Compliance is a top priority for federal agencies and the contractors that store and process sensitive government data. Even if an organization does not yet operate in the private sector, it is important to understand federal IT compliance standards like FISMA and FedRAMP. These government compliance standards can be complex as they often overlap and some apply only to certain groups. There are many similarities between FISMA and FedRAMP, along with some distinct differences.
The U.S. government is the largest buyer of goods and services in the world. Doing business with federal agencies requires businesses to meet strict compliance standards. FISMA and FedRAMP possess the same high-level goals of protecting confidential government data and minimizing information security risks across federal information systems. Learn more about FISMA and FedRAMP, the differences between them, and why it is important to meet compliance.
What is FISMA?
The Federal Information Security Management Act (FISMA) is a federal law passed in 2002 that provides security standards and guidelines that federal agencies are required to meet. FISMA calls on agencies to develop, document, and implement an information security program to protect sensitive government information and operations. Modified in 2014, FISMA emphasizes the importance of continual monitoring. .
Similar to other federal cybersecurity laws, FISMA enforces a rigorous set of rules designed to establish standards for IT departments in federal agencies to follow. Although FISMA was initially written to impose security standards on federal agencies, it also affects some private companies. Under FISMA, an Authorizing Official (AO) is responsible for determining if an information system complies with FISMA standards, regardless of whether the system is run by a federal agency or a private federal contractor.
What is FedRAMP?
The Federal Risk and Management Program (FedRAMP) is a cybersecurity risk management program used by U.S. government agencies that buy and use cloud-based products and services. Cloud service providers (CSPs) must obtain FedRAMP authorization before they can work with federal agencies. FedRAMP was implemented by the Office of Management and Budget (OMB) in response to the 2011 Cloud First Policy.
Requirements under FedRAMP are outlined in NIST 800-53, which represents the gold standard in cybersecurity. Authorization is only granted to CSPs through the FedRAMP Authority to Operate (ATO).
To achieve authorization and compliance, a CSP must complete all applicable FedRAMP documentation, implement controls in compliance with FIPS 199 categories, undergo an assessment by a third-party assessment organization (3PAO), and develop a Plan of Action and Milestones (POA&M). Next, they must obtain approval from the Joint Authorization Board (JAB), Provisional ATO (P-ATO) or Agency ATO, and finally implement a Continuous Monitoring (ConMon) program.
What are the Differences?
Both FISMA and FedRAMP reference the standards of NIST 800-53, but each has different objectives. While FISMA provides security guidelines to government agencies on how to keep data protected, FedRAMP provides security guidelines on how to protect sensitive government data to agencies looking to utilize a CSP. FedRAMP is essentially the CSP version of FISMA.
There is also a difference in the assumption of risk between FISMA and FedRAMP. With FISMA, the federal agency that uses a CSP assumes all risks associated with outsourcing information system management. Government agencies may require businesses to meet FISMA standards and CSPs may also be required to meet certain agency-specific standards. Some CSPs are required to complete multiple security assessments across several agencies to maintain an ATO.
Information systems that are evaluated under both FISMA and FedRAMP are categorized per FIPS 199 as either low, moderate or high. Based on the security categorization, further security controls from NIST SP 800-53 are applied as either low impact, moderate impact or high impact. However, FedRAMP requirements include several additional controls outside of the standard NIST baseline controls. These extra controls address various elements of cloud computing to ensure that data remains secure in cloud-based environments.
Certain requirements also differ between FISMA and FedRAMP. Cloud service providers seeking FedRAMP authorization must first pass a third-party security assessment. Although all federal agencies must undergo an independent assessment of their security control implementation, FedRAMP is the only type of implementation that currently requires a 3PAO assessment. Cloud service providers can obtain an ATO from the government in two ways: Joint Authorization Board Provision ATO (JAB P-ATO) or FedRAMP ATO.
Speak with the NYC IT Experts at SeaGlass Technology
Federal agencies in search of a FedRAMP-compliant CSPwill likely expect it to also be FISMA-compliant. It is important for CSPs to comply with both FISMA and FedRAMP standards and regulations to maintain an ATO from the federal government. The IT experts at SeaGlass Technology can help organizations become compliant through services like advisory consulting. For more information about the differences between FISMA and FedRAMP, schedule a consultation with SeaGlass Technology today.