The U.S. federal government is one of the largest organizations in the world, and a vast number of private businesses provide goods and services to the government as federal government contractors. This means that those contractors must pay close attention to two cybersecurity standards: the Federal Risk and Authorization Management Program (FedRAMP) and the Federal Information Security Management Act (FISMA).

Although these two standards both address cybersecurity, they do so in different ways and they are not at all the same thing. Contractors need to understand those differences as you strive to stay in the federal government’s good graces. This post will explore where FISMA and FedRAMP do, and don’t, overlap.

What Is FISMA?

The Federal Information Security Management Act (FISMA) is a U.S. federal law enacted as part of the Electronic Government Act of 2002. It requires federal agencies to develop, document, and implement an information security and protection program. 

FISMA’s core focus is on the security of data, the risk management process, and the importance of building a robust cybersecurity environment. By setting standards and guidelines, it helps agencies manage their information security systems effectively, ensuring confidentiality, integrity, and availability of critical data.

Who needs FISMA compliance?

FISMA compliance is primarily required for federal agencies and all entities that work with them. This includes:

  1. Federal agencies. All federal agencies are required to comply with FISMA to protect their data and information systems.
  2. Government contractors and subcontractors. Companies that provide services to federal agencies must also be FISMA-compliant, especially if they handle sensitive government data.
  3. State agencies receiving federal funding. State agencies that receive federal funds, particularly those involved in managing federal programs such as Medicare or Medicaid, are often required to adhere to FISMA standards.
  4. Information systems hosting federal data. Any organization that manages information systems on behalf of a federal agency must comply with FISMA regulations.

In essence, any organization that directly or indirectly deals with federal data and information systems must comply with FISMA requirements.

Why Is FISMA Important?

FISMA plays a crucial role in protecting sensitive government data and maintaining national security. FISMA dicates the security posture of federal agencies and their partners, guiding the overall cybersecurity infrastructure of the nation.

Here are some specific reasons why FISMA is important:

  1. Enhances national security. By safeguarding data against unauthorized access and cyber threats, FISMA bolsters national security.
  2. Protects sensitive data. FISMA assures that sensitive government data, including personal information of citizens, is protected against breaches and leaks.
  3. Standardizes security practices. FISMA creates a standardized approach for assessing and monitoring the risk associated with federal information and information systems.
  4. Promotes a culture of security. By mandating regular assessments and reporting, FISMA fosters a culture of continuous improvement and awareness regarding cybersecurity within government entities.
  5. Builds public trust. Effective implementation of FISMA builds the public trust in federal agencies’ ability to secure data and manage private information responsibly.

What Is FedRAMP?

FedRAMP is a program to standardize the security of cloud-based service providers (CSPs) that seek to offer their services to the federal government. FedRAMP spells out standards for security assessment, continuous monitoring, and authorization processes; and essentially acts as a seal of approval for CSPs. Any CSP that wants to bid on federal governments should be FedRAMP-compliant, or else that provider isn’t likely to win any of that business. 

The chief overseers of FedRAMP are the Office of Management and Budget (OMB), the General Services Administration (GSA), the Department of Defense (DoD), and the  National Institute of Standards and Technology (NIST). Together, they have established two primary types of authorizations:

  • The Provisional Authority to Operate (P-ATO) from the Joint Authorization Board (JAB); and 
  • The Agency Authority to Operate (ATO) that comes from an individual government agency.

FedRAMP’s requirements are based on the NIST Special Publication 800 series, which establishes various cybersecurity standards. To achieve FedRAMP compliance, CSPs must go through an independent security assessment carried out by a third-party assessment organization (3PAO) to assure that authorizations are in line with the Federal Information Security Management Act (FISMA).

FedRAMP compliance is vital because it allows government agencies to migrate from insecure legacy IT systems to more secure and cost-effective cloud-based IT.

Who Needs FedRAMP Compliance?

FedRAMP compliance is typically required for CSPs that want to work with U.S. federal agencies. This compliance assures that CSP’s offerings meet specific security requirements to handle federal information and data. Here’s a breakdown of who needs FedRAMP compliance:

  • Cloud service providers (CSPs). CSPs that want to offer their services to federal agencies must achieve FedRAMP compliance. This includes Infrastructure as a Service (IaaS), Platform as a Service (PaaS), and Software as a Service (SaaS) providers.
  • Government contractors and subcontractors. Companies that contract with federal agencies, particularly those handling sensitive federal data, often need to be FedRAMP-compliant. This is because they might use or provide cloud services as part of their contractual obligations.
  • Third-Party service providers. Organizations that provide services to CSPs which, in turn, work with federal agencies may also be required to comply with FedRAMP standards. This assures the entire supply chain maintains the requisite security levels.
  • State and local agencies. While not always mandatory, state and local government agencies sometimes choose to adopt FedRAMP standards for their cloud services to assure a high level of security.
  • Organizations seeking to adopt best practices. Private sector companies may also pursue FedRAMP compliance simply as a way to adhere to industry best practices for cloud security, even if those companies never bid on government contracts.

