Incident Response (IR) at CMS: Responding Quickly to Protect Systems and Data

At the Centers for Medicare & Medicaid Services (CMS), safeguarding our information systems requires more than strong preventive controls. It also demands the ability to respond quickly and effectively when an incident occurs. The Incident Response (IR) program provides this capability by ensuring CMS can rapidly detect, contain, and recover from cybersecurity and privacy events that may impact the confidentiality, integrity, or availability of our systems and data.

Why Incident Response Matters

Today’s cyber threat landscape is constantly evolving. Even organizations with mature security programs face risks such as targeted attacks, accidental data exposure, or system disruptions. The CMS IR program is essential in helping the agency:

• Detect and analyze cybersecurity and privacy incidents
• Coordinate timely, effective responses across teams and systems
• Contain and recover from threats while minimizing disruptions
• Investigate incidents and apply lessons learned
• Meet federal and CMS policy requirements

By maintaining a consistent, agency-wide approach to incident response, CMS strengthens its cyber resilience and helps ensure continuity of care and critical services for millions of beneficiaries.

How CMS Implements Incident Response

CMS aligns with federal requirements—including the Federal Information Security Modernization Act (FISMA)—and follows best practices outlined in NIST SP 800-61 Revision 3. Internally, the Information Systems Security and Privacy Policy (IS2P2) and Acceptable Risk Safeguards (ARS 5.1) guide how incident response actions are planned and executed.

The CMS Cybersecurity Integration Center (CCIC) and its Incident Management Team (IMT) lead enterprise-wide coordination. Every CMS information system must also maintain a system-level Incident Response Plan (IRP) that aligns with the agency’s overarching IRP.

Key Features of CMS’s IR Program

Structured Incident Handling Process

CMS uses a four-phase lifecycle to ensure consistent and effective incident handling:

• Preparation: Risk assessments, system hardening, training, and tool readiness
• Detection and Analysis: Monitoring activity, reviewing logs, and evaluating indicators of compromise
• Containment and Recovery: Isolating affected components, restoring services, and preserving evidence
• Post-Incident Activities: Conducting lessons-learned reviews and updating plans or procedures

Training and Exercises

To ensure readiness across the agency:

• All CMS employees and contractors complete annual IR training.
• System Owners, Business Owners, and ISSOs receive additional role-specific training.
• Tabletop exercises simulate real-world events to test and refine CMS’s response capabilities.

Automated Tools for Monitoring and Response

CMS leverages several enterprise tools to support rapid detection and coordinated incident handling:

• ServiceNow for reporting and tracking incidents
• RSA Archer/CFACTS SecOps for communication with HHS and forensic support
• Splunk as the enterprise SIEM for real-time threat monitoring and correlation

Reporting Requirements

Any CMS personnel who suspects a cybersecurity or privacy incident must report it to the CMS IT Service Helpdesk within one hour. Reports should include details such as the affected system, data involved (e.g., PII/PHI), and the time of discovery.

Coordination Across Programs

Incident response activities are closely integrated with other CMS cybersecurity programs, including vulnerability management, configuration management, contingency planning, and continuous monitoring. CMS also coordinates with the Office of the Inspector General (OIG), Senior Official for Privacy (SOP), and the HHS Privacy Incident Response Team (IRT) when appropriate.

Continuous Improvement and Oversight

CMS reviews its IR policies and plans annually—or sooner if a significant incident occurs. The IMT analyzes trends, identifies gaps, and incorporates lessons learned from exercises and real-world events. This continuous improvement process helps ensure CMS’s IR capabilities remain strong, current, and adaptive to emerging threats.

In Conclusion

Incident Response is a vital part of CMS’s cybersecurity strategy. From early detection to full recovery, the IR program is designed to act quickly and effectively to protect CMS systems, safeguard sensitive data, and maintain the public’s trust. Whether you manage a system, lead a business process, or simply use CMS technologies, your awareness of and adherence to IR procedures is essential.

For more information, visit the CMS IR Informational Guide on CyberGeek or contact your Information System Security Officer (ISSO).