systems categorized as Impact-level MODERATE.
• (H) – Applies to systems categorized as Impact-level HIGH.
On April 15, 2020, the IRS launched the Get My Payment (GMP) application, a web-based tool
that provides taxpayers with the ability to check the status of their Economic Impact Payments
and submit missing bank information for their accounts. The GMP application is part of the
Integrated Customer Communications Environment (ICCE), which is comprised of numerous web
and telephone applications. The functionality of these automated self-service applications
supports the IRS mission by providing taxpayers with a variety of services, such as the ability to
check tax refund status and establish payment agreements. Each of these taxpayer-facing,
interactive applications are currently operational. The ICCE, including the GMP application, is
designated as an Impact-level MODERATE system.
Agency security policies require that security controls be documented and assessed for a
system’s initial authorization, updated and assessed annually for a system’s continued
authorization, and updated and assessed on an ad-hoc basis resulting from significant changes
performed on the system. 10 According to Cybersecurity function officials, the addition of the
GMP application to the ICCE was a significant change to the system and triggered an
Event-Driven Security Controls Assessment.
We determined that 470 NIST and agency-specific security controls and control enhancements
were applicable to the GMP application. We found that 463 (99 percent) of 470 applicable
security controls and control enhancements were fully implemented. Figure 2 provides a
summary of the GMP security controls implementation.
7
Department of Commerce, Federal Information Processing Standards Publication 200, Minimum Security
Requirements for Federal Information and Information Systems Publication (Mar. 2006).
8
IRM 10.8.1, Information Technology Security, Policy and Guidance (May 9, 2019).
9
Department of Commerce, Federal Information Processing Standards Publication 199, Standards for Security
Categorization of Federal Information and Information Systems (Feb. 2004).
10
IRS, Federal Information Security Modernization Act Security Controls Assessment Standard Operating Procedure
(Feb. 7, 2020).
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Security Vulnerabilities Are Being Remediated
Figure 2: Summary of GMP Application Security Controls Implementation
(Number of controls implemented)
Applicable Security Security Controls Security Controls
Control Family
Controls Implemented Not Implemented
Access Control 32 32 0
Audit and Accountability 27 27 0
Awareness and Training 11 11 0
Configuration Management 42 39 3
Contingency Planning 39 39 0
Identification and Authentication 18 18 0
Incident Response 23 23 0
Maintenance 22 22 0
Media Protection 16 16 0
Personnel Security 28 28 0
Physical and Environmental Protection 37 37 0
Planning 16 16 0
Risk Assessment 18 17 1
Security Assessment and Authorization 26 26 0
System and Communications Protection 34 33 1
System and Information Integrity 41 39 2
System and Services Acquisition 40 40 0
Totals 470 463 7
Source: Treasury Inspector General for Tax Administration analysis of the GMP application’s Baseline
Security Controls.
The four control family categories identified in Figure 2 as having controls not implemented
contained specific risk areas that need to be addressed. The IRS documented an active Plan of
Action and Milestones (POA&M) for each risk area to reduce these risks, ensure system integrity,
and maximize system availability for taxpayers.
Critical and high security vulnerabilities were not timely remediated
To satisfy the NIST security control requirement for Vulnerability Scanning (Risk Assessment
control family), the IRM requires system owners to deploy vulnerability scanning tools that look
for software flaws and improper configurations and measure vulnerability impacts. The IRM also
requires information systems to be scanned at least monthly for vulnerabilities. We found that
the IRS has successfully deployed the necessary tools and implemented procedures to detect
software vulnerabilities for the GMP application. The IRM also states that legitimate
vulnerabilities shall be remediated in accordance with agency-approved response times based
on the severity level of the vulnerability. Vulnerabilities with the highest risk shall be prioritized
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Security Vulnerabilities Are Being Remediated
and remediated first. Common Vulnerability Scoring System scores provided by the scanning
tools shall be used to prioritize vulnerabilities. Figure 3 shows the score ranges and their
associated remediation time frames.
Figure 3: Common Vulnerability Scoring System Ranges by
Severity Risk Level and Remediation Time Frames
Score Range Vulnerability Severity Risk Level Remediation Time Frame
0.0 None None
0.1-3.9 Low 180 days
4.0-6.9 Medium 120 days
7.0-8.9 High High Value Assets = 60 days
All other systems = 90 days
9.0-10.0 Critical 30 days
Source: IRM 10.8.1.
