What is FISMA Compliance?
FISMA (the Federal Information Security Management Act) is a U.S. law requiring federal agencies, certain state agencies, and private government contractors to develop, document, and implement an information security and protection program.
Using key security standards established by the National Institute of Standards and Technology (NIST) Cybersecurity Framework, FISMA aims to reduce the security risk to federal information and data.
FISMA regulates information security, which it defines as “protecting information and information systems from unauthorized access, use, disclosure, disruption, modification, or destruction in order to provide integrity, confidentiality and availability.”
FISMA was created to ensure that federal agencies establish and maintain strong cybersecurity programs. It was enacted in 2002 and is associated with regulations like NIST SP 800-53 and NIST SP 800-37, setting standards and procedures for safeguarding government information systems.
Who Does FISMA Apply To?
When the E-Government Act was created in 2002, FISMA was its strongest component. At the time, the law only applied to federal agencies. Later, it expanded to cover state agencies that managed federal programs like Medicare, Medicaid, unemployment insurance, student loans, and so on.
FISMA doesn’t just stop with the public sector, it now includes companies that contract work with federal agencies. Even private organizations that must comply with FISMA guidelines and mandates if they are affiliated with government agencies — or face penalties for violations.
FISMA Compliance Checklist
Based on guidance from NIST, here are 6 steps to achieve FISMA compliance:
- Information System Inventory: Federal agencies or contractors must keep an inventory of all the information systems they use —this should include a record of maintenance or repairs, a record of service, description, manufacturer, model number, date of purchase, when it was deployed, and when the hardware was last updated.
- Risk Categorization: The Standards for Security Categorization of Federal Information and Information Systems (FIPS 199), lay out the guidelines for categorizing the risk levels of their information systems. Categorization identifies systems that hold the most sensitive data so agencies can then put the necessary security measures in place to protect it.
- System Security Plan: Agencies must create and maintain a security plan — and update it regularly. The plan should include security controls, policies, and a timeline for future security updates.
- Security Controls: NIST SP 800-53 serves as a catalog of security controls for FISMA compliance. These 20 controls should be adopted, documented, and monitored by agencies — dependent on what is relevant to their systems.
- Risk Assessments: Agencies should conduct regular risk assessments to see if there are any holes in their security process—especially anytime there is a change to their systems. Using the Risk Management Framework, agencies can identify risk at the organizational, business process, and information system levels.
- Certification and Accreditation: After all the previous steps have been completed, agencies must conduct annual security reviews that prove they can maintain and continuously monitor risk. To keep security risks to a minimum, continuous monitoring is key.
Implementing the ‘right’ FISMA Risk Assessment
FISMA (Federal Information Security Management Act) requires federal agencies to conduct various types of assessments to ensure the security of their information systems. The primary types of FISMA assessments include:
- Security Control Assessments (SCA): These assessments involve evaluating the effectiveness of security controls implemented within an information system. SCAs typically include testing, examination, and documentation review to determine whether controls are operating correctly and providing the intended security.
- Security Assessment and Authorization (A&A): Security A&A is a comprehensive process that includes security control assessments, risk assessments, and the final authorization of the information system. The A&A process leads to the decision to authorize the system for operation or to deny authorization.
- Risk Assessments: Risk assessments are critical to understanding and managing the security risks associated with an information system. Agencies assess vulnerabilities, threats, and the potential impact of security incidents to identify and prioritize risks.
- Vulnerability Assessments: These assessments focus on identifying and assessing vulnerabilities in an information system, such as software flaws or misconfigurations. Vulnerability assessments help agencies understand weaknesses that could be exploited by attackers.
- Penetration Testing: Penetration testing, also known as ethical hacking, involves actively attempting to exploit vulnerabilities in an information system to assess its security. This type of assessment is more hands-on and may simulate real-world attacks.
- Continuous Monitoring: Continuous monitoring involves ongoing, real-time or near-real-time tracking of an information system’s security status. This includes monitoring security controls, events, and incident detection to ensure that security remains effective over time.
- Self-Assessments: Agencies may conduct self-assessments to review their information systems for compliance with security controls and FISMA requirements. These assessments are often part of the ongoing monitoring process.
- Independent Verification and Validation (IV&V): In some cases, agencies may engage external entities or third-party assessors to independently verify and validate the security of their information systems. These assessments provide an objective view of security measures.
- Security Audits: Security audits involve reviewing an information system’s security documentation, configurations, and practices to verify compliance with FISMA and other security standards.
- Compliance Assessments: These assessments focus on ensuring that information systems are compliant with specific security regulations, standards, and guidelines, including FISMA, NIST, and other relevant requirements.
- Incident Response Assessments: These assessments evaluate an agency’s ability to detect, respond to, and recover from security incidents, including breaches and cyberattacks.
Penalties of FISMA Non-Compliance
Non-compliance with FISMA (Federal Information Security Management Act) can result in various penalties and consequences, which may include:
- Loss of Funding: Federal agencies that fail to meet FISMA compliance requirements may have their budgets reduced or face limitations on future funding for IT projects.
