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FedRAMP and FISMA answer different questions
| Framework or decision | What it answers | What it means for a buyer |
|---|---|---|
| FISMA | What information-security program and accountability must a federal agency maintain? | The agency must manage risk across its information and systems, including systems provided or managed by contractors and other organizations. |
| FedRAMP | How can agencies reuse standardized assessment evidence when considering cloud services? | A FedRAMP package can support agency risk and authorization work; it is evidence, not a substitute for that work. |
| Agency ATO | Is this particular system, with this agency’s data, configuration, integrations, users, and agency-operated controls, authorized for this agency’s use? | The agency makes this system-specific decision and accepts the associated risk. |
In short, FedRAMP evidence supports FISMA implementation; it does not replace FISMA accountability or the agency’s system authorization. [FISMA 2014] [FedRAMP]
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What FISMA requires
FISMA 2014, codified at 44 U.S.C. § 3551 et seq., requires each federal agency to develop, document, and implement an agency-wide information-security program for information and systems supporting agency operations and assets. Its scope includes systems supplied or managed by another agency, a contractor, or another source. Agency leadership remains accountable, with duties delegated to officials such as the CIO and security leaders.
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What FedRAMP does for cloud procurement
FedRAMP is a government-wide standardized and reusable approach to assessing and authorizing cloud products and services that process unclassified information used by agencies. It produces assessment information and a package agencies can use in their own risk decisions. The aim is to reuse common evidence rather than treat each agency’s review as an entirely separate cloud assessment. [FedRAMP] [FedRAMP authorization guidance]
Reusing evidence does not mean an agency delegates its responsibility. An agency authorizing official must still determine whether the evidence, controls, and remaining risks are acceptable for the agency’s particular system and mission.
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When FedRAMP applies to a cloud service
FedRAMP scope can cover infrastructure, platform, and software cloud services that create, collect, process, store, or maintain federal information on behalf of an agency, subject to specified exclusions. Scope depends on the planned agency use; a product does not necessarily have one universal status for every use. The agency determines whether its use case falls within scope. [FedRAMP scope guidance]
Useful factors in that determination include:
- Whether the service handles sensitive federal information under agency oversight.
- Whether the agency configures and centrally administers a tenant.
- Whether the service integrates with agency enterprise security services.
- Whether the service is shared or reasonably reusable across agencies or third parties.
Mixed indicators call for case-specific analysis rather than an automatic conclusion based on a product label.
What a FedRAMP designation establishes—and what it does not
A FedRAMP authorization or certification establishes that security information for a defined cloud service has been collected and reviewed through the applicable program process. The package is intended for reuse and is presumed adequate as evidence for agency authorization work, subject to agency responsibilities and any documented deficiencies. [FedRAMP authorization guidance] [FedRAMP package guidance]
It does not by itself establish that every agency can use the service for every workload, approve the agency’s chosen configuration, make the agency’s risk decision, or issue an ATO for the agency’s complete information system. The agency’s decision covers its use of the service—including the information processed, configuration, integrations, and controls that the agency operates. [FedRAMP authorization guidance] [FedRAMP]
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FedRAMP materials use certification and validation designations and classes to describe the coverage and depth of assessment evidence. Those labels do not, by themselves, rate a service’s overall security or replace the agency’s system categorization and risk decision. Because program terminology and transition dates can change, verify the live package and current guidance when procuring. [Current FedRAMP guidance]
A practical workflow for federal IT buyers
- Define the mission use. Identify users, data, information sensitivity, integrations, and required protections before comparing vendors. [FedRAMP buyer guidance]
- Determine scope for that use. Decide whether the planned agency use falls within FedRAMP scope; do not assume that a vendor-wide label resolves the question. [FedRAMP scope guidance]
- Inspect the exact service package. Check the current designation and assessment evidence for the cloud service offering and boundary being procured. Review inherited controls, provider responsibilities, configuration guidance, and ongoing evidence. [FedRAMP package guidance]
- Decide how much evidence can be reused. Reuse the package to the extent practicable. If it is substantially deficient for the agency’s authorization purpose, document why and determine and justify any additional agency requirements. [FedRAMP authorization guidance]
- Complete the agency’s authorization work. Assess the federal information system using the service, including agency-responsible controls and ongoing monitoring. The resulting ATO applies to that system and use. [FedRAMP authorization guidance] [FedRAMP buyer guidance]
How to compare cloud offerings
Do not compare services on a certification label alone. For each offering, assess the same dimensions so the agency can see both the evidence available and the work that remains:
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- Scope and boundary: Which specific service components and environments are covered?
- Designation and assessment evidence: What is the current status, and what evidence supports it?
- Impact level and mission fit: Does the assessed service fit the sensitivity of the agency’s information and operational needs?
- Control responsibility: Which controls are inherited from the provider, and which must the agency or customer implement?
- Configuration and integrations: What settings and connections are needed for the intended deployment?
- Monitoring and package currency: What ongoing evidence is available, and is the package current for procurement?
- Remaining ATO work: What risk assessment, agency controls, and authorization activities are still needed for the agency’s system?
These comparisons help distinguish reusable provider evidence from agency-specific obligations; neither a label nor a package alone answers whether a particular deployment is acceptable. [FedRAMP package guidance] [FedRAMP buyer guidance]
FISMA’s date and the earlier law
FISMA 2014 (Public Law 113-283) was enacted on December 18, 2014. The original FISMA was enacted on December 17, 2002, as Title III of the E-Government Act. [NIST FISMA history]
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