FISMA Compliance

Secure Federal Information Systems

The U.S. federal government operates vast information systems processing sensitive data including classified national security information, personally identifiable information (PII) of citizens, financial and payment data, law enforcement and intelligence data, health and medical records, critical infrastructure control systems, and mission-critical operational data. These systems face sophisticated threats from nation-state adversaries, organized cybercrime groups, hacktivists and insider threats, and advanced persistent threats targeting government networks, contractors, and supply chain vulnerabilities. High-profile breaches including OPM data breach (2015) compromising 21.5 million security clearance records, SolarWinds supply chain attack (2020) affecting numerous federal agencies, and ongoing targeting of federal contractors and grant recipients demonstrate real and persistent threat to federal information. To address these risks, U.S. Congress enacted FISMA (Federal Information Security Management Act) as part of E-Government Act of 2002 (updated by FISMA Reform Act of 2014). FISMA establishes comprehensive framework for securing federal information systems requiring federal agencies implement information security programs based on risk management principles, continuous monitoring and assessment, security controls from NIST standards, and reporting to OMB and Congress. FISMA applies to federal civilian agencies, Department of Defense (DOD), Intelligence Community (with variations), and contractors, service providers, and state/local entities handling federal information systems or processing federal data on behalf of agencies. For federal agencies, FISMA compliance is mandatory legal requirement overseen by Office of Management and Budget (OMB), inspected by agency Inspectors General (IGs), and reported annually to Congress. Non-compliance creates significant consequences including IG audit findings and recommendations, OMB oversight and reporting, GAO investigations and congressional testimony, potential budget impacts and funding restrictions, reputational damage from public breach disclosures, and legal liability for inadequate protection of federal data. For contractors and service providers, FISMA compliance increasingly prerequisite for federal contracts particularly those involving information systems, data processing, cloud services, and IT infrastructure. Federal agencies require contractors meet FISMA-equivalent security standards validated through System Security Plans (SSPs), Authority to Operate (ATO) or security authorization, continuous monitoring and reporting, and incident response and breach notification. At Glocert International, we provide expert FISMA compliance services helping federal agencies and contractors meet Federal Information Security Management Act requirements. Our experienced team guides you through Risk Management Framework (RMF) process, NIST 800-53 security control implementation, System Security Plan development, security assessment and authorization, continuous monitoring programs, and ongoing compliance management. Partner with Glocert to achieve FISMA compliance, secure federal information systems, meet regulatory requirements, and protect sensitive government data from cyber threats.

What is FISMA?

FISMA (Federal Information Security Management Act) is U.S. federal law requiring federal agencies and their contractors to develop, document, and implement information security programs protecting federal information and information systems. Originally enacted in 2002 and modernized by FISMA Reform Act of 2014, FISMA establishes framework for federal cybersecurity based on NIST standards and risk management principles.

Legislative Foundation

FISMA comprises several key components:

FISMA 2002: Original Federal Information Security Management Act establishing federal information security requirements, agency responsibilities, and reporting obligations
FISMA Reform Act 2014: Modernized FISMA emphasizing continuous monitoring, automated security tools, improved metrics and reporting, and enhanced oversight
OMB Circulars: Office of Management and Budget policy directives including OMB Circular A-130 (Managing Information as Strategic Resource), OMB M-21-31 (Improving Federal Cybersecurity), and various memoranda on specific security topics
NIST Standards: NIST publishes technical standards and guidelines supporting FISMA including NIST SP 800-53 (Security and Privacy Controls), NIST SP 800-37 (Risk Management Framework), FIPS 199 (Security Categorization), FIPS 200 (Minimum Security Requirements)

Scope and Application

FISMA applies to various federal entities and their supporting organizations:

Federal Civilian Agencies: Executive branch agencies, independent agencies, government corporations. Must fully comply with FISMA and OMB requirements
Department of Defense: DOD has separate security framework (DOD RMF) aligned with but distinct from FISMA. Applies DOD-specific security requirements and authorization processes
Intelligence Community: IC has separate framework (ICD 503) but aligned with NIST standards. Applies classification-based protections
Federal Contractors and Service Providers: Organizations operating federal information systems or processing federal data on behalf of agencies. Must meet FISMA-equivalent security requirements validated through agency authorization processes. Includes cloud service providers (FedRAMP), IT service providers, outsourcers, and SaaS vendors
State and Local Government: When receiving federal grants or operating federal programs, must comply with federal security requirements for systems processing federal data

Key Principles

FISMA built on several core principles:

Risk Management: Security programs based on risk assessment and management. Controls tailored to risk level not one-size-fits-all approach
Continuous Monitoring: Ongoing assessment of security controls rather than point-in-time audits. Automated tools for continuous visibility
Agency Accountability: Agency heads responsible for information security. CIO and CISO accountable for implementing security programs
Standardized Controls: Security controls from NIST 800-53 providing common baseline across federal government
Authorization and Accreditation: Formal process for authorizing information systems to operate (ATO) based on acceptable risk
Incident Response: Requirements for detecting, reporting, and responding to security incidents

