Cloud computing has become an essential component of everyday life. It has improved the effectiveness of our work and more essentially enabled everyone to experience greater convenience at lower costs.

In recent years, cloud computing grew from being a disruptive technology itself to becoming the foundation of a plethora of interruptive technologies. Studies revealed that cloud computing has already surpassed the $100 billion mark and is predicted to reach $150 billion by the end of the year.

The massive growth can be attributed to enterprises moving to cloud computing in the hopes of reducing the cost of managing and maintaining their IT systems as well as ensure flexibility of work practices. Statistics further indicated that 67 percent of enterprise infrastructure would be moving to the cloud by the end of 2020.

 

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What is FedRAMP?

The rise of cloud computing has put significant emphasis on the government to move to commercial cloud services. Additionally, the government is encouraged to use cloud-based services if they are available to meet the mission needs of the governmental organization. 

This move is all geared towards trimming costs within the government as they attempt to consolidate data centers. The expanded use of cloud services within the government has also increased the need to be able to provide a standardized way to assessing the security posture of these cloud services and authorizing them for use within federal agencies. 

That is why the Federal Risk and Authorization Management Program (FedRAMP) and the Federal Information Security Management Act (FISMA) were established to protect government data and minimize information security risk within federal data systems. They are also developed on the foundation of the National Institute of Standards and Technology (NIST) Special Publication (SP) 800-53A controls. 

 These controls include maintenance, media protection, access controls, awareness and training, audit and accountability, planning, risk assessment, personal security, and incident response. They also share the same commands when it comes to contingency planning, configuration management, security assessment and authorization, program management, system and service acquisition, and identification and authentication. 

FISMA and FedRAMP also use similar requirements with the capability to provide prescriptive implementation levels depending on the risk within each system. Moreover, the impact level and the number of controls assessed can be broken down further within each control family. 

The controls are implemented based on the classification of the system as a high impact, moderate impact, or low impact. The number of restrictions designated to an information system may increase considerably from little effect to medium impact and from moderate impact to high impact as well. Networks that are assessed FISMA and FedRAMP are also classified under FIPS 199. 

Despite their similarities, there is a distinct contrast between these concepts in terms of authorization, security controls, and federal policies. Generally, FedRAMP was designed to make the cloud service procurement method easier on organizations. 

On a more granular level, FedRAMP is geared more particularly at cloud service providers. Data systems assessed under FedRAMP for use by government agencies are commercial cloud-based systems used by private-sector businesses. 

Cloud-based systems assessed under FedRAMP are also required to work with the FedRAMP Program Management Office as part of issuing an agency-specific authorization to operate. The FedRAMP PMO is responsible for critical milestones across the assessment process like the security assessment report review, kickoff meeting, and the authorization process. Before the development of FedRAMP, individual federal organizations managed their assessment methodologies adhering to the guidelines set by FISMA.  

FedRAMP also provides a way for commercial cloud services to be authorized for use throughout the whole federal government. The security posture of retail cloud service providers is assessed by Third-Party Assessment Organizations (3PAO) that have passed a meticulous accreditation process by the American Association of Laboratory Accreditations (A2LA). 

3PAOs are responsible for performing a risk assessment based on the results of the security evaluation as well. This risk evaluation will serve as a guide to federal Authorization Officials (AO) since these people are the only ones who can accept risks on behalf of their federal agency. 

 The CSP will receive a FedRAMP authorization to operate if the agency AO classifies the risk for their operational environment. FedRAMP does not deploy innovative controls as well, but it adds controls from the NIST baseline controls.

Besides an assessment from 3PAO, providers can also work directly with organizations to get a FedRAMP Agency authority to operate certification. These authorizations are designed for niche cloud services that may only be used for a handful of clientele. 

FedRAMP also has a marketplace that provides everyone with a searchable and sortable database of civil society organizations that have achieved a FedRAMP designation. The FedRAMP Marketplace also features 3PAOs and are maintained by the FedRAMP PMO. 

On the other hand, FISMA covers the compliance parameters of the processing and storage of government information. It requires federal organizations and their private-sector vendors to apply data security controls that guarantee data security postures of national data systems are safeguarded. The FISMA article also requires all private-sector firms that sell services to the federal government to adhere to FISMA requirements. 

The main framework for FISMA compliance is adhering to NIST SP 800-53. In other words, vendors must implement the recommended information security controls for federal information systems as identified in the NIST SP 800-53 to be FISMA compliant. Usually, FISMA evaluations concentrate on information systems that support a single organization. 

Unlike FedRAMP, FISMA-compliant vendors only receive the authority to operate from the particular federal organization with which they are doing business. If the vendor has business agreements with a myriad of governmental organizations, they are required to acquire an authority to operate from each agency because security controls may differ depending on the specific data security needs.

The organization only receives the approval to operate if they successfully undergo a FISMA assessment and has an approved plan in place for mitigating all risks and findings. Organizations under FISMA are also required to initiate annual risk assessments to ensure that standard and new data security risks are prevented. 

 

FISMA vs. FedRAMP: Why FISMA is the Better Option?