On June 25, 2020, the IRS provided the May 2020 database vulnerability scan report for the
ICCE, which houses the GMP application. Based on our evaluation of the report, we determined
the following:
• There were a total of 186 critical and high vulnerabilities; 17 critical (four unique)
vulnerabilities and 169 high (five unique) vulnerabilities.
o All 17 critical vulnerabilities exceeded the IRS policy of 30 days for remediation.
o All 169 high vulnerabilities exceeded the IRS policy of 90 days for remediation.
• That nine (53 percent) of the 17 critical vulnerabilities have existed for more than
180 days, of which four had a first-failed date of October 2, 2018.
• That 121 (72 percent) of the 169 high vulnerabilities have existed for nearly 590 days, of
which 105 had a first-failed date of October 2, 2018.
In addition, in the June 2020 GMP application’s Security Assessment Report, 11 the Cybersecurity
function’s Security Risk Management office issued a finding to the ICCE Authorizing Official
stating that the database vulnerability scan reports identified 17 critical and 169 high security
vulnerabilities. The IRS assessed the likelihood of a threat exploiting these vulnerabilities as
high, the impact of a threat exploiting these vulnerabilities as moderate, and assessed the
overall risk level associated with these vulnerabilities as moderate.
During the course of the audit, the IRS had completed multiple actions in an effort to resolve
these findings, including the installation of required database patches, coordination with
database administrators from the Enterprise Operations function to develop a hardening script,
and deployment of the script to the production database. However, we determined that due
to multiple competing priorities and time constraints, the IRS did not timely remediate these
vulnerabilities within agency-defined time frames.
Failing to timely remediate critical and high security vulnerabilities could compromise the
security posture of the GMP application’s database and can lead to unauthorized access,
11
IRS, Get My Payment Tier 2 Security Assessment Report (June 10, 2020).
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increased vulnerability to attacks, and unauthorized data sharing, all of which compromise the
integrity, confidentiality, and availability of the system.
Management Action: On June 18, 2020, in response this finding, the Applications
Development function opened POA&M 37055 with a planned completion date of July 1, 2021.
The source code security review identified medium-and low-risk security vulnerabilities
The IRM states that a code review shall be conducted for all new or modified systems going
through a Security Assessment and Authorization that have not previously had a code review
conducted and when code is being placed into production on an IRS information technology
system. The IRS completed the required code review for the GMP application on April 3, 2020.
To satisfy NIST security controls requirement for Flaw Remediation and Information Input
Validation (System and Information Integrity control family), the IRM12 states that applications
shall protect from cross-site scripting vulnerabilities, protect from command injection, and
validate all input. In addition, the IRM also contains recommended best practices for logging
and resource allocation. Our analysis of the source code security review report identified six
security vulnerabilities (two medium risk and four low risk) related to input validation, injection,
cross-site scripting, information leakage through log files, and improper resource shutdown due
to using outdated software. All six of these vulnerabilities are associated with NIST security
controls Flaw Remediation and Information Input Validation.
In addition, in the June 2020 GMP application’s Security Assessment Report, the Cybersecurity
function’s Security Risk Management office issued a finding to the ICCE Authorizing Official
stating that medium- and low-risk findings were identified in the Static Source Code Analysis
and the Dependency Check Report. Failure to remediate all findings in the Source Code
Analysis and the Dependency Check Report could result in known weaknesses in the application
being exploited by malicious bad actors.
Management Action: On June 18, 2020, in response to this finding, the Applications
Development function opened POA&M 37053 with a planned completion date of July 2, 2021.
The web application vulnerability report for the GMP application identified weak
cryptographic ciphers
To satisfy the NIST security control requirement for Cryptographic Protection (System and
Communications Protection control family), the IRM states that when cryptographic protection
is used, IRS information systems shall use cryptographic modules that comply with applicable
Federal laws, Executive Orders, directives, policies, regulations, and standards.
We requested a web application vulnerability report for the GMP application and on
July 28, 2020, the IRS provided the January 2020 scan report. Based on our evaluation of the
report, we found one medium-risk vulnerability due to the use of weak ciphers.
In addition, in the June 2020 GMP Security Assessment Report, the Cybersecurity function’s
Security Risk Management office issued a finding to the ICCE Authorizing Official stating that
the web application scan had identified the use of weak ciphers. The use of weak cryptographic
ciphers could be exploited by a malicious attacker and potentially compromise the system’s
confidentiality, integrity, and availability.
