If you work in network security, you may have heard of FedRAMP and FISMA, two federal frameworks that aim to ensure the security of cloud services and information systems. But what are they exactly, and how do they differ? In this article, we will explain the basics of FedRAMP and FISMA, and compare their scope, requirements, and benefits.
FedRAMP stands for Federal Risk and Authorization Management Program. It is a government-wide program that provides a standardized approach to assess, authorize, and monitor the security of cloud products and services used by federal agencies. FedRAMP was created in 2011 to promote the adoption of cloud computing while reducing the risks and costs associated with security compliance. FedRAMP uses a "do once, use many times" framework, which means that once a cloud service provider (CSP) obtains a FedRAMP authorization, it can be reused by multiple agencies.
The NIST Risk Management Framework (RMF) outlined in SP 800-37 defines a lifecycle approach for the security of information systems, and it provides an implementation plan for compliance with FISMA. FedRAMP extends the guidance provided by the RMF to focus specifically on solutions provided by cloud service providers (CSPs) that host US Government information systems, services, and data. The process to achieve FedRAMP certification is comprehensive and difficult. It ensures CSPs have a federal sponsor, and it ensures consistent implementation of controls and practices at defined security levels: low, moderate, and high.
At a very high level, FISMA is the overarching framework for federal information security management and FedRAMP is a program within that framework. FedRAMP specifically addresses cloud service provider security for federal agencies. Both play essential roles in securing federal information systems, though with distinct focuses and scopes
FISMA stands for Federal Information Security Management Act. It is a law that was enacted in 2002 to establish a framework for securing federal information systems and data. FISMA requires all federal agencies to develop, implement, and maintain an information security program that follows the standards and guidelines issued by the National Institute of Standards and Technology (NIST). FISMA also requires agencies to conduct periodic risk assessments, audits, and reports on their information security performance.
The key to FISMA is the Risk Management Framework (RMF) outlined in NIST Special Publication 800-37. The RMF allows federal agencies (and commercial organizations) to implement consistent protections based on a system lifecycle approach that focuses on the impact that a compromise of confidentiality, integrity, or availability of information would have on the organization. This data-centric approach is used to define what NIST calls a control baseline to ensure effective controls are in place to manage risk at a low, moderate, or high level. The framework also ensures involvement of senior leaders from the top of the organization to middle managers to the owners of data and information systems.
One of the main differences between FedRAMP and FISMA is their scope. FedRAMP focuses specifically on cloud services, while FISMA applies to all types of information systems, whether they are on-premise, hosted, or cloud-based. FedRAMP is also a voluntary program for CSPs, while FISMA is a mandatory law for federal agencies. However, if a federal agency uses a cloud service, it must comply with both FedRAMP and FISMA requirements.
FedRAMP is required for cloud service providers that host data and information that belongs to federal organizations. This ensures that the CSP has adequate controls in place to satisfy FISMA requirements. A federal organization usually sponsors a commercial CSP who seeks accreditation under FedRAMP. An accredited Third-party Assessment Organization (3PAO) completes the certification process similar to the approach used by AICPA for SOC certification. FISMA is required only for federal agencies of the US Government. Therefore, FedRAMP is only required for federal agencies.
Another difference between FedRAMP and FISMA is their requirements. FedRAMP has three baseline levels of security controls: low, moderate, and high, based on the impact level of the data processed by the cloud service. Each level has a different number of controls that the CSP must implement and document. FedRAMP also has a standardized process for obtaining an authorization, which involves three steps: initial assessment, authorization package submission, and continuous monitoring. FISMA, on the other hand, does not have predefined levels of security controls, but rather allows each agency to determine the appropriate level of security based on their own risk assessment. FISMA also does not have a uniform process for authorization, but rather relies on each agency's own procedures and policies.
FedRAMP and FISMA both have benefits for network security. FedRAMP can enhance cloud services and data security, reduce duplication of effort and cost for CSPs and agencies, increase trust and transparency between CSPs and agencies, as well as improve interoperability and innovation of cloud solutions. On the other hand, FISMA can improve security of information systems and data, increase accountability and oversight of information security practices, enhance compliance with federal laws and regulations, as well as reduce the risk of data breaches and cyberattacks.