Attachment F - ACF External System Control Implementation Policy and Procedures_20251203.docx

ACF External System Control Implementation Policy and Procedures

ACF OCIO

Version 0.1

Dated 12/3/2025

Table 1. Document Revision History

ACF External System Control Implementation Policy and Procedures iii

Table of Contents

1. Policy Statement The Administration for Children and Families (ACF) require all external systems that connect to, interface with, or provide services to ACF systems to implement ACF baseline security controls to ensure consistent security posture and risk management across the enterprise.

2. Authority

· Federal Information Security Modernization Act (FISMA)

· NIST SP 800-53 Rev. 5

· HHS Information Security and Privacy Policy (IS2P): Available on the HHS intranet.

Policies, Standards, Memoranda & Guide

· OMB Memoranda on Federal Cybersecurity

· Executive Order 13556, "Controlled Unclassified Information" (November 4, 2010).

· 32 CFR Part 2002, "Controlled Unclassified Information"

· Federal Information Security Modernization Act (FISMA) of 2014

· Privacy Act of 1974, as amended

· Federal Records Act

3. Scope This policy applies to all external systems, including but not limited to:

· Cloud service providers

· Contractor-operated systems

· Partner agency systems

· Third-party applications and services

· Interconnected systems

4. Compliance and Enforcement Non-compliance may result in connection termination. Regular audits will verify ongoing compliance.

Escalation procedures defined for non-compliance issues.

5. Roles and Responsibilities

6. Requirements ACF requires that any external information system connected to ACF systems must have an approved Authority to Operate (ATO) memo completed within the past 3 years. A security assessment or risk assessment will take place as soon as possible if Security Authorization is not already in place.

In addition, when ACF systems enter a trust relationship with external organizations, the following ACF-defined controls must be implemented:

· Documented description, specific use, and access restrictions for how restricted or highly restricted data will be processed, stored, or transmitted.

· Cloud Service Providers (and other external system owners) must enforce:

· Access controls aligned to documented and approved user roles, responsibilities, and privileges.

· Monthly reviews of all system accounts and access.

· Least privilege access for all users.

Access Control-20 (AC-20): Use of External Information Systems External systems connecting to ACF must:

1. Control Implementation: Implement security controls equivalent to ACF's system baseline controls as defined in the current ACF Control Baseline in Appendix X (Appendix X Rev5-Low and Appendix X Rev5-Moderate)

2. Provide documented evidence of control implementation through:

· System Security Plans (SSP)

· Security Assessment Reports (SAR)

· Plan of Action and Milestones (POA&Ms)

· Continuous monitoring reports

3. Submit to independent security control assessment by ACF-approved assessors or provide assessment report or certification (e.g. SOC 2 or ISO 27001 certification). The assessment must have occurred within 3 years of intended connection to the ACF system.

4. Execute formal agreements (Memorandums of Understanding (MOUs), Interconnection Security Agreements (ISAs), or contracts) specifying security control requirements.

Protecting Controlled Unclassified Information on External System External system providers must:

1. Establish and maintain information security and privacy programs that meet or exceed ACF baseline requirements as advised or stipulated within the security and privacy requirements (standard language) stipulated in contract or collaborative agreement.

ACF Tech Standard Language Document.

2. Demonstrate executive-level commitment to security program implementation.

3. Provide regular compliance reporting aligned with ACF's continuous monitoring strategy.

7. Appendix Standards and Guidelines

· NIST Special Publication 800-171, "Protecting Controlled Unclassified Information in Nonfederal Systems and Organizations"

· NIST Special Publication 800-53, "Security and Privacy Controls for Federal Information Systems and Organizations"

· CISA Cybersecurity Framework

· HHS Information Security Program Policy

References Chapter 2: Interagency Agreement: Available on the HHS intranet.

Chapter 2 - Interagency Agreeme

ACF Appendix X Rev5 Moderate and Low Baseline Control Selections:

Appendix X-Rev5-Moderate.xlsx

Appendix X Rev5-Low.xlsx image2.png image3.png image4.png image1.png