12
IRM 10.8.6, Information Technology Security, Application Security and Development (July 21, 2020).
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Management Action: On June 18, 2020, in response this finding, the Applications
Development function opened POA&M 37054 with a planned completion date of July 1, 2021.
There is no Information System Component Inventory for the GMP application
To satisfy NIST security control requirement for Information System Component Inventory
(Configuration Management control family), the IRM states that the IRS shall develop and
document an inventory of information system components that accurately reflects the current
information system. In addition, it should include all components within the authorization
boundary of the information system and be at a level of detail necessary for tracking and
reporting. Lastly, information system components shall be reviewed and updated at a minimum
annually, and during system component installations, removals, and system updates.
During our review of the GMP application’s Event-Driven Security Controls Assessment 13 and the
GMP application’s Security Assessment Report, we determined that the GMP application does
not develop, maintain, or update an inventory for the GMP application that is at the required
level of granularity and that contains all system components of the GMP application. When
asked why the GMP application’s inventory was not updated as required, officials from the
Applications Development function stated that the inventory was not updated to include the
GMP application because the ICCE Annual Security Controls Assessment had already started its
review of the ICCE System Security Plan and the ICCE Information System Contingency Plan.
Failing to develop, maintain, or update a complete inventory could result in information system
components not being included in vulnerability and compliance scanning, as well as the
information system contingency plan being inadequate if it is needed during an event.
Management Action: On June 18, 2020, in response to this deficiency, the Applications
Development function opened POA&M 37052 with a planned completion date of July 1, 2021.
The Chief Information Officer should:
Recommendation 1: Ensure that critical and high security vulnerabilities are timely remediated
based on agency-defined timelines.
Management’s Response: The IRS agreed with the recommendation and will remediate
the critical and high vulnerabilities identified in the audit.
Recommendation 2: Ensure that POA&Ms associated with the GMP application are completed
timely based on agency defined timelines and processes.
Management’s Response: The IRS agreed with the recommendation and will remediate
the POA&Ms identified in the audit.
The Digital Identity Acceptance Statement Met Both Federal and Agency
Security Requirements
In June 2017, the NIST updated technical requirements for Federal agencies related to
authentication and identity risks associated with implementing digital identity services. 14
13
IRS, Get My Payment Continuous Monitoring Assessment Plan (May 21, 2020).
14
NIST Special Publication 800-63-3, Digital Identity Guidelines (June 2017).
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Federal agencies must perform risk assessments; select individual assurance levels for identity
proofing, authentication, and federation (if applicable); determine which processes and
technologies they will employ to meet each assurance level; and document these decisions in a
Digital Identity Acceptance Statement.
The Digital Identity Acceptance Statement must include the assessed assurance levels, the
implemented assurance levels, rationale if the implemented assurance levels differ from the
assessed assurance levels, comparability demonstration of compensating controls, and rationale
if federated entities are not accepted.
Agency procedures for the Digital Identity Risk Acceptance process implement the risk
acceptance methodology required by the NIST. 15 Agency procedures also document the
purpose, procedures, and outputs of each activity within the Digital Identity Risk Acceptance
process and include three main components: assessment of assurance levels, assurance levels
for implementation, and approval and oversight.
We reviewed the Digital Identity Acceptance Statement and all related documents for the GMP
application. The IRS assessed the GMP application’s appropriate identity and authenticator
assurance levels at level two; however, the IRS implemented the GMP application’s assurance
levels at the less-restrictive level one. The NIST defines the components of level one and level
two identity assurance and authenticator assurance as follows:
• Identity Assurance Level One: There is no requirement to link the applicant to a specific
real-life identity. Any attributes provided in conjunction with the authentication process
are self-asserted or should be treated as such.
• Identity Assurance Level Two: Evidence supports the real-world existence of the claimed
identity and verifies that the applicant is appropriately associated with this real-world
identity. This level also introduces the need for either remote or physically present
identity proofing.
• Authenticator Assurance Level One: Provides some assurance that the claimant controls
an authenticator bound to the subscriber’s account. This level requires either
single-factor or multifactor authentication using a wide range of available authentication
technologies. Successful authentication requires that the claimant prove possession and
control of the authenticator through a secure authentication protocol.
