Program Management at CMS: Strengthening Security and Privacy Across the Enterprise

At the Centers for Medicare & Medicaid Services (CMS), protecting information systems and sensitive data requires more than technical safeguards. It demands enterprise-level governance, leadership, and coordination. Program Management (PM) provides this foundation by ensuring security and privacy requirements are embedded in every CMS system, process, and mission activity.

Why Program Management Matters

In a rapidly evolving digital landscape, PM enables CMS to adapt to new threats, technologies, and federal mandates by:

• Establishing enterprise-wide security and privacy programs
• Maintaining formal program and privacy plans
• Ensuring compliance with FISMA, OMB A-130, the Privacy Act, and NIST standards
• Aligning risk management with CMS’s mission and strategic goals
• Coordinating security, privacy, and data governance across the enterprise

This framework protects sensitive information while supporting reliable healthcare services for millions of Americans.

How CMS Implements Program Management

CMS integrates PM controls across the organization to guide its security and privacy posture. Core components include:

• Program Plans: Documents defining CMS’s security and privacy requirements, common controls, and risk management practices.
• Leadership and Governance: Oversight from the CISO, SAOP, Risk Executive, Data Governance Body, and Data Integrity Board.
• Risk Management Strategy: Organizational risk tolerance and continuous monitoring practices, reviewed annually.
• System and Data Inventories: Enterprise tracking of systems and PII to ensure proper use, minimization, and transparency.
• Authorization and Oversight: Standardized processes for system authorization, risk acceptance, and ongoing monitoring.

Key Features of CMS’s PM Program

Training and Workforce Development

• Role-based training for security and privacy professionals
• Insider threat and awareness programs to reduce internal risks

Performance and Monitoring

• Outcome-based performance measures aligned with risk tolerance
• Continuous monitoring for near real-time visibility
• POA&Ms to track remediation across CMS

Collaboration and Threat Awareness

• Participation in federal and industry groups to share intelligence and best practices
• Automated tools to integrate threat indicators into monitoring processes

Privacy and Data Protection

• Enterprise privacy plans defining PII safeguards
• Processes for PIAs, disclosure accounting, and data quality management to ensure transparency and compliance

Continuous Improvement and Oversight

CMS regularly updates its program and privacy plans to reflect organizational changes, audit findings, and evolving federal requirements. Governance bodies monitor trends, oversee compliance, and strengthen accountability across the enterprise. By embedding PM into daily operations, CMS continuously improves its security and privacy posture.

Conclusion

Program Management is the backbone of CMS’s security and privacy strategy. It delivers the structure, leadership, and oversight needed to secure systems, protect data, and uphold CMS’s mission. Through strong governance, risk management, and workforce development, PM enables CMS to maintain public trust and provide secure, reliable services to the American people.