What is FISMA Compliance – 7 FISMA Compliance Checklist

2015 saw one of the most notable data breaches related to the U.S. government. Hackers had gained access to 22.1 million records of federal employees from the US. Office of Personnel Management (OPM), including sensitive information such as Social Security Numbers, addresses, etc. The breach led to incidents of identity theft and national security risks—all of which were preventable if only the OPM had heeded the repeated warnings they had received about security weaknesses.

The breach highlighted the critical importance of strong cybersecurity measures and compliance to frameworks like FISMA, designed to protect sensitive government information. Standards like FISMA not only increase the accountability of federal agencies but help safeguard themselves against security weaknesses and implications at the national level.

This blog is a beginner’s guide to FISMA compliance, the key requirements, benefits, challenges, and more. Let’s get started. 

What is FISMA Compliance?

FISMA, or Federal Information Security Management Act, is a U.S. Federal law enacted in 2002 that provides a framework to protect government information and operations by requiring federal agencies to implement an information security program.

• FISMA is a part of the broader E-Government Act passed by Congress in 2002
• The National Institute of Standards and Technology (NIST) provides security controls and guidelines for implementation of FISMA
• FISMA (Federal Information Security Modernization Act) was amended in 2014 when President Obama signed a bill for its modernization. The updated version enhanced the role of DHS (Department of Homeland Security), updated breach notification requirements, revised reporting requirements, and made several other additions.

Who needs to comply with FISMA?

FISMA applies to any organization dealing with federal government information. This includes:

• Federal agencies and departments within the United States
• State agencies that administer federal programs such as Medicare, student loans, unemployment insurance, etc.
• Private sector firms that sell services to the federal government or receive federal grant money. 

However, private companies cannot be FISMA compliant as the framework only applies to federal agencies. Private companies often need an Authorization to Operate (ATO) to demonstrate that their information systems and practices meet the requirements.

How to get FISMA Compliant?

To get FISMA compliant, you need to fulfill the 7 requirements of FISMA and build a strong information security program. Once you implement the catalog of security controls, conduct an assessment of security controls to evaluate if the federal systems meet the requirements, and based on the results, you’ll receive an ATO.

Here’s the 7-step FISMA checklist you need:

1. Maintaining Information Systems Inventory

Government agencies (or their contractors) must maintain an inventory of federal information systems, including hardware, software, network components, etc. The agencies must also document and maintain interconnections between these information security systems and those outside agency control.

2. Categorization of risk

Agencies must categorize their data and information systems based on risk levels as low, medium, and high. The risk severity must be determined based on the impact level. Any system that contains sensitive information that can acutely impact the U.S. government will be a high-risk system. The guidance for this categorization is included in NIST SP 800-60.

3. Develop a System Security Plan

Federal agencies must develop and maintain a System Security Plan that details baseline security controls and the plan of action. The SSP must provide a snapshot of which controls are implemented, how they are implemented, and the progress relating to each control.

4. Implementation of security controls

NIST SP 800-53 provides a detailed list of twenty controls for FISMA compliance. Federal agencies must choose and implement appropriate controls based on their organizational requirements. The selected controls must be documented in the SSP.

5. Conducting risk assessments

Agencies must seek guidance from NIST’s Risk Management Framework (RMF) and perform a three-tiered risk assessment. These tiers help identify risks at the organizational, business process, mission or information system-level. Identified risks must be prioritized based on severity, and any additional or appropriate security controls must be implemented.

6. Certification and accreditation

After documentation processes and risk assessments, agencies must conduct annual security reviews to get certified. The security Certification and Accreditation process (C&A) is defined in NIST SP 800-37. The Office of Management and Budget (OMB) requires and manages the process for quality control.

7. Continuous monitoring

Accredited agencies must continuously monitor security controls, manage configurations, and document system modifications. Risk assessments must also be carried out in case of significant changes. Activities like impact analysis of system changes and status reporting must be regular to ensure compliance.