• Authenticator Assurance Level Two: Provides high confidence that the claimant controls
authenticators bound to the subscriber’s account. Proof of possession and control of
two distinct authentication factors is required through secure authentication protocols.
Approved cryptographic techniques are required at this level and above.
Although the IRS implemented identity and authenticator assurance levels that were below the
assessed level, we found the Digital Identity Acceptance Statement met NIST and agency
requirements by including a detailed implementation and rationale, compensating controls and
risk mitigation factors, a description of risk acceptance, and a plan of action. Examples of the
compensating controls and risk mitigation factors included providing passive protection against
malicious bots, masking taxpayer bank account information except for the last four digits,
limiting the number of daily attempts per Social Security Number, and sending audit records to
the Cybersecurity function’s Cyber Fraud Analytics and Monitoring team for review and
15
IRS, Digital Identity Risk Assessment Standard Operating Procedures, Version 1.6 (July 2019).
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detection of potential fraudulent activity. IRS officials reported that there were no confirmed
cases of fraud in the GMP application associated with user’s bank account information. In
addition, due to the identification of potential high-risk transactions, the Cyber Fraud Analytics
and Monitoring team recommended that 159,739 Economic Impact Payments be transitioned
from direct deposit to paper check delivery.
By ensuring that the GMP application complies with all applicable NIST and agency security
requirements related to digital identity services, the IRS properly implemented compensating
controls to mitigate the risks from using inappropriate authentication controls, which could
allow unauthorized access and activities, compromised taxpayer records, and lost revenue due
to identity theft refund fraud.
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Appendix I
Detailed Objective, Scope, and Methodology
Our overall objective was to review the effectiveness of IRS systems security and operations
related to the CARES Act Economic Impact Payment processing. To accomplish our objective,
we:
• Interviewed key stakeholders within the Applications Development function and
reviewed the results from our planning survey to determine the IRS tax systems involved
in delivering the Economic Impact Payments to individual taxpayers.
• Analyzed IRS Information Alerts and interviewed key stakeholders from the Applications
Development function to determine if any tax systems experienced a malfunction or
performance issue specifically related to the implementation and delivery of the CARES
Act legislation.
• Reviewed multiple security vulnerability reports, security assessment reports, risk
assessment plans, a system security plan, and several POA&Ms to determine if the IRS
implemented the GMP application’s required baseline security controls and control
enhancements established by the NIST and the IRM.
• Reviewed one security vulnerability report and two security assessment reports and
conducted interviews with officials from the Applications Development and
Cybersecurity functions to determine whether critical and high security vulnerabilities
were timely remediated based on agency-defined timelines.
• Reviewed the Digital Identity Risk Assessment Determination, the Digital Identity Risk
Assessment Ongoing Assessment, the Digital Identity Risk Assessment Tool Results, and
Oversight and Pre-Oversight Voting Concurrence documents to determine whether the
GMP application’s Digital Identity Acceptance Statement met minimum Federal and
agency security requirements.
Performance of This Review
This review was performed with information obtained from the Information Technology
organization’s Applications Development and Cybersecurity functions during the period April
through October 2020. Due to the ongoing Coronavirus-19 pandemic, we conducted all audit
work virtually. We held meetings and interviews via teleconference. We conducted this
performance audit in accordance with generally accepted government auditing standards.
Those standards require that we plan and perform the audit to obtain sufficient, appropriate
evidence to provide a reasonable basis for our findings and conclusions based on our audit
objective. We believe that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objective.
Major contributors to the report were Danny Verneuille, Assistant Inspector General for Audit
(Security and Information Technology Services); Jena Whitley, Director; Jason McKnight, Audit
Manager; Mike Curtis, Lead Auditor; Naomi Koehler, Senior Auditor; and Johnathan Elder,
Information Technology Specialist (Data Analytics).
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Internal Controls Methodology
Internal controls relate to management’s plans, methods, and procedures used to meet their
mission, goals, and objectives. Internal controls include the processes and procedures for
planning, organizing, directing, and controlling program operations. They include the systems
for measuring, reporting, and monitoring program performance. We determined that the
following internal controls were relevant to our audit objective: NIST requirements for selecting
and specifying security controls for organizations and information systems supporting the
Federal government and IRM polices related to information systems security requirements and
the Digital Identity Risk Assessment and Acceptance process. We evaluated these controls by
interviewing IRS employees and analyzing relevant documentation provided by the IRS.
