The U.S. federal government has many laws and regulations intended to assure strong cybersecurity for government agencies. Two of the most important are the Federal Information Security Management Act (FISMA) and the Federal Risk and Authorization Management Program (FedRAMP).

Both FISMA and FedRAMP have the same fundamental goal: to assure that federal agencies and their vendors protect government data. That said, they also differ in many ways. This article explores those similarities and differences, so that any government agency or government contractor can understand the cybersecurity compliance obligations your organization faces.

What Is FISMA Certification?

The Federal Information Security Management Act (FISMA) is a federal law enacted in 2002. It defines cybersecurity standards and guidelines to protect government information. FISMA requires federal government agencies and their contractors to meet these information security standards to protect the government operations, data, and systems.

FISMA’s requirements represent industry best practices around risk management and cybersecurity. Organizations that comply with these requirements (regardless of whether they’re federal agencies, federal contractors, or non-federal companies) are usually better prepared to address cyber threats, respond to data breaches, and strengthen their security posture.

Who Needs FISMA Compliance?

Initially, FISMA (Federal Information Security Management Act) standards were established with the specific aim of safeguarding the IT infrastructure, information, and information systems utilized by U.S. government agencies. The goal was to bolster security and ensure the integrity of governmental operations at the federal level.

However, as the digital landscape has evolved and interdependencies have increased, the reach of FISMA has expanded significantly. Today, it’s not just federal agencies that must adhere to these stringent standards. A broader array of entities now falls under the FISMA compliance umbrella, including:

  • State Government Agencies: Those involved in administering programs that are a collaboration between state and federal governments are required to meet FISMA standards. This ensures a cohesive and secure approach across different levels of government.
  • Private Sector Contractors: Companies that engage with federal agencies, whether by providing technology solutions, software, or services, must also comply. This includes Software-as-a-Service (SaaS) vendors and Cloud Service Providers (CSPs) whose platforms and services are integral to federal operations.

In essence, FISMA compliance has become a critical consideration for any organization that enters into a contract with the federal government, receives federal grants, or plays a role in supporting federal programs. This broad application underscores the importance of robust information security practices across all sectors that interact with the government, ensuring a unified and secure framework for protecting critical data and infrastructure.

How Is FISMA Applied?

FISMA is distinct in its application compared to other regulatory frameworks. Unlike laws such as HIPAA, which impose significant penalties for non-compliance and apply broadly across entire organizations, FISMA adopts a more targeted and nuanced approach to ensure information security.

Focused Assessment of Security: FISMA is unique in that it evaluates the security measures of individual information systems rather than the entire organization or agency. This granular approach allows for a more detailed assessment of specific areas of vulnerability and security within a system.

The Role of the Authorizing Official (AO): Central to FISMA‘s implementation is the role of the Authorizing Official. Typically a senior manager with a deep understanding of information security, the AO is tasked with a critical responsibility. They must evaluate and determine whether the information systems of their agency, or those of contractors working with the agency, meet the stringent standards set out by FISMA.

Assessment and Authorization Process: Regardless of whether an agency manages its systems internally or outsources them, the AO conducts a thorough assessment of the system’s compliance with FISMA. Upon a satisfactory evaluation, the AO issues an Authority to Operate (ATO). This authorization is not merely a formality; it’s a testament to the system’s security and compliance with federal standards. Whether the agency runs the systems in-house or outsources management to another party, the AO will assess the system’s FISMA compliance and provide an ATO sign-off.

Implications of an ATO: The issuance of an ATO is a pivotal moment in the FISMA compliance process. It signifies that a system has met the necessary requirements and is deemed secure enough to operate. However, it also implies accountability. Should there be a data breach or an unauthorized access incident involving a system with an ATO, it can lead to severe repercussions for the agency and the AO, highlighting the stringent nature of FISMA‘s compliance and security standards.

FISMA‘s approach to ensuring information security is specific, thorough, and holds individuals at high levels of responsibility accountable. By focusing on individual systems and involving high-level officials in the compliance process, FISMA ensures a dedicated and detailed approach to protecting federal information systems.

Understanding NIST and FISMA certifications

The National Institute of Standards and Technology (NIST) produces FISMA’s security guidelines and standards. Federal agencies and contractors use these guidelines to categorize information and information systems. Appropriate information security controls are implemented based on a range of applicable risk levels.

NIST has also developed the minimum information security requirements that information and information systems in each category must satisfy. These security requirements fall into three groups: technical security, operational, and management.

Risk-Based Security Categorization: NIST‘s guidelines assist organizations in identifying and categorizing information and systems based on the potential impact of security breaches. This risk-based approach ensures that resources are allocated effectively, focusing more stringent security measures on systems where a breach would be most detrimental.

