What Is FISMA Compliance? Requirements and Best Practices

What Is FISMA? 

FISMA, also known as the Federal Information Security Management Act of 2002, is key U.S. legislation aimed at enhancing the security of data and information systems used by the federal government. This law was passed in response to the increasing reliance on information technology and the corresponding need to secure federal information systems against threats that could compromise their integrity, availability, and confidentiality. 

FISMA establishes a set of guidelines and standards developed by the National Institute of Standards and Technology (NIST) to ensure federal agencies and their partners implement robust information security controls. By emphasizing a risk-based approach to security, FISMA requires agencies to develop, document, and implement an information security program, which includes providing security protections for information collected or maintained by or on behalf of government agencies.

FISMA compliance is mandatory for all federal agencies as well as organizations that deal with federal agencies and their data. By complying with FISMA requirements, these agencies and organizations ensure they have implemented the necessary measures to protect the data and information they handle. FISMA compliance plays a crucial role in maintaining the integrity, confidentiality, and availability of the U.S. federal government’s data and information.

Recommended Reading: What Is SIEM, Why Is It Important and 13 Key Capabilities.

Who Must be FISMA Compliant? 

The following categories of organizations need to comply with the FISMA regulation:

• All federal agencies, regardless of their size or the nature of the data and information they handle.
• Any organization that contracts with a federal agency or handles federal agency data. This includes private sector organizations, state and local government organizations, and nonprofit organizations. The aim is to ensure that no matter who handles the federal government’s data, it remains secure.
• Third-party service providers who handle federal agency data must also be FISMA-Compliant. This includes cloud service providers and IT service providers.

Tips from the expert

Steve Moore is Vice President and Chief Security Strategist at Exabeam, helping drive solutions for threat detection and advising customers on security programs and breach response. He is the host of the “The New CISO Podcast,” a Forbes Tech Council member, and Co-founder of TEN18 at Exabeam.

In my experience, achieving and maintaining FISMA compliance requires a proactive and structured approach. Here are advanced strategies to help organizations streamline their compliance efforts and improve their security posture:

Use Continuous Diagnostics and Mitigation (CDM) Tools

Leverage CDM tools for real-time monitoring of vulnerabilities, configuration issues, and unauthorized access. These tools provide actionable insights into system security and compliance gaps, enhancing your ability to meet FISMA’s continuous monitoring requirements.

Automate Security Control Assessments (SCAs)

Use automated tools to regularly test the effectiveness of security controls. Automating SCAs ensures consistent evaluations and reduces the manual effort needed for compliance reporting.

Leverage NIST 800-53 Rev. 5 Enhancements

Incorporate the latest updates from NIST SP 800-53 Rev. 5, which emphasize privacy controls, supply chain risk management, and cloud security. This ensures your systems align with the most up-to-date FISMA requirements.

Implement Role-Based Access Control (RBAC)

Enforce RBAC to limit access to sensitive data and systems based on users’ roles and responsibilities. This minimizes the risk of insider threats and supports FISMA’s “least privilege” principle.

Develop a Dynamic System Security Plan (SSP)

Keep your SSP updated with system changes, new threats, and emerging compliance requirements. Use automated workflows to document updates in real-time, ensuring your SSP remains a reliable compliance artifact.

The Three Levels of FISMA Compliance 

There are three levels of FISMA compliance, determined based on the potential impact of a security breach on the federal agency’s operations, assets, or individuals:

• Low impact: Systems are classified as low-impact when the potential impact of a security breach is limited. In these systems, the unauthorized disclosure, modification, or unavailability of information would only have a limited adverse effect on organizational operations, assets, or individuals. For low-impact systems, FISMA mandates a basic level of security controls, which typically involve standard security measures like basic user authentication and access controls.
• Moderate impact: Systems are considered moderate-impact when the potential impact of a security breach is more serious but not severe. In these cases, the unauthorized disclosure, modification, or unavailability of information would cause a serious adverse effect on organizational operations, assets, or individuals. Moderate-impact systems require a more comprehensive set of security controls, including enhanced authentication, more rigorous access control policies, and stronger protection against cyber threats.
• High impact level: Systems are categorized as high-impact when the potential impact of a security breach is severe or catastrophic. In such systems, the unauthorized disclosure, modification, or unavailability of information would have a severe or catastrophic adverse effect on organizational operations, assets, or individuals. This might include threats to human life, severe economic damage, or major harm to national security. High-impact systems require the most stringent security controls, designed to protect against even the most sophisticated threats, such as advanced persistent threats. They include advanced encryption, multi-factor authentication, continuous monitoring, and incident response capabilities.

The National Institute of Standards and Technology (NIST) provides guidelines and minimum requirements for each level in its series of publications, particularly NIST Special Publication 800-53, “Security and Privacy Controls for Information Systems and Organizations.”

Each federal agency is responsible for categorizing their information and information systems according to these potential impact levels and for applying the appropriate level of security controls. The categorization must be reviewed periodically as changes to operations or new threats may alter the impact level of the systems.

FISMA Compliance Requirements 

Information System Inventory

Under FISMA, organizations are required to maintain an inventory of all information systems used within the agency. This inventory serves as a comprehensive list that includes details about each system, such as its purpose, environment of operation, and the information it processes. 

The inventory is critical for tracking the security status of each system and forms the basis for further FISMA compliance activities. Regular updates and audits of the inventory ensure that new systems are incorporated and decommissioned systems are removed, thereby maintaining the accuracy and relevance of the inventory.

Risk and Data Type Categorization

Under FISMA, organizations must categorize their risks and the types of data they handle to establish appropriate security measures. This categorization process involves evaluating the sensitivity and value of the information to determine the level of protection needed. Categories typically include confidential, restricted, and public information.