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Appendix II
Management’s Response to the Draft Report
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Appendix III
Glossary of Terms
Term Definition
Verifying the identity of a user, process, or device, often as a prerequisite to
Authentication
allowing access to resources in an information system.
All components of an information system to be authorized for operation by
Authorization Boundary an authorizing official and excludes separately authorized systems, to which
the information system is connected.
Official with the authority to formally assume responsibility for operating an
information system at an acceptable level of risk to agency operations
Authorizing Official
(including mission, functions, image, or reputation), agency assets, or
individuals.
An attack in which the goal is execution of arbitrary commands on the
Command Injection
host operating system via a vulnerable application.
Provides an open framework for communicating the characteristics and
Common Vulnerability impacts of information technology vulnerabilities. It attempts to assign
Scoring System severity scores to vulnerabilities, allowing responders to prioritize responses
and resources according to threat.
A vulnerability that allows attackers to inject malicious code into an
otherwise benign website. These scripts acquire the permissions of scripts
Cross-site Scripting generated by the target website and can therefore compromise the
confidentiality and integrity of data transfers between the website and
client.
The discipline that embodies the principles, means, and methods for the
Cryptography
transformation of data in order to hide their semantic content, prevent their
(Cryptographic)
unauthorized use, or prevent their undetected modification.
Initiated when changes are made to an information system that affect
security controls. This process only applies to Federal Information Security
Event-Driven Security
Modernization Act reportable information systems with an existing security
Controls Assessment
authorization. It does not apply to new systems without a security
authorization.
Any method used by hackers to gain unauthorized access to computers, the
Exploit act itself of a hacking attack, or a hole in a system’s security that opens a
system to an attack.
A process intended to eliminate a means of attack by patching
Hardening
vulnerabilities and turning off nonessential services.
The IRS database that maintains transactions or records of individual tax
Individual Master File
accounts.
The intentional or unintentional release of information to an untrusted
Information Leakage
environment.
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Management policy and procedures designed to maintain or restore
Information System
business operations, including computer operations, possibly at an
Contingency Plan
alternate location, in the event of emergencies, system failures, or disasters.
The proper testing of any input supplied by a user or application to prevent
Input Validation
improperly formed data from entering an information system.
An information system in which at least one security objective
(i.e., confidentiality, integrity, or availability) is assigned a Federal
Moderate-Impact System
Information Processing Standards potential impact value of moderate, and
no security objective is assigned a potential impact value of high.
Using two or more different factors to achieve authentication. Factors
Multifactor
include something you know (e.g., password); something you have
Authentication
(e.g., cryptographic device, token); or something you are (e.g., biometric).
A document that identifies tasks needing to be accomplished. It details
Plan of Action and
resources required to accomplish the elements of the plan, any milestones
Milestones
in meeting the tasks, and scheduled completion dates for the milestones.
The act of correcting a vulnerability or eliminating a threat through
Remediation activities such as installing a patch, adjusting configuration settings, or
uninstalling a software application.
The process of identifying risks to organizational operations (including
mission, functions, image, reputation), organizational assets, individuals,
Risk Assessment other organizations, and the Nation, resulting from the operation of an
information system. Incorporates threat and vulnerability analyses, and
considers mitigations provided by security controls planned or in place.
Provides a disciplined and structured approach for documenting the
Security Assessment
findings of the assessor and the recommendations for correcting any
Report
identified vulnerabilities in the security controls.
A safeguard or countermeasure prescribed for an information system or an
organization designed to protect the confidentiality, integrity, and
Security Control
availability of its information and to meet a set of defined security
requirements.
A set of instructions and statements written by a programmer using a
Source Code computer programming language. This code is later translated into
machine language by a compiler.
A formal document that provides an overview of the security requirements
System Security Plan for an information system and describes the security controls in place or
planned for meeting those requirements.
A weakness in an information system, system security procedure, internal
Vulnerability control, or implementation that could be exploited or triggered by a threat
source.
Weak Cipher An encryption/decryption algorithm that uses a key of insufficient length.
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Appendix IV
Abbreviations
CARES Act Coronavirus Aid, Relief, and Economic Security Act
GMP Get My Payment
ICCE Integrated Customer Communications Environment
IRM Internal Revenue Manual
IRS Internal Revenue Service
NIST National Institute of Standards and Technology
POA&M Plan of Action and Milestones
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