Government cybersecurity standards such as FedRAMP and CMMC can be challenging to comprehend. There are a host of details to decipher for each one, let alone both.
Let’s dive into common questions about these two programs: How they work together, how they work independently, and other questions that frequently arise.
What is FedRAMP?
The Federal Risk and Authorization Management Program (FedRAMP) is a federal program that dictates necessary cybersecurity requirements when U.S. government agencies access cloud products and cloud services.
FedRAMP is not the same as FISMA (the Federal Information Security Management Act). FedRAMP is a set of regulations that specifically apply to cloud services. FISMA is a law that defines general cybersecurity standards and information security policies for government agencies and private companies doing business with the government.
FedRAMP uses a framework to guide security assessment, authorization, and continuous oversight of cloud service providers (CSPs). It serves as a seal of approval for CSPs; those that are FedRAMP certified can then bid more easily and quickly on IT projects for government agencies. The program grants authorizations to cloud service providers at three impact levels: low, medium, and high.
FedRAMP is crucial because it provides uniformity in the security of the government’s cloud services and the evaluation and monitoring of that security. In addition, it establishes a single set of standards for all government departments and cloud providers.
FedRAMP-authorized cloud service providers are listed in the FedRAMP Marketplace. When government agencies need to find a new cloud-based solution, they go first to this marketplace. It is significantly easier and faster for an agency to use an already-authorized CSP than to begin the authorization process with a new vendor.
What is the CMMC Framework?
“CMMC” stands for Cybersecurity Maturity Model Certification. It’s a set of standards to implement cybersecurity across the Defense Industrial Base (DIB).
The CMMC program is used by the Department of Defense (DoD) to secure sensitive defense data. CMMC originally proposed to have five levels of security risk, but in November 2021 the Defense Department streamlined that to three levels like FedRAMP.
In addition to CMMC, the Department of Defense created another agency, the Cybersecurity Maturity Model Certification Accreditation Body (CMMC-AB), to train and test assessors.
These trained assessors are then qualified to join the CMMC Assessors and Instructors Certification Organization (CAICO), responsible for performing cybersecurity audits of defense contractors’ networks.
The primary advantage to businesses that get CMMC certification is the development of their processes while also improving the safety of controlled unclassified information and intellectual property inside the US DIB supply chain.
If all companies adopted the stringent CMMC certification, global cybercrime costs would dramatically drop, however, as per CMMC 2.0 outside assessments are not voluntary for most businesses.
The three levels of the CMMC program are as follows:
- Level 1 (Foundational) applies to companies that focus on safeguarding FCI. It is similar to the previous CMMC Level 1. The protection of FCI will be the focus at Basic Level 1, which will be based on 17 control measures found in FAR 52204-21, Basic Safeguarding of Covered Contractor Information, and limiting access to authorized users. These controls aim to safeguard covered contractor information systems and restrict access to authorized persons.
- Level 2 (Advanced) applies to organizations working with CUI. It’s similar to CMMC Level 3 from before. CMMC 2.0’s Level 2 (Advanced) criteria will be identical to NIST SP 800-171 and will get rid of all CMMC practices and maturity processes. Instead, Level 2 aligns with the 14 levels and 110 security controls established by the National Institute of Technology and Standards (NIST) to safeguard CUI. As a result, the DoD’s 20 criteria for Level 3 of the CMMC were dropped, meaning that the new Level 2 (Advanced) is completely in line with NIST SP 800-171.
- Level 3 (Expert) is concerned with reducing the danger from Advanced Persistent Threats, or APT. It’s intended for organizations working on DoD’s most vital projects. It resembles CMMC Level 5 from before. The DoD has not yet determined the specific security requirements for Level 3 (Expert), but it has stated that they will be based on NIST SP 800-171’s 110 controls and a subset of NIST SP800-172 controls.
When Will the DoD Fully Implement CMMC?
The Defense Department released the first version of the Cybersecurity Maturity Model Certification (CMMC) in January 2020. The department announced significant adjustments to the CMMC program in November 2021. The DoD intends to revamp the CMMC program again to simplify the model, lower assessment costs, and have more flexible implementation.
It also appears that the implementation schedule has been hastened since the DoD announced that CMMC 2.0 would become a contract requirement once the rulemaking process is completed (in 9-24 months). This presumably indicates that all contractors must plan for CMMC compliance by November 2023, at the latest.
