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Improving data quality in preparation for onboarding to CDM

Learn how to properly manage data quality in order to smooth the path to CDM onboarding and ensure that CMS systems and end users are protected.

Published on: 2/3/2026

3 minute read

What is data quality and why is it important?

Data quality (DQ) ensures that data collected into the Centers for Medicare & Medicaid Services (CMS) ecosystem is accurate and has the required structure for the subject matter. DQ activities include establishing DQ metrics and thresholds, as well as cleansing and correcting data as needed.

Good data quality ensures that the data serves its intended purpose for the mission of the system and its users. It helps CMS make sound decisions to reduce risks that could negatively impact environments. 

Data quality and CDM

Data quality is an integral part of onboarding FISMA systems at CMS to the Continuous Diagnostics and Mitigation (CDM) program. CDM uses automated scanning tools to identify and prioritize cyber risks and support rapid response. It ensures compliance with OMB and FISMA mandates and enhances enterprise-wide visibility.

For systems using AWS Cloud, CMS Hybrid Cloud is the pathway to getting started with CDM – and that requires teams to ensure their systems are reporting data correctly. There are steps taken at both onboarding and offboarding to ensure good data quality.

Data validation and onboarding

As part of CMS Hybrid Cloud onboarding, data fields and flows are verified logically to capture and report data accurately. Data is validated before synchronizing data flow within the cyber risk reporting tools. Teams should complete these tasks before beginning the onboarding process:

Tasks to do before onboarding

Task

Location

Details

Confirm the TLC status phase is NOT listed as “Initiate”. 

CFACTS

For onboarding to continue, the TLC status phase must be listed as “Operate”.

Talk to the CMS Cloud team that manages the environment and review all AWS Cloud Accounts before onboarding to ensure the CAMP DB team will have the correct accounts to align to the right systems. 

CMS Hybrid Cloud

AWS applications and platforms must adhere to Gold Image requirements.

Check hosting coordinator

CMS Hybrid Cloud onboarding assistance

Verify that all platforms have been updated properly.

Submit a service ticket

Hybrid Cloud support

Submit a ticket to begin the onboarding process.

Data decommissioning and offboarding 

Decommissioning data affects end-user access and may trigger reclassification of FISMA systems. Proper decommissioning activities – including the management of offboarding roles – will reduce the number of access errors along the way. 

To ensure smooth decommissioning, teams should:

  • Develop a lifecycle plan for the assets that includes maintenance and decommissions. 
  • Coordinate access removal for downstream data consumers and remove permissions from consumer roles as needed.
  • Update the configuration lifecycle to ensure user lists reflect accurate access rights at both group and individual levels.
  • Ensure that all on-premises assets (applications and servers) are up to date with vulnerability and firmware updates. 

Conclusion

Strong data quality depends on consistent onboarding practices, accurate validation, and coordinated decommissioning efforts. These steps help reduce reporting issues, support cleaner data flows, and ensure systems are reflected correctly within the CDM and Cyber Risk Management (CRM) programs. These practices strengthen visibility and help teams make informed decisions – keeping their environment aligned with mission and security requirements. 

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About the author

Vanessa Thomas (ASSYST) is an M.S. Project Manager and ITIL Intermediate in Service Transition, specializing in enterprise systems security and release management. She contributes to ongoing data quality and system management efforts within CMS.

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About the publisher

Cyber Risk Management (CRM) at CMS supports the continuous evaluation, identification, and management of risk to keep our systems and sensitive data safe. We help CMS stakeholders use modern tools to take a proactive, data-based approach to security compliance.

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