Why Is FedRAMP Important?

All CSPs working with federal agencies or holding federal data require FedRAMP authorization, which means those CSPs must comply with FedRAMP’s standards. CSPs won’t be able to do business with the federal government without being FedRAMP-compliant.

Many businesses and local governments also look for the FedRAMP “seal of approval” when choosing their own CSPs.

How Do FISMA and FedRAMP Differ?

FedRAMP is a regulatory requirement that spells out the cybersecurity standards that CSPs should achieve if they want to do business with the U.S. government. FISMA is a law that spells out what federal agencies themselves should do to protect confidential data in their possession.

Both FISMA and FedRAMP have the same basic objectives for keeping government data secure, and both rely on the NIST 800-53 security framework for specific controls that should be implemented. But FISMA and FedRAMP address different groups, and have somewhat different requirements (especially around third-party assessment of your cybersecurity program).

What Is the Difference Between FISMA and NIST?

FISMA is a law that dictates certain cybersecurity standards for U.S. government agencies. NIST is a government agency itself, which publishes security standards — including those that organizations should use to achieve FedRAMP or FISMA compliance.

Is FedRAMP the Same as NIST?

No. NIST is a government agency that provides frameworks and other guidance for organizations to achieve compliance with FedRAMP. Several NIST standards (in the 800 series of NIST standards) are crucial to achieving FedRAMP compliance, but they are not the same as FedRAMP’s compliance demands; they are elements within FedRAMP’s demands.

What is the FISMA Compliance Process?

The FISMA compliance process is a systematic approach to assure that federal agencies and their partners adequately protect the government’s information and assets. This process involves several key steps.

  1. Categorize information and information systems. The first step is to identify and categorize all information and systems based on the level of harm that a compromise could have on the agency’s operations, assets, or individuals.
  2. Select appropriate security controls. Based on the categorization, agencies must select relevant security controls from the NIST 800-53 standard. These controls are tailored to protect the confidentiality, integrity, and availability of information.
  3. Implement security controls. Once selected, these security controls need to be implemented effectively. This includes applying technical, administrative, and physical safeguards.
  4. Assess security controls. Regular assessments are conducted to assure that the controls are working as intended. This step often involves testing and evaluating the effectiveness of the security measures.
  5. Authorize the information system. A senior agency official reviews the CSP’s security package and decides whether the risk is acceptable. If it is, that official grants an Authorization to Operate (ATO).
  6. Monitor security controls. Continuous monitoring of security controls is essential for maintaining compliance. This involves regular reporting, security updates, and responding to new threats.

FISMA compliance is an ongoing cycle of activity, assuring that federal agencies continually adapt to evolving cybersecurity challenges.

What is the FedRAMP Compliance Process?

The FedRAMP compliance process is designed for CSPs aiming to offer their services to the U.S. federal government. This process entails:

  1. Initiation. The CSP selects a third-party assessment organization (3PAO) to help understand FedRAMP requirements and begin the compliance process.
  2. Document security controls. The CSP documents how its cloud service meets FedRAMP security controls in a System Security Plan (SSP).
  3. Assessment. The 3PAO assesses the CSP’s implementation of the security controls and produces a Security Assessment Report (SAR).
  4. Authorization. The CSP submits the SSP and SAR to the FedRAMP Program Management Office (PMO) and a Joint Authorization Board (JAB) or a federal agency for authorization. Authorization is either granted or denied, and if denied, the CSP must implement improvements to bring its offering up to standards.
  5. Continuous monitoring. Once authorized, the CSP must engage in continuous monitoring and reporting to assure ongoing compliance with FedRAMP requirements. This includes regular updates, vulnerability scans, and annual reassessments.

FedRAMP compliance is rigorous and assures that CSPs maintain the highest standards of security when offering cloud services to federal agencies.

How ZenGRC Can Help With FISMA and FedRAMP

ZenGRC provides an integrated solution for organizations navigating the complexities of FISMA and FedRAMP compliance. Its streamlined approach simplifies compliance workflows, offering automated tools to manage and assess necessary security controls. 

For FISMA compliance, ZenGRC aligns with NIST standards, assuring that federal agencies and their partners efficiently meet their security requirements.

For FedRAMP, ZenGRC proves invaluable for cloud service providers by aiding in the documentation, assessment, and continuous monitoring processes required by the program. Its comprehensive dashboard offers real-time insights into compliance status, risk management, and audit readiness, significantly reducing the manual effort and complexity often associated with compliance management. 

By integrating these capabilities into a single platform, ZenGRC makes it easier for organizations to maintain robust security postures while adhering to the stringent requirements of these federal compliance programs.

Schedule a demo and learn more about how RiskOptics can help you implement NIST 800-series security controls.

How to Upgrade Your Cyber Risk Management Program with NIST


How to Upgrade Your Cyber Risk
Management Program with NIST