What is FISMA and how to comply with it

22 November, 2024

Implementing the Federal Information Security Management Act (FISMA) is essential for federal agencies and contractors handling government data. This blog will guide you step-by-step through the process, providing clarity and actionable advice.

Introduction

FISMA, a U.S. federal legislation, mandates a systematic approach to information security for federal agencies and organizations managing government data. Unlike European frameworks like CRA, NIS2, and DORA, which can sometimes feel vague or complex, FISMA provides a clear roadmap for compliance. Even if you’re skeptical about the necessity of security regulations, FISMA makes implementation straightforward with its practical guidelines.

In this blog, I will first explain what FISMA is and its primary use cases. Then, I will provide a high level description and the steps to implement FISMA successfully.

What is FISMA?

FISMA, part of the E-Government Act of 2002 and updated in 2014 under the Federal Information Security Modernization Act, aims to enhance the security of federal systems. It establishes a framework for federal agencies and their contractors to manage risks systematically.

Primary use cases for implementing FISMA

FISMA serves several use cases, all aimed at safeguarding government data and ensuring a standardized approach to information security. Here is a list of several primary use cases for implementing FISMA.

1. Federal Agencies: FISMA mandates a structured process to secure government data and ensure compliance with federal security requirements.
2. Contractors: Organizations working with government agencies must meet FISMA standards, ensuring the safe handling of sensitive information.
3. Risk Management: FISMA enables organizations to identify, assess, and mitigate security risks effectively, helping them stay ahead of potential threats.

It is important to stress that FISMA is not just about compliance. It is about building a strong foundation for managing security risks in a standardized manner.

The Process for Implementing FISMA

To implement FISMA effectively, you need to follow a series of structured steps, each guided by NIST standards. This section explains these steps in detail.

What is FIPS 199 and How to Use It?

FIPS 199 (Standards for Security Categorization of Federal Information and Information Systems) is the first step in implementing FISMA. It helps categorize information systems based on their sensitivity, which determines the level of security controls required.

Categorization Levels

FIPS 199 has three categorization levels in terms of impact that you will have to establish

• Low impact: Limited effect on operations, assets, or individuals.
• Moderate impact: Significant effect, but not catastrophic.
• High impact: Severe consequences for operations, assets, or individuals.

How to use FIPS 199

1. Assess the potential impact on confidentiality, integrity, and availability for each system.
2. Assign a category based on the worst-case scenario in any of these areas.
3. Document the categorization to guide the selection of appropriate security controls.

Example: categorizing a system with FIPS 199

Imagine as a vendor to the US Federal Government you are developing a benefits portal that processes sensitive data like Social Security Numbers (SSNs). After a careful consideration you will end up with the following classification:

• Confidentiality: Exposure of SSNs could lead to identity theft (High Impact).
• Integrity: Altered data could cause incorrect benefits (Moderate Impact).
• Availability: Downtime is to be avoided, but it won’t have a major impact (Low Impact).

Overall Impact: The system is categorized as High Impact because the highest individual impact is “High.” This guides the selection of stronger security controls from NIST SP 800-53 (see next section).

Hence, in a nutshell FIPS 199 ensures you apply the right level of protection to each system, avoiding over- or under-engineering security measures.

NIST SP 800-53

NIST SP 800-53 provides a comprehensive catalog of security and privacy controls for federal information systems. It serves as the backbone for implementing FISMA requirements. These controls are organized into families such as Access Control, Risk Assessment, Incident Response, System and Communications Protection, and Audit and Accountability, ensuring all aspects of security are systematically addressed.

How to use NIST 800-53 when implementing FISMA

Implementing FISMA using NIST SP 800-53 is a straightforward process:

1. Select controls that match the impact category determined by FIPS 199.
2. Implement these controls across your organization’s systems.
3. Conduct regular assessments to ensure they are functioning effectively (see the next section).

NIST SP 800-53 ensures a thorough approach to securing federal systems while aligning with FISMA’s requirements.