You can manage these requirements by bringing your FISMA framework to the Sprinto dashboard. The compliance automation tool enables you to automatically map requirements, enables control implementation and collects evidence automatically.

Benefits and challenges of FISMA compliance

FISMA compliance lays the foundation for enhancing your cybersecurity posture as it is based on the NIST publication’s guidance. It protects federal information, making you more eligible for future government contracts and better opportunities.

Benefits

Protection of sensitive information

Government data is highly sensitive, and any impact can have catastrophic results. FISMA compliance primarily helps protect any financial data, personal information or confidential data related to government operations from unauthorized access, disclosure, or destruction. It takes a risk-focused approach to implementing controls and fortifying defenses.

Enhanced incident response

FISMA requires organizations to prepare an incident response plan as a part of the overall information security program. The plan helps organizations prepare better for security incidents and respond faster to minimize the impact of a successful attack.

Cost savings

FISMA compliance enables streamlined operations and ensures that IT security investments are based on risks. This also helps in resource optimization and operational efficiency, bringing in cost savings. Next, reduced incidents and better preparedness also help minimize the costs of breaches and non-compliance.

Better trust and reputation

FISMA compliance helps assure customers, stakeholders, and the public that the agency upholds high standards of integrity in protecting sensitive information. Especially for small contractors competing for government contracts, demonstrating tight information security controls can provide a competitive advantage. 

Challenges

At the same time, businesses face some challenges with the implementation because of information overload and practical implementation difficulties. Let’s take a look at FISMA challenges:

Creating an accurate inventory

Several federal agencies struggle with the initial scoping exercise where they must determine what systems and data must be a part of the program. The dynamic environment and a mix of legacy systems, cloud services, third-party systems, etc. make creating an accurate inventory of assets challenging.

Control implementation complexities

The guidance for control implementation is generic and needs to be customized per specific business requirements. Customization is necessary to address the complexities of multi-cloud environments, the Internet of Things (IoT), AI, and other emerging technologies. Organizations may also need to comply with other frameworks which can further create control implementation difficulties.

Resource constraints

Small agencies have limited budgets, staff, and expertise. They may also rely on external support for IT services. The resource constraints make it demanding to build and implement a full-fledged security program and prioritize security measures.

Lack of relevant metrics

FISMA compliance has been called out for the lack of relevant performance metrics to evaluate the effectiveness of security programs. It focuses heavily on security program development but needs to address the issues of gaps in security posture.

Best practices for FISMA

Following FISMA best practices can help you build a culture of compliance and eventually move towards continuous compliance readiness, which is the ultimate goal. You are already aware of the general best practices such as encryption of data, annual security reviews, regular risk assessments, configuration management etc. 

Here are 5 best practices for FISMA:

Familiarize yourself with baseline documents

FISMA requirements come primarily from 3 basic documents: FIPS 199 (Federation Information Procession Standard), FIPS 200, and NIST publications (NIST SP 800-53, NIST SP 800-60). These publications and compliance standards contain useful information such as a guide to mapping information and systems, Risk Management framework basics, security best practices, etc. Understanding these can help you accurately incorporate the right recommendations and expedite the process.

Sprinto supports the NIST framework and you can read about NIST basics here.

Keep testing controls

Conduct regular security assessments internally and get controls tested by an external party for an unbiased opinion. Regular testing and monitoring are crucial even after you get certified to make the renewal processes easier and ensure continuous compliance.

Understand and map standard controls

Frameworks like NIST, ISO 27001, Fedramp, and HIPAA share some common controls with FISMA. If you are subject to multiple frameworks, minimize duplication of efforts by mapping common compliance requirements. This way you can also utilize the same evidence for more than one standard at the time of audit and expedite certification processes.

With Sprinto you can leverage magic mapping. The platform automatically maps common controls across frameworks and makes it easier for you to get compliant across multiple security standards in less time.

Maintain documentation and reports

Maintain detailed documents and centralize their management. Since you do not implement every control suggested, it is crucial to document which controls have been implemented and the reasons for not selecting other controls. Documentation also serves as a tool for training and awareness.

