Compliance Frameworks for Doing Business with the US Government

Introduction

• Analogy of athletes crossing a river to describe different approaches to government compliance.
• Common goal: doing business with the US federal government.
• Focus on understanding three frameworks: FISMA, FedRAMP, and NIST.

FISMA (Federal Information Security Management Act)

• Introduced in 2002; mandates federal agencies to develop and implement information security programs.
• Applies to:
  • Federal government agencies
  • State agencies administering federal programs
  • Private firms supporting federal programs or receiving federal grants
• Authorization Process:
  1. Identify risks
  2. Build a System Security and Privacy Plan (SSP)
  3. Conduct an assessment
  4. Post-assessment review
  5. Obtain an Authorization to Operate (ATO) and plan for future risks
• ATO required from each federal agency separately.
• Assessment can be done by the agency or a third-party assessment organization.
• Requirements based on:
  • Federal Information Processing Standard 199
  • Federal Information Processing Standard 200
  • NIST 8503

FedRAMP (Federal Risk and Authorization Management Program)

• Established in 2011 to support the federal government’s cloud-first initiative.
• Provides a centralized security program for cloud service providers (CSPs).
• Applies to:
  • Cloud service providers (SaaS, PaaS, IaaS)
  • Contractors and subcontractors of CSPs
• Authorization:
  • A single FedRAMP ATO permits business with any federal agency.
  • Requires rigorous certification by a FedRAMP-approved third-party.

NIST (National Institute of Standards and Technology)

• Develops the NIST 853 standard and other frameworks like NIST 8171 and NCSF.
• Provides standards and risk assessment frameworks for cybersecurity.
• Functions as a guideline for how to become compliant with FISMA and FedRAMP.

Differences Between FISMA, FedRAMP, and NIST

1. Who Needs Compliance:
   • FISMA: All federal agencies and related companies.
   • FedRAMP: Third-party CSPs hosting federal information.
   • NIST: Critical infrastructure operators, including federal agencies and related companies.
2. Verification of Certification:
   • FISMA: ATOs from each agency separately.
   • FedRAMP: One-time ATO by FedRAMP-approved third-party.
   • NIST: No formal certification, but compliance can be assessed.
3. Nature:
   • FISMA: Federal law
   • FedRAMP: Program
   • NIST: Non-regulatory agency providing guidelines

Similarities Between FISMA, FedRAMP, and NIST

• All focus on improving security of information systems, specifically for the American federal government.
• Enable businesses to standardize cybersecurity processes to work with the federal government.
• Increasingly adopted by the private sector for their comprehensive security measures.

Getting Compliant

• Shift towards automated, digital, and integrated compliance methods.
• Use of tools like Sprinto for compliance automation and continuous monitoring.
• Resources:
  • Free NIST 8503 controls checklist
  • Sprinto for streamlined compliance processes

Conclusion

• Consider consulting with cybersecurity experts or using automated tools for efficient compliance.
• Additional resources and support available for further assistance.