Comprehensive Security Requirements: Beyond categorization, NIST has delineated minimum security requirements that must be met by information and systems in each category. These requirements are meticulously designed to cover all aspects of information security:

  • Technical Security Controls: These involve safeguards implemented and executed by computer systems, including access control mechanisms, encryption, and intrusion detection systems.
  • Operational Controls: Operational controls are focused on the procedures and mechanisms that are executed by people, such as security training, incident response protocols, and maintenance procedures.
  • Management Controls: These controls encompass organizational security policies and procedures, which include risk assessment methodologies, security planning, and the oversight of security operations.

Continuous Updates and Guidance: In response to the evolving cyber threat landscape and technological advancements, NIST continuously updates its guidelines and standards. It ensures that FISMA‘s framework remains robust, responsive, and in line with current best practices and emerging threats. This ongoing effort includes publishing special publications, offering training, and facilitating workshops to aid in the understanding and implementation of its guidelines.

Promoting a Culture of Security: NIST‘s role extends beyond setting standards; it’s about fostering a culture of continuous monitoring and improvement. By providing tools, frameworks, and guidance, NIST helps agencies not just comply with FISMA but also embed security into their DNA, ensuring a resilient and secure federal information infrastructure.

In essence, NIST‘s contributions to FISMA are dynamic and multifaceted, reflecting the complexities and necessities of modern information security. Its ongoing work ensures that federal agencies and contractors have access to the latest, most effective strategies and tools to protect the nation’s critical information infrastructure.

Managing FedRAMP and FISMA Compliance

The FISMA certification process starts by classifying the federal agency or contractor according to the security sensitivity of the operations in question. That is, would a breach lead to low-, moderate, or high-impact security disruption?

Whatever that category is, the agency or contractor must then implement the appropriate information security controls as dictated by NIST standards. (NIST has defined 18 categories of security controls that might be needed, depending on the impact level.) To meet FISMA’s compliance requirements, the agency or contractor must implement all necessary controls.

As part of the FISMA assessment and compliance process, agencies and vendors must maintain an inventory of all in-use information systems. The inventory list should specify how the systems integrate with the enterprise network. In addition, the agency or contractor must:

  • Categorize information by risk to ensure that sensitive information gets the highest possible security;
  • Create, maintain, and update a system security plan;
  • Perform risk assessments at three levels: organization, business process, and information system.

Once the organization successfully completes all these activities, it gets FISMA certification. To retain that accreditation, FISMA compliant organizations are subject to annual reviews.

FISMA Compliance Benefits

FISMA compliance is mandatory for all government agencies and the contractors that want to work with them. For the latter, compliance indicates that solid information security controls are in place to protect government systems and sensitive data.

FISMA’s risk management approach and cybersecurity framework can also benefit any organization looking to secure its information systems from cyber threats.

What Is FedRAMP Certification?

Since 2011, the federal government has been trying to move its IT infrastructure to the cloud to reduce sprawl and fragmentation. To this end, the Cloud First Initiative was launched to help federal agencies realize the value of cloud computing at a faster pace. The initiative requires agencies to evaluate secure cloud computing options before making new investments.

The Federal Risk and Authorization Management Program (FedRAMP) allows agencies to understand which cloud providers are secure enough for the agencies to use.

All CSPs that want to provide cloud services to federal agencies must comply with both FISMA and FedRAMP. FedRAMP, in particular, provides a standardized approach to help CSPs achieve FISMA compliance and certification.

How FedRAMP Works

There are two categories of FedRAMP compliance:

  • Joint Authorization Board Provisional Authority to Operate (JAB P-ATO)
  • FedRAMP Agency Authority to Operate (ATO)

The rules for JAB P-ATO certification are more stringent than the rules for ATO certification. Also, earning JAB P-ATO requires a more significant investment of time and resources. Moreover, JAB P-ATO has to be approved by:

  • FedRAMP Project Management Office (PMO)
  • Joint Authorization Board which consists of officials from the:
    • General Services Administration (GSA)
    • Department of Homeland Security (DHS)
    • Department of Defense (DoD)

Nonetheless, achieving JAB P-ATO can also bring more benefits to CSPs since it gives them freedom to work with any federal agency.

ATO certification rules are less stringent, and more suitable for CSPs that intend to work with only one or two agencies. The CSP must be “sponsored” by a federal agency to earn ATO, and in effect, the agency assumes the risk for the CSP.

Distinctions Between FISMA and FedRAMP Certifications

Both FISMA and FedRAMP certifications are related to the security of information and information systems. FISMA and FedRAMP are also both based on the security controls recommended by the NIST’s SP 500-83. Many of these controls are common to both.

Differences

Applicable Scope

FISMA provides guidelines for protecting all kinds of information and information systems. FedRAMP applies FISMA rules to one specific category of IT: cloud computing and cloud security. Its guidelines pertain to federal agencies adopting cloud service providers and protecting government data in the cloud.