Assessing control effectiveness

Once controls are implemented, one needs to evaluate their effectiveness. This step ensures that controls are correctly implemented and address the intended risks (i.e., “Did we do a good enough job?”).

1. Review implementation: Verify that the selected controls are properly implemented as designed. For example, confirm that multi-factor authentication is enforced for all users in high-impact systems.
2. Test functionality: Use predefined testing methods outlined in SP 800-53A to ensure controls function as intended. For instance, test audit logging by attempting a policy violation and confirming that it is logged correctly.
3. Identify and address gaps: Document any deficiencies or areas where controls fall short, such as an incomplete incident response procedure. Implement corrective actions, like updating the procedure or conducting additional training.

Regular assessments focus on the effectiveness of controls, building confidence that your systems can handle evolving threats and meet FISMA compliance requirements.

Continuous monitoring

FISMA emphasizes continuous monitoring to adapt to new threats, maintain compliance, and ensure the ongoing effectiveness of security controls. This involves several key activities:

1. Real-Time Monitoring with Automated Tools: Tools like intrusion detection systems (IDS) or vulnerability scanners monitor network activity for unusual behavior or weaknesses. For example, detecting unauthorized access attempts in real time can help mitigate potential breaches.
2. Periodic Audits: Regular audits assess whether controls are implemented correctly and functioning as intended. For instance, reviewing access logs monthly can reveal patterns of unauthorized access or unusual activity.
3. Updating Security Measures: Based on audit findings or emerging risks, organizations must update their controls. For example, a discovered vulnerability in a critical system might require immediate patching or implementing additional controls, like stricter authentication.

Continuous monitoring ensures that security evolves with the threat landscape, transforming it from a reactive process into a proactive, ongoing effort.

NIST SP800-171: Protecting Controlled Unclassified Information

In the previous section, we discussed how NIST SP 800-53 is the cornerstone for implementing FISMA by providing a comprehensive set of security controls. However, in certain contexts you may implement FISMA using a more compact standard, namely NIST SP 800-171.

NIST SP 800-171 focuses on safeguarding Controlled Unclassified Information (CUI) in non-federal systems and organizations. It is particularly relevant for federal contractors who process or store sensitive information on behalf of government agencies. While SP 800-53 provides controls for federal systems, SP 800-171 adapts these controls for contractors, making it a critical extension for ensuring CUI protection under FISMA. For example, contractors must implement access controls, encryption, and incident response mechanisms to prevent unauthorized access to sensitive data.

Example: A contractor managing a benefits portal for a federal agency would use SP 800-171 to secure citizen data such as Social Security Numbers (SSNs) and financial records.

NIST 800-53 vs NIST 800-171

If you are wondering whether you should be using NIST 800-53 or NIST 800-171 here is a summary of the key differences.

Self-assessment vs. third-party assessment

Finally, one of the coolest (though you might disagree) aspects of FISMA is choosing whether to conduct a self-assessment or hire a reputable third party. While both are valid, accuracy and integrity are crucial. Intentionally lying to the federal government is obviously never a good idea. However misrepresentation can also lead to severe penalties under the False Claims Act.

In general, I would recommend a self-assessment for low-risk systems in case you have strong internal expertise. For high-stakes contracts or critical systems, third-party assessments (e.g., Conquest Security) offer credibility and thoroughness, minimizing compliance risks.

Conclusion

FISMA offers a systematic approach to securing federal information systems, ensuring both compliance and protection against evolving threats. By following the steps outlined in FIPS 199 and NIST SP 800-53 or NIST SP 800-171, organizations can implement effective security measures tailored to their needs.

Key takeaways:

• Categorize systems using FIPS 199 to determine their sensitivity.
• Apply controls from NIST SP 800-53 or NIST SP 8000-171 based on the system’s category.
• Continuously monitor and assess systems to maintain compliance.

FISMA compliance is more than a regulatory requirement; it’s a pathway to building a secure and resilient information security program. By leveraging its clear guidance and complementary standards, organizations can ensure their systems remain secure and reliable.