Federal Information Security Modernization Act
Cybersecurity framework for federal agencies and their contractors
// What is FISMA?
FISMA establishes a comprehensive framework for securing federal government information systems. The law requires federal agencies to develop, document, and implement agency-wide information security programs to protect data and systems.
FISMA mandates risk-based security controls aligned with NIST guidelines, particularly NIST SP 800-53. Agencies must categorize systems by impact level, implement appropriate controls, assess effectiveness, and authorize systems before operation. Continuous monitoring and annual reporting to Congress are required.
Contractors and third parties operating systems on behalf of federal agencies must also comply with FISMA requirements, making it essential for organizations in the federal supply chain to understand and implement these standards.
// Inside the Regulation
FISMA compliance follows the Risk Management Framework (RMF) defined in NIST SP 800-37, with security controls from NIST SP 800-53. The framework provides a structured approach to managing information security risk.
Risk Management Framework Steps
FISMA compliance follows the six-step NIST Risk Management Framework for system authorization.
Categorize
Determine system impact level (Low, Moderate, High) based on FIPS 199 criteria for confidentiality, integrity, and availability.
Select
Choose appropriate security controls from NIST SP 800-53 based on system categorization and organizational requirements.
Implement
Deploy selected security controls and document implementation details in the System Security Plan (SSP).
Assess
Evaluate control effectiveness through testing and examination; document results in Security Assessment Report (SAR).
Authorize
Authorizing Official reviews security package and issues Authorization to Operate (ATO) decision.
Monitor
Continuously monitor controls, report security status, and manage ongoing authorization.
Key Documentation
FISMA requires comprehensive security documentation throughout the system lifecycle.
System Security Plan (SSP)
Documents system boundaries, security controls, and implementation details. Foundation of the authorization package.
Security Assessment Report (SAR)
Results of security control assessment including findings, recommendations, and risk determinations.
Plan of Action & Milestones (POA&M)
Tracks security weaknesses, remediation plans, and milestone dates for addressing deficiencies.
Authorization Decision
Formal ATO, Denial of Authorization, or Interim Authorization from the Authorizing Official.
Reporting Requirements
FISMA mandates regular security reporting to OMB and Congress.
Annual FISMA Report
Agencies report on security program status, incidents, and compliance metrics to OMB annually.
CyberScope Reporting
Quarterly and monthly reporting through DHS CyberScope system on security metrics and incidents.
Inspector General Audits
Annual independent evaluation of agency information security program by the IG.
Note: FISMA was modernized in 2014 to emphasize continuous monitoring over point-in-time compliance. The update shifted focus from paperwork to real-time security awareness and automated monitoring capabilities. CISA provides operational guidance and coordinates federal cybersecurity efforts.
// Who Must Comply
- 1 All federal executive branch agencies
- 2 Federal contractors operating information systems for agencies
- 3 Grantees and organizations receiving federal funding with data handling
- 4 State agencies administering federal programs
- 5 Cloud service providers serving federal agencies (via FedRAMP)
// Key Requirements
Risk Assessment
Periodic assessment of information security risks to operations, assets, and individuals
Security Planning
Comprehensive System Security Plans documenting controls and implementation
Security Controls
Implementation of NIST SP 800-53 controls appropriate to system risk level
Security Assessment
Regular testing and evaluation of security control effectiveness
Continuous Monitoring
Ongoing awareness of vulnerabilities, threats, and security posture
Incident Response
Capabilities for detecting, reporting, and responding to security incidents
// Enforcement & Penalties
FISMA non-compliance can result in budget impacts, contract issues, and reputational consequences. Agencies face congressional scrutiny and potential budget restrictions. Contractors may lose contracts or face termination for non-compliance.
Contract termination; agency budget impacts; IG findings
Examples:
- Congressional scrutiny and negative IG audit findings
- Budget restrictions for agencies with poor FISMA scores
- Contract termination for non-compliant contractors
- Removal from approved vendor lists
- Increased oversight and remediation requirements
// Cyber Insurance Impact
FISMA compliance demonstrates mature security practices aligned with federal standards. Organizations with strong FISMA compliance programs may receive favorable cyber insurance terms, particularly for policies covering government contract work.
// How Breach Craft Helps
We help organizations achieve FISMA compliance through genuine security improvements—not checkbox exercises. Our services address the specific requirements and challenges of FISMA.
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