While achieving a FedRAMP certification brings a wealth of benefits, organizations with on-premise information systems that support a single agency should opt for a FISMA assessment from RSI Security. This is because achieving FISMA compliance increases the security of your information system and protects private data while reducing IT-related costs. 

 Technically, FISMA was established to require each federal organization to concoct, record, and employ an all-encompassing security measure to protect and support the operations of the agency. FISMA was one article in a more significant piece of legislation known as the E-Government Act, which was created to recognize the importance of data security to the national and economic interests of the United States. 

The FISMA regulation was amended by the U.S. Congress in 2014 to ensure that it can blend in with the present problems concerning information security. The evolvement of FISMA has urged federal organizations to use more constant tracking and concentrate on compliance than what was needed in the previous legislation. 

Originally, FISMA compliance was only applicable to federal organizations. However, the regulation has evolved, covering state agencies that manage federal programs and businesses with contracts to work with federal groups. In short, private sector businesses that work with national organizations must also comply with the similar data security standards as the federal agency.  

Failure to adhere to FISMA compliance may lead to severe violations that include the loss of federal funding. This could mean prove catastrophic for a federal agency and could be the end of your organization if you are a federal contractor. Other than that, penalties for FISMA compliance violations may also include a loss of reputation due to bad press or data breaches and missing out on federal project bid opportunities. 

 

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How to Become FISMA-Compliant?

 FISMA is perhaps one of the essential regulations for federal information security standards and guidelines. Not only that it was introduced to minimize the security threat to national data, but it was also designed to help manage federal spending on information security. 

NIST plays a critical role in the FISMA implementation project as it produces the essential security standards and guidelines required by FISMA. These standards include FIPS 199, FIPS 200, and the NIST 800 series. Among the primary requirements to increase the chances of being compliant with FISMA include:  

• Creating a List of Information Systems. FISMA requires every federal organization to have an information systems inventory in place. The organization must determine the integrations between these data systems and other systems within their network as well.  

• Classify Information and Data Systems Based On Risk Level. All dossier and data systems should be classified based on the goals of providing sufficient degrees of information security according to a range of risk levels. The Standards for Security Categorization of Federal Information found FIPS 199 describes a variety of risk levels within which agencies can place their information systems. 
• Set Security Controls. Federal data systems should be able to meet the minimum security requirements defined in the following mandatory security standard required by FISMA legislation. The method of choosing the appropriate security controls and assurance requirements for organizational data systems is to accomplish sufficient security and ensure flexibility with baseline controls. This enables organizations to adjust the security controls to guarantee that it tightly fits with their operational environments and mission requirements.

• Establish a System Security Plan. Agencies are required to develop policies on the system security planning process as outlined on NIST SP 800-18. The system security plan is a significant input to the security accreditation and certification procedure for the system. Governmental organizations and contractors should also ensure that their system security plans are evaluated, updated, accepted, and are consistent with the FIPS 199 security category to move into the next step. 

• Perform Risk Assessments. A risk assessment of an organization helps validate the security controls set and recognizes if any further restrictions are needed to safeguard the assets, operations, and the individuals within the agency as well as the nation. The risk assessment starts by pinpointing potential vulnerabilities and mapping implemented controls to each risk. An auditor will subsequently estimate the impact and likelihood that any given threat can be exploited. The assessment culminates by displaying the calculated risk for all threats while describing whether the risk should be accepted or denied. 

• Certification and Accreditation. The controls of the information systems should be reviewed and certified to ensure proper function after the risk assessment and documentation have been completed. Agency officials should also acquire the most trustworthy, accurate, and complete information on the security of data systems to make risk-based, timely, and credible decisions on whether to authorize the operation. 

All FISMA-accredited information systems are required to track a chosen set of security controls. Changes and modifications to the policies should also be recorded on the system documentation to avoid losing the accreditation.

Organizations accredited by FISMA are also obliged to perform constant monitoring activities like security impact analyses of changes to the system, consistent security control assessments, and configuration management. The federal organization also must establish the schedule for control monitoring to make sure that sufficient coverage is achieved. 

 In most cases, organizations that begin categorizing information at its more granular levels move closer to achieving FISMA compliance. Starting at the most basic level enables these organizations to establish security layers up as they add measures related to subsequent layers of the corporation. 

FISMA also encourages organizations to reassess the agency-level information threats that do not appear at the primary level. This enables agencies to determine where additional security measures are needed and implement tracking practices over their security systems as it communicates with employees, contractors, and other organizations. 

 

In Conclusion

Staying compliant with FISMA increases the data security of an organization while reducing IT-related expenditures to the federal agency. FISMA encourages organizations to reassess the agency-level information threats that do not appear at the primary level. This enables agencies to determine where additional security measures are needed and implement tracking practices over their security systems as it communicates with employees, contractors, and other organizations.

An RSI Security risk assessment is a great place to start your FISMA compliance journey. Our experts will emphasize the risk of sensitive information and track your data for potential cyberattacks. Find out more about FISMA compliance by talking to RSI Security today.