In other words, FedRAMP is the version of FISMA that’s specifically applicable to the cloud and CSPs. All federal agencies and contractors must be FISMA certified. FedRAMP certification, however, is only required for CSPs working with federal agencies.

Number of Controls

Another difference is that FedRAMP has more controls than FISMA. These controls are specifically related to CSPs. For example, FedRAMP has 326 and 421 controls, respectively, for moderate-impact and high-impact cloud services. FISMA has only 261 and 343 controls, respectively, for all moderate-impact and high-impact information solutions and services.

ATO Requirements

To maintain an Authority to Operate (ATO) with U.S. federal agencies, CSPs must achieve and maintain both FISMA and FedRAMP certifications. That said, there are differences in the ATO certification process for each.

For instance, CSPs pursuing FedRAMP ATO must pass a 3PAO assessment (see the FedRAMP Certification Process section above). FISMA certification doesn’t require a 3PAO assessment.

Risk Assumption

Another difference is in the assumption of risk. Under FedRAMP, the federal agency that uses (or plans to use) a CSP assumes the risk of outsourcing information system management. With FISMA compliance, each agency and organization is responsible for managing its own compliance.

How To Determine Which Information Security Risk Compliance You Need

Navigating the landscape of information security risk compliance can be daunting. The key to determining which compliance framework is right for your organization involves a deep understanding of your business operations, data, and regulatory environment. Here’s a step-by-step guide to help you make an informed decision:

  1. Understand Your Data and Systems: Begin by thoroughly mapping out the type of data you handle. Is it sensitive personal information, health records, financial data, or federal information? Identifying the nature and sensitivity of your data will help determine the level of security needed.
  2. Identify Regulatory Requirements: Different industries are subject to different regulations. Understand the specific laws and regulations that apply to your industry and operations. This may include HIPAA for healthcare, GLBA for financial services, or FERPA for educational institutions.
  3. Assess Your Relationships: Consider your relationships with other entities. If you’re a contractor for the federal government, you may need to comply with standards like FISMA or FedRAMP. Understand the compliance requirements of your partners, customers, and suppliers.
  4. Evaluate Your Risk Profile: Conduct a risk assessment to understand your vulnerabilities and the potential impact of security incidents. This will help you prioritize the security controls that are most critical to your organization.
  5. Consult with Experts: Consider consulting with legal counsel or a compliance consultant who can provide expert advice tailored to your specific situation.
  6. Review and Decide: Review the requirements, costs, and benefits of each relevant compliance framework. Consider the long-term implications of compliance, including ongoing monitoring and updates.

Remember, the goal of compliance is not just to check a box but to protect your organization and your customers from the ever-evolving landscape of cyber threats.

How to choose between FISMA vs FedRAMP

Choosing between FISMA and FedRAMP depends largely on the nature of your organization’s operations and its relationship with federal agencies. Here’s how you can decide:

  1. Understand the Purpose and Scope:
    • FISMA is geared towards federal agencies and organizations that create, collect, or manage federal information on behalf of the government. It’s about managing information security for all aspects of federal operations.
    • FedRAMP is specifically designed for cloud service providers (CSPs) that serve federal agencies. It provides a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services.
  2. Determine Your Service Model:
    • If your organization provides cloud services to federal agencies, FedRAMP will be your necessary path. It’s not just about compliance; it’s about ensuring that your cloud services meet the strict security requirements needed to serve the federal government.
    • If your organization operates more broadly with federal information in non-cloud environments or has a diverse IT infrastructure, FISMA is more applicable.
  3. Consider the Type of Data and Systems:
    • FISMA applies to all types of data and systems, whether they are hosted on-premises or in the cloud. It’s about ensuring the security of federal data across the board.
    • FedRAMP is focused solely on cloud environments and the specific risks associated with cloud computing.
  4. Review Your Contracts and Obligations:
    • Review any contracts or agreements with federal agencies. They often specify the required compliance standards. If you’re working under a contract that requires FedRAMP, the choice is clear.
    • If your work with the federal government is more varied or not exclusively cloud-based, FISMA may be the more relevant framework.
  5. Consult with Federal Partners:
    • If in doubt, consult with your federal partners. They can provide guidance on the compliance requirements for your specific contracts and services.
  6. Seek Expert Advice:
    • Consider seeking advice from compliance consultants or legal experts who specialize in federal information security requirements.

Choosing between FISMA and FedRAMP is a strategic decision that should align with your organization’s specific operations, services, and federal engagements. By carefully considering your unique circumstances and requirements, you can select the compliance path that best ensures the security and integrity of your operations and federal partnerships.

Maintain Your Certifications and Compliance Posture with ZenGRC

An automated, intuitive, and visual GRC tool like ZenGRC can help your organization simplify and speed up the FedRAMP and FISMA certification process.

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