Understanding FISMA and FedRAMP

This article aims to clarify the differences between FISMA and FedRAMP to help IT/security directors, security managers and CFOs make informed decisions about compliance strategies.?

What is FISMA?

FISMA is a United States federal law enacted in 2002 and updated in 2014. Its primary purpose is to help ensure the security of federal information systems and the data they process, store and transmit.?

Key components of FISMA

FISMA promotes risk-based security management, requiring organizations to assess and mitigate potential threats to their information systems. The Act also mandates continuous monitoring of these systems to promptly detect and respond to security incidents. Additionally, FISMA requires the implementation of security controls based on guidelines set forth by the?National Institute of Standards and Technology (NIST). Regular reporting on the organization’s security posture is another crucial aspect of FISMA compliance.?

Scope and applicability

Compliance with FISMA is mandatory for a wide range of entities. This includes all federal agencies, state agencies that administer federal programs and private sector organizations that support or interact with federal information systems. FISMA’s broad scope underscores its importance in maintaining the security of government data across various sectors.?

What is FedRAMP?

FedRAMP?was established in 2011. It provides a standardized approach to security assessment, authorization and continuous monitoring for cloud products and services used by federal agencies.?

Key components of FedRAMP

FedRAMP establishes standardized security requirements specifically for cloud service providers (CSPs) seeking to work with federal agencies. It employs a “do once, use many times” framework for security assessments, allowing CSPs to leverage a single authorization across multiple agencies.??

This approach significantly streamlines the process for both providers and government agencies. FedRAMP also emphasizes ongoing monitoring and reporting requirements for continued compliance and security. The program fosters collaboration between government agencies and CSPs, promoting a unified approach to cloud security in the federal sector.?

Scope and applicability

FedRAMP compliance?is specifically required for CSPs looking to offer their services to federal agencies. This focused approach helps ensure that cloud services used by the government meet a consistent, high standard of security.?

Similarities between FISMA and FedRAMP

While FISMA and FedRAMP serve different purposes, they share some common ground. Both frameworks aim to protect government data and reduce information security risks, forming a comprehensive approach to federal information security. They both use?NIST Special Publication 800-53?as a foundation for security controls, establishing a consistent baseline across different compliance requirements. Risk management and the implementation of appropriate security measures are emphasized in both FISMA and FedRAMP, reflecting the proactive approach needed in today’s cybersecurity landscape. Additionally, both frameworks strongly emphasize continuous monitoring and reporting, recognizing that security is an ongoing process rather than a one-time achievement.?

FISMA vs FedRAMP – What’s the difference?

Despite their similarities, FISMA and FedRAMP have several crucial differences.??

Scope and applicability?

FISMA applies to all federal information systems, including both on-premises and cloud-based solutions. In contrast, FedRAMP is specifically designed for cloud services used by federal agencies, reflecting the government’s increasing reliance on cloud technologies.?

Authorization process??

FISMA requires authorization from each individual agency, creating a one-to-one relationship between the service provider and the agency. On the other hand, FedRAMP provides a “do once, use many times” approach, allowing a single authorization to be leveraged across multiple agencies. This difference can significantly impact the efficiency of the compliance process for organizations working with multiple government entities.?

Assessment requirements?

FISMA assessments can be conducted by the agency itself or a third party, offering some flexibility in the evaluation process. FedRAMP, however, requires assessment by an accredited Third-Party Assessment Organization (3PAO). This standardized approach promotes consistency across all cloud service providers seeking FedRAMP authorization.?

Certification rigor?

While both FISMA and FedRAMP are comprehensive, FedRAMP is generally considered more stringent due to its standardized approach and the potential for wider use across multiple agencies.?

Compliance process

While compliance is crucial for FISMA and FedRAMP, it’s important to understand the difference in the relevant processes.

FISMA compliance process

Achieving FISMA compliance involves a structured process.?This process helps ensure that federal information systems maintain a high level of security and protect sensitive data effectively.?

Steps to achieve authorization?

1. Organizations must categorize their information systems based on potential impact, classifying them as low, moderate or high risk.??
2. Select and implement appropriate security controls from NIST SP 800-53.??
3. Assess the effectiveness of these controls so they adequately protect the system and its data.

Once the controls are in place and verified, the information system is authorized for operation. However, FISMA compliance doesn’t end there. Organizations must maintain compliance by continuously monitoring and regularly reporting on their security posture.?

Required documentation

Documentation plays a crucial role in the FISMA compliance process. Organizations are required to develop and maintain several key documents. These include:?

• System Security Plan(SSP):?Outlines the system’s security requirements and controls
• Security Assessment Report (SAR):?Details the results of the security assessment
• Plan of Action and Milestones (POA&M):?Addresses any identified vulnerabilities or areas for improvement.?

FedRAMP compliance process

The?FedRAMP authorization process?is equally structured but tailored specifically for CSPs.??

Steps to achieve authorization

1. Preparation phase:?CSPs develop the required documentation and implement necessary security controls.?
2. Assessment phase:?A 3PAO evaluates the CSP’s security posture.?
3. Authorization phase:?The CSP works with either a sponsoring agency or the Joint Authorization Board (JAB) to obtain an Authority to Operate (ATO). This authorization is a critical milestone in the FedRAMP process. However, like FISMA, FedRAMP compliance is an ongoing process.??
4. Continuous monitoring:?This involves ongoing assessment and reporting of security controls by CSPs to maintain their authorization status.?

Role of third-party assessment organizations (3PAOs)

Third-party assessment organizations (3PAOs) play a crucial role in the FedRAMP process. These accredited organizations conduct independent assessments of CSPs’ security implementations, ensuring a standardized and thorough evaluation of each provider’s security measures.?

Choosing between FISMA and FedRAMP?

Selecting the appropriate compliance framework is a critical decision for organizations working with federal agencies. The choice between FISMA and FedRAMP depends on various factors and can significantly impact an organization’s operations and opportunities in the federal market.??

Factors to consider when exploring FISMA vs FedRAMP

When deciding which standard to pursue, organizations must consider several factors:?

• Nature of services provided:?Whether services are cloud-based or on-premises can dictate which framework is more appropriate?
• Requirements of target federal agencies:?Some agencies may specifically require either FISMA or FedRAMP compliance?
• Resource availability:?FedRAMP typically requires more resources and time due to its rigorous assessment process and ongoing monitoring requirements?
• Potential return on investment:?For cloud service providers aiming to work with multiple federal agencies, FedRAMP certification can:
• 1.?Open doors to a broader range of federal contracts
• 2.?Potentially offer a strong return on investment??

Use cases for each framework?

Organizations providing non-cloud services or primarily working with a single agency may find FISMA more appropriate. Conversely, cloud service providers aiming to work with multiple federal agencies will likely need to pursue FedRAMP authorization.?

BPM for FISMA and FedRAMP

Understanding the critical differences between FISMA and FedRAMP is essential for organizations looking to work with federal agencies. While both frameworks share the goal of protecting government data, they differ in scope,?application and authorization processes.?

As you navigate the complex world of federal compliance, consider partnering with organizations that guide you through the process. BPM offers comprehensive services to help organizations achieve and maintain compliance with both FISMA and FedRAMP requirements. Our experienced professionals can assist you in assessing your current security posture, developing and implementing compliance strategies, preparing required documentation, conducting gap analyses and remediation planning, and providing ongoing support for continuous monitoring and reporting.??

To learn how we can help your organization navigate the complexities of FISMA and FedRAMP compliance,?contact us.??