FedRAMP & FISMA Compliance: Key Differences Explained
FedRAMP… FISMA… CISA… NIST… government compliance is an alphabet soup of acronyms. Keeping them straight is a job in and of itself. It doesn’t help that compliance standards like FedRAMP vs FISMA are both distinct but with overlap that blurs the lines.
If you’re a cloud service provider (think: SaaS or cloud infrastructure provider) then this article will help you sort through fog and come away with a clear idea of what applies to you and why.
What is FedRAMP?
Federal Risk and Authorization Management Program (FedRAMP) is a compliance standard and certification program. It enables federal agencies to take advantage of the latest SaaS and cloud infrastructure offerings by creating a standard security and compliance evaluation process. Established in 2011, FedRAMP is the “verify” component of the security adage “trust but verify” that enables Federal agencies to access the productivity gains of modern software services.
To get the full low-down on FedRAMP, see our complete guide.
What is FISMA?
The Federal Information Security Management Act (FISMA) is a United States federal law. It was designed to address the risk that grew out of maturation of the internet from a curiosity to a viable market for commerce (post dot-com boom/bust) and the growth of interest in cybercrime to divert some of the new commercial gains into pockets of criminals. It was, also, a response to the fact that the most current legislation that provided guidance to federal agencies was the Computer Security Act of 1987 which was 15 years outdated by the time FISMA superseded it.
FedRAMP vs FISMA: A Comparison
Scope & Applications
- FedRAMP applies to cloud service providers (CSPs) that offer SaaS or cloud infrastructure products and services to federal agencies. If your company provides cloud solutions, you’ll need FedRAMP compliance to do business with the US government.
- FISMA applies to federal agencies and any external companies providing information systems or services to these agencies. This encompasses a broader range of IT systems beyond just cloud services.
Model
- FedRAMP is founded on a “do once, use many times” ethos where cloud services can be authorized once and re-used across multiple agencies. A massive efficiency gain versus the previous method of being certified by each individual agency.
- FISMA uses an agency-specific approach and prioritizes flexibility. It requires each federal agency to assess and authorize its own information systems. Agencies are responsible for implementing security controls, conducting risk assessments, and granting Authorization to Operate (ATO) for their systems.
Goals
- FedRAMP is a specific framework for achieving secure systems in cloud environments. It aims to ensure CSPs meet the necessary protection levels for federal data while also accelerating the adoption of secure cloud services.
- FISMA is a general framework to guide agencies when developing their own security and compliance frameworks. FedRAMP is an example of a specific framework that meets the broad mandates of FISMA.
Governing Bodies
- FedRAMP is managed by the Joint Authorization Board (JAB), which includes representatives from the Department of Defense (DoD), Department of Homeland Security (DHS), and the General Services Administration (GSA).
- FISMA is overseen by the Office of Management and Budget (OMB), with implementation guidelines published by the National Institute of Standards and Technology (NIST).
Process
- FedRAMP involves a rigorous process of security assessment, authorization, and continuous monitoring. It begins with a readiness assessment, followed by an evaluation by an accredited third-party assessment organization (3PAO).
- FISMA requires agencies to achieve a number of high-level information security goals, such as, inventory systems, categorize information, conduct risk assessments, implement security controls, and continuously monitor these controls. It defers specifics to NIST which has published documents like the Risk Management Framework (RMF), NIST 800-37 and the Control Catalog, NIST 800-53. These reference documents were then incorporated into FedRAMP.
Helpful Tools
- Tools that support automated compliance and continuous monitoring for both frameworks:
- Anchore Secure: Vulnerability scanning tools
- Anchore Enforce: Automated NIST & SSDF compliance solutions
- Governance, risk and compliance (GRC) platforms
- Security information and event management (SIEM) systems
- FedRAMP authorization and continuous monitoring tools include…
- Anchore Enforce: Automated FedRAMP compliance solutions
- Automation and orchestration tools
- Cloud security posture management (CSPM)
- FISMA doesn’t have any purpose-built tooling because the law is purposefully general and requires that federal agencies create their own frameworks that implement the general mandates.
Where FedRAMP & FISMA Overlap
- Goals: Both FISMA and FedRAMP are designed to protect the security and integrity of federal information systems. They aim to ensure that federal agencies and their contractors maintain adequate information security controls to protect sensitive data.
- Framework: Both programs utilize NIST to define specific security and compliance controls. The standards that NIST produced for both FISMA and FedRAMP are the RMF, NIST 800-37 and the Control Catalog, NIST 800-53. They outline a standardized approach to risk management, which includes categorizing IT systems, selecting and implementing security controls, and continuously monitoring those controls.
- Continuous monitoring: Both FISMA and FedRAMP emphasize the importance of continuous monitoring of IT systems. This involves regularly assessing the effectiveness of security controls and making adjustments as needed to address emerging threats and vulnerabilities.
Choosing Between FedRAMP and FISMA
This is a bit of a false choice. You don’t choose between FedRAMP vs FISMA since they apply to different types of organizations. Federal agencies have to be compliant with FISMA and are required to purchase software and services from companies that are FedRAMP-compliant. CSPs on the other hand have to choose between meeting FedRAMP compliance and being able to sell to agencies or not. FedRAMP is a specific framework that meets FISMA compliance, CSPs inherit FISMA compliance through FedRAMP.
Next Steps
FedRAMP vs FISMA are closely related topics but with enough overlap that distinguishing between the two can be difficult at times. This article is meant to help demystify the sometimes blurry distinction. If you’re ready to move beyond this high-level overview and dips your toes into the more technical aspects of FedRAMP compliance, we would recommend our:
- FedRAMP Pre-Assessment Strategy Playbook for Containers and;
- FedRAMP Requirements Checklist for Container Vulnerability Scanning
Learn about best practices for achieving FedRAMP and SSDF compliance.