FedRAMP vs. CMMC: How Are They Related?
The Defense Department announced at the start of 2021 that it would provide CMMC reciprocity for any ISO 27001 and FedRAMP audits. That is, any audits to achieve FedRAMP or ISO 27001 certification would apply equally to CMMC compliance.
Understanding FedRAMP and CMMC reciprocity can aid in the development of supply chain compliance strategies for members of the Defense Industrial Base (DIB).
FedRAMP compliance, according to the Defense Department and CMMC Accreditation Body (CMMC-AB) authorities, would count toward CMMC Level 3 certification, but this has not been formalized.
What’s the Difference Between DFARS 7012 and FedRAMP Moderate?
DFARS 7012 is the government contracting rule the Defense Department uses to require cybersecurity among all DoD contractors. The cybersecurity standard required in DFARS 7012 is NIST 800-171, also commonly known as the NIST Cybersecurity Framework.
In other words, to meet the requirements of DFARS 7012, which allows a business to bid on Defense Department contracts, that business must implement the NIST Cybersecurity Framework.
“FedRAMP Moderate” is the FedRAMP standard for cloud computing security at all other federal government agencies. The moderate impact level is appropriate for CSPs that will handle government data that is not publicly available.
While DFARS 7012 applies to defense contractors working for the Defense Department, FedRAMP applies to all government contractors working with any other U.S. government agency.
What Are NIST Framework Controls?
The NIST Cybersecurity Framework, released by the National Institute of Standards and Technology, provides security policies and guidance for organizations to improve security within their systems.
This framework guides organizations in improving their ability to handle cyber-attacks. The framework contains an exhaustive list of cybersecurity standards and the security controls needed to secure the system.
The NIST framework consists of five functions. These functions are:
- Identify: The organization can identify essential assets that need protection, whether those assets are data or IT systems;
- Protect: Create tasks to assure critical services remain functional;
- Detect: Create tasks that monitor the occurrence of a security event;
- Respond: Create tasks that are used when facing a detected security event;
- Recover: Create tasks to repair damage after a security event occurs.
The difference between CMMC and the NIST framework is that CMMC is more rigorous than NIST in several ways. The most significant distinction is that CMMC employs a maturity model: tiers of cybersecurity competence that contractors may qualify for through a third-party audit.
What is Supply Chain Compliance?
The phrase “supply chain compliance” refers to the regulations and requirements that can apply not just to an organization but to that organization’s supply chain. For example, supply chain compliance might govern your suppliers’ cybersecurity or relate to concerns such as ethical sourcing, product liability, and other issues.
Maintain Cybersecurity Compliance with Reciprocity ROAR
FedRAMP and CMMC have similar requirements for the Defense Department, but the DoD has yet to determine and formalize how much reciprocity will exist between the two.
Defense Department officials have indicated that offering certification reciprocity between FedRAMP and CMMC is something they want to achieve, to keep compliance costs as low as possible. The challenge, however, is that FedRAMP and CMMC have a different number of security levels, which makes reciprocity more difficult.
This is why software like the Reciprocity ROAR platform can be a cost-effective and seamless way to assure compliance among multiple, complex cloud security standards and compliance frameworks.
Reciprocity Roar is ready to assist you in managing the whole lifecycle of all your essential cybersecurity risk management frameworks. Templates and control mapping simplifies document management and reduces the duplication of efforts across frameworks.
As part of the Reciprocity Roar product suite, ZenComply‘s compliance templates can simplify your self-assessments, while our easy-to-use, central dashboard provides a single view across all your compliance frameworks, showing you where gaps exist in your cybersecurity program and how to fill them.
Security policies, incident response procedures, and internal controls must be documented and updated regularly to assure they meet the evolving cybersecurity environment. With Reciprocity ROAR’s document repository, policies and procedures are revision-controlled and easy to find.
Workflow management features offer easy tracking, automated reminders, and audit trails. The ZenConnect feature enables integration with popular tools, such as Jira, ServiceNow, and Slack, ensuring seamless adoption within your enterprise.
Reciprocity ROAR stores and organizes all related documentation, so it’s easy to procure when it’s time for your audit. Achieve “Zen-mode” in your compliance efforts and risk management efforts. Schedule a demo today!