Sensitive information, such as personal identification details or national security data, requires higher security controls compared to less sensitive information. Categorizing data types helps in applying tailored security measures that are efficient and cost-effective, ensuring robust protection without over-securing less critical information. This process is crucial for the effective prioritization of security efforts and resources.

System Security Plan

The System Security Plan (SSP) is a formal document that outlines how an organization will implement and maintain the necessary security controls for an information system. Under FISMA, creating an SSP is a critical requirement. The SSP should provide a detailed overview of the security requirements of the system and describe the controls in place or planned to meet those requirements. 

The SSP also includes roles and responsibilities, security policies, and procedures related to the system. The SSP is a living document, meaning it requires regular updates to reflect changes in the system or operational environment.

Security Controls

Security controls are the safeguards or countermeasures that an organization employs to protect the confidentiality, integrity, and availability of its information systems. 

FISMA requires federal agencies to implement an appropriate set of security controls based on the risk categorization of their information systems. These controls can be managerial, operational, or technical in nature and are selected from a standard catalog of controls, such as NIST Special Publication 800-53. 

The implementation of these controls must be documented, and their effectiveness must be regularly tested and evaluated. The goal of these controls is to mitigate identified risks to an acceptable level, ensuring the security and resilience of the information systems.

Risk Assessments

Risk assessments are a core element of FISMA compliance, involving a thorough analysis of the potential risks to the confidentiality, integrity, and availability of an information system. This process includes identifying potential threats and vulnerabilities, assessing the likelihood of occurrence, and determining the potential impact of such events. 

The outcome of a risk assessment helps in understanding the level of risk to the system and informs decisions about the necessary security controls to mitigate these risks. Regular risk assessments are required to keep pace with the changing threat landscape and to ensure that the security controls remain effective over time.

Certification and Accreditation

Certification and Accreditation (C&A) are critical components of the FISMA compliance process, aimed at formally assessing and authorizing the security of information systems before they go live and periodically thereafter. The certification process involves a comprehensive evaluation of the technical and non-technical security features of an information system to ensure they meet the required security standards. This evaluation includes testing the effectiveness of security controls, identifying vulnerabilities, and assessing the risk posed by potential threats.

Following certification, the accreditation process involves a senior official within the agency reviewing the certification documentation and risk assessment results to decide whether the risks are acceptable. If the risks are deemed acceptable, the official grants the system authorization to operate (ATO). This decision is based on whether the security controls are adequate and effective in protecting the agency’s operations and assets. 

Accreditation is a crucial step because it signifies official acceptance of the risk to agency operations, assets, or individuals based on the implementation of an agreed-upon set of security controls. This process ensures that only systems that meet stringent security requirements are allowed to operate.

What Are the Penalties for Non-Compliance with FISMA?

Non-compliance with FISMA can have severe consequences for organizations. Government agencies who fail to comply with FISMA might face censure by congress and a reduction in federal funding. Non-government organizations face reputational damage and censure from entering future government contracts. 

Maintaining FISMA Compliance 

Here are some best practices that can help organizations achieve FISMA compliance.

Implementing Security Monitoring Plan for Data Activity and Threats Detection

To maintain FISMA compliance, organizations should implement a comprehensive security monitoring plan that includes continuous surveillance of data activity and the timely detection of security threats. This plan should outline procedures for monitoring network traffic, user activities, and access logs to identify unusual or unauthorized activities that could indicate a security breach.

Effective security monitoring involves the use of automated tools to analyze large volumes of data for potential threats, alongside regular manual checks by security personnel. The plan should also specify response strategies for different types of detected threats, ensuring that the organization can quickly and effectively mitigate risks to maintain the integrity and security of its information systems.

Implement Encryption for Sensitive Data

Encryption transforms data into a format that is unreadable without a decryption key, providing a strong defense against unauthorized access and data breaches.

Automatic encryption ensures that all data, whether at rest or in transit, is encrypted without requiring manual intervention. This not only minimizes the risk of human error but also provides a consistent level of protection across all data. Automatic encryption can be achieved using various tools and technologies, including databases that support native data encryption and encryption gateways that automatically encrypt data as it passes through.

Develop a Risk-Based Approach

FISMA compliance requires organizations to develop a risk-based approach to information security. This means identifying potential threats and vulnerabilities, assessing the risk they pose, and implementing controls to mitigate them.

The risk assessment process involves identifying the assets that need protection, pinpointing potential threats and vulnerabilities, assessing the impact and likelihood of these threats, and prioritizing risks based on their potential impact. Once the risks have been assessed, organizations can then implement controls to mitigate them.

Regularly monitor information Security Systems and Show Escalation Paths and RCA for Changes in Security Posture

Regular monitoring of information security systems is essential for ensuring ongoing compliance with FISMA. This monitoring should include continuous checks on the effectiveness of implemented security controls, verification of compliance with security policies, and assessment of the systems’ ability to resist new and evolving threats.

The security monitoring plan should detail escalation paths for addressing security incidents, including who is responsible for taking action at various levels of the incident. Additionally, it should provide a clear methodology for root cause analysis (RCA) to understand the underlying reasons behind any changes in the security posture. This analysis helps in making informed decisions to strengthen security measures and prevent future breaches.

Track Effectiveness of Security Controls

To ensure FISMA compliance, it’s not enough to simply implement security controls; organizations must also track their effectiveness. This involves regular audits and assessments to ensure that the controls are working as intended and that they’re providing the necessary level of protection.

Organizations should also have a process in place for addressing any deficiencies that are identified during these assessments. This could include updating security controls, retraining staff, or implementing new technologies.

Additionally, organizations should keep detailed records of these assessments. These records can provide valuable insights into the organization’s information security posture and can help to demonstrate compliance with FISMA requirements.