Keep abreast of latest updates

Stay informed about the latest updates of both NIST and FISMA frameworks. Subscribe to mailing lists, attend workshops and webinars, review federal government websites and other useful resources. It helps you keep proactive in the evolving landscape.

Consequences of FISMA non-compliance

Non-compliance with FISMA may lead to the perception that your business lacks credibility. This can directly result in strict government actions such as censure, lawsuits, penalties, etc.

These are the consequences of FISMA non-compliance:

Funding cuts from the federal government

Federal agencies that fail to prioritize information security and FISMA compliance face government funding withdrawal. It can be an overall budget cut, a reduction in funds for a special program, or a loss of grants.

Penalties and government hearings

For theft of government data or other extreme compliance violations, agencies and contractors can face penalties and repeated government hearings. This takes a lot of time and resources and brings you in the headlines for the wrong reasons.

Tarnished reputation

Non-compliance can negatively affect public perception because your agency can no longer be trusted to protect sensitive information. The reputational damage can slow down the sales cycles and have a long-term impact on business operations.

Loss of government contracts

FISMA compliance is a mandate for participating in federal contracts. Agencies failing to comply may lose out on future contracts from the government in case of a severe violation and where high risks are discovered during investigations.

Security events and breaches

Failing to comply has a direct impact on the security posture of the organization and causes weakened defenses. FISMA non-compliance leads to gaps in security controls, increasing the chances of cyber threats, attacks, or data breaches.

Difference between FISMA and FEDRAMP

FEDRAMP or Federal Risk and Authorization Management Program is a U.S. government compliance program for federal agencies using cloud services to ensure security and protection of sensitive information. It provides a standardized approach to security assessments, authorization, and monitoring of cloud services for their safe adoption by agencies.

FEDRAMP and FISMA are often compared because they are both focused on security of federal information and are based on guidelines from NIST standards. However, they both are different in purposes and have distinct requirements.

Have a look at the differences:

Basis	FISMA	FEDRAMP
Scope	Covers all federal agencies, contractors and private businesses that deal with federal information	Covers cloud service providers that host federal information for agencies
Control implementation	Requires agencies to select and implement controls based on NIST 800-53 as per business security requirements.	Requires Cloud service providers to implement specific controls laid out in FedRAMP Security Assessment Framework (based on NIST 800-53)
Assessments	The assessments are performed by federal agencies	The assessments are performed by 3PAO (third-party assessment organization)
ATO process	Companies must obtain a fresh ATO from every federal agency they work with	FedRAMP ATO’s are a one-time effort and once a CSP obtains it, it can be used by every federal agency.

Manage FISMA with Sprinto’s Custom Framework Management

FISMA requires continuous visibility into controls, which means that organizations must shift from traditional paperwork and manual approaches to digitized and automated compliance. Sprinto as a compliance automation tool helps you leverage streamlined workflows across several frameworks such as NIST, ISO 27001, FedRAMP etc. and custom framework management for FISMA.

With Bring Your Own Framework (BYOF) you can import FISMA controls onto Sprinto’s dashboard and easily activate automated checks for compliance. 

Additionally, you can leverage control overlap and reduce the workload by reusing efforts done for frameworks such as NIST. Expand the scope of your compliance program with automated evidence collection, security policy templates, in-built training modules, role-based access controls and more.

FAQs

What are the 3 levels of FISMA compliance?

 The 3 levels of FISMA compliance are low impact, moderate impact and high impact. The classification is based on the severity of the impact of operations and information assets.

What is the key difference between NIST and FISMA?

The key difference between NIST and FISMA is that NIST develops guidelines and controls while FISMA requires federal agencies to implement these standards.

What is an Authorization to Operate (ATO)?

An ATO is an official declaration by an authorizing official that the information systems have been evaluated for security and the organization is authorized to operate while acknowledging the risks associated with their operations.

What is the role of OMB in FISMA Compliance?

The OMB is responsible for providing FISMA guidance to agencies and oversight of their implementation efforts.