- Reputation Damage: Non-compliance can harm the reputation of an agency, eroding public trust and confidence.
- Legal and Regulatory Consequences: Depending on the severity of non-compliance, agencies may face legal action, fines, or sanctions.
- Security Incidents: Failure to comply with FISMA increases the risk of security incidents and data breaches, potentially leading to data loss, financial losses, and legal liability.
- Loss of Authorization: Non-compliance can result in the suspension or revocation of authorization to operate (ATO) for information systems, disrupting agency operations.
- Increased Oversight: Non-compliant agencies may face increased scrutiny, audits, and oversight from regulatory bodies, which can be resource-intensive and disruptive.
- Contractual Implications: Government contractors involved in federal projects may also face penalties, including contract termination or legal action, if they fail to meet FISMA requirements.
A loss or reduction in federal funding can be debilitating for both federal agencies and private vendors. For some private contractors, moreover, that loss — and the damaged relationships with federal agencies that can result from FISMA non-compliance — can spell the end of a company.
FedRAMP vs FISMA
While FISMA sets the compliance standard for information systems, FedRAMP outlines the requirements for cloud service providers (CSPs). The U.S. government encourages cloud computing as a way to reduce costs for federal agencies. The Federal Risk and Authorization Management Program (FedRAMP) is a government program that standardizes the way agencies approach CSPs.
This typically takes the form of security assessments, authorizations, monitoring, and more. Software vendors looking to land government accounts should explore FedRAMP authorization.
Agency-Specific FISMA Compliance Requirements
FISMA (Federal Information Security Management Act) requirements apply to all federal agencies, and while the core requirements are generally consistent across agencies, specific implementation and details can vary. Here’s a brief description of FISMA requirements for each of the agencies you mentioned:
- Department of Defense (DoD):
- DoD is responsible for implementing FISMA requirements to protect sensitive military and national security information.
- FISMA compliance includes securing classified and unclassified information systems, conducting regular risk assessments, and adhering to NIST security controls.
- It also involves strict access controls, continuous monitoring, and robust incident response capabilities due to the highly sensitive nature of DoD’s information.
- Department of Homeland Security (DHS):
- DHS plays a crucial role in safeguarding the nation’s critical infrastructure and addressing cybersecurity threats.
- FISMA compliance at DHS involves comprehensive risk assessments, adherence to NIST security controls, continuous monitoring, and coordinating security efforts across various federal and non-federal entities.
- Department of Health and Human Services (HHS):
- HHS is responsible for managing a vast amount of healthcare and public health information.
- FISMA requirements for HHS include securing healthcare data, conducting risk assessments, implementing NIST security controls, and ensuring compliance with the Health Insurance Portability and Accountability Act (HIPAA) for protecting sensitive patient information.
- Federal Bureau of Investigation (FBI):
- The FBI is tasked with protecting national security and investigating cybercrime.
- FISMA compliance for the FBI involves securing law enforcement information, conducting risk assessments, implementing NIST security controls, and having robust incident response capabilities for addressing cyber threats.
- Internal Revenue Service (IRS):
- The IRS manages a vast amount of sensitive taxpayer information.
- FISMA requirements for the IRS include protecting taxpayer data, conducting risk assessments, implementing NIST security controls, and ensuring compliance with tax-related laws and regulations.
- Environmental Protection Agency (EPA):
- EPA manages sensitive environmental data and information.
- FISMA compliance at EPA involves securing environmental data, conducting risk assessments, implementing NIST security controls, and ensuring that its information systems support environmental protection efforts.
- Social Security Administration (SSA):
- SSA manages extensive personal and financial information related to social security benefits.
- FISMA requirements for SSA include securing social security data, conducting risk assessments, implementing NIST security controls, and maintaining the confidentiality and integrity of beneficiary information.
- Department of Transportation (DOT):
- DOT oversees transportation infrastructure and safety and manages various types of sensitive data.
- FISMA compliance for DOT includes securing transportation-related information, conducting risk assessments, implementing NIST security controls, and ensuring the safety and security of transportation systems.
- Department of Education (ED):
- ED manages educational and student data.
- FISMA requirements for ED include securing educational information, conducting risk assessments, implementing NIST security controls, and ensuring the confidentiality of student records.
- Department of Energy (DOE):
- DOE manages sensitive energy-related information, including national security-related data.
- FISMA compliance for DOE includes securing energy information, conducting risk assessments, implementing NIST security controls, and protecting nuclear and energy-related data.
- Department of Defense (DoD):
How to Become FISMA Compliant with BigID
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Know your data risk — and reduce it: Prioritize your most high-risk, sensitive data. Identify and minimize risk on sensitive data with risk scores that incorporate data parameters like data type, location, residency, and more.
Achieve FISMA compliance: Maintain detailed records of information systems, stay on top of audits, and annually report on FISMA compliance.