Why FISMA Compliance Matters

1. Legal and Regulatory Mandate

FISMA is federal law creating binding legal obligation for federal agencies. Agencies must comply with FISMA requirements under penalty of law with oversight from multiple entities including Office of Management and Budget (OMB) which oversees federal cybersecurity policy and monitors agency compliance, Inspector General (IG) which conducts annual FISMA audits evaluating agency information security programs and controls, Government Accountability Office (GAO) which investigates cybersecurity issues and reports to Congress, and Congressional oversight through hearings and appropriations. Non-compliance identified through IG audits, GAO investigations, or security incidents results in audit findings requiring remediation plans and timelines, OMB reporting and potential restrictions, public reporting in annual FISMA report to Congress, media scrutiny and congressional hearings (particularly after breaches), budget impacts with potential funding restrictions for non-compliant programs, and legal liability for agency officials. Recent emphasis on federal cybersecurity following SolarWinds, Colonial Pipeline, and other incidents has intensified FISMA oversight. Executive orders including EO 14028 (Improving Nation's Cybersecurity) mandate enhanced security measures many implemented through FISMA framework. For agency CIOs and CISOs, FISMA compliance critical responsibility with career implications. Failure to maintain adequate security programs can result in adverse personnel actions particularly if breaches occur due to negligence. For contractors, FISMA compliance prerequisite for federal business. Agencies require contractors meet security standards through ATO process, security assessments and audits, continuous monitoring and reporting, and incident response requirements. Inability to achieve FISMA compliance blocks federal contracts and revenue opportunities.

2. Protection of Sensitive Federal Data

Federal information systems process extraordinarily sensitive data with national security, privacy, and operational implications. Types of sensitive federal data include classified national security information (Top Secret, Secret, Confidential), controlled unclassified information (CUI) such as FOUO, law enforcement sensitive, export controlled, personally identifiable information (PII) including Social Security numbers, financial records, health records, security clearance data, financial and payment data including tax information, benefits payments, grant funds, critical infrastructure data including SCADA systems, facility security, transportation, and mission-critical operational data supporting agency missions and public services. Compromise of federal data creates severe consequences including national security damage (intelligence disclosure, operational exposure), privacy violations (identity theft, discrimination, harassment of individuals whose PII exposed), financial fraud and losses, operational disruption (mission impact, public service interruption), and diplomatic and international relations impacts. FISMA framework specifically designed to protect federal data through security categorization (determining sensitivity and impact of data - FIPS 199), baseline security controls (implementing NIST 800-53 controls appropriate to sensitivity), access controls (limiting data access to authorized personnel with need-to-know), encryption (protecting data in transit and at rest), and monitoring and auditing (detecting and responding to unauthorized access or misuse). Organizations achieving FISMA compliance demonstrate they protect federal data appropriately reducing breach risk and consequences. For contractors handling federal data, FISMA compliance proves trustworthiness and capability protecting sensitive information enabling federal agencies to outsource functions with confidence data remains secure.

3. Cyber Threat Defense

Federal government faces most sophisticated cyber threats globally. Adversaries include nation-state actors (China, Russia, Iran, North Korea) targeting intelligence, military capabilities, technology, PII, APTs conducting long-term espionage campaigns, organized cybercrime groups pursuing financial gain through ransomware, fraud, and data theft, hacktivists targeting government systems for political purposes, and insiders (malicious or negligent employees and contractors). Recent attacks demonstrate threat severity including SolarWinds supply chain compromise affecting multiple agencies, OPM breach compromising security clearance records, numerous ransomware attacks on federal contractors and state/local governments receiving federal funds, and persistent targeting of pandemic response systems (unemployment, healthcare, vaccine distribution). FISMA controls specifically address cyber threats through preventive controls including system hardening, patching, access controls, network segmentation, detective controls including intrusion detection, security monitoring, log analysis, threat hunting, responsive controls including incident response procedures, forensics capabilities, recovery processes, and continuous improvement through lessons learned, threat intelligence integration, control updates. FISMA's Risk Management Framework requires ongoing assessment and continuous monitoring enabling agencies detect threats earlier, respond faster to incidents, and adapt defenses to evolving threat landscape. Organizations with mature FISMA implementations significantly more resilient to cyber attacks compared to those with weak or non-existent security programs. Investment in FISMA compliance directly translates to improved cyber defense capabilities protecting federal missions from disruption.

4. Supply Chain Risk Management

Federal agencies increasingly reliant on contractors, cloud providers, and commercial technology for IT infrastructure, software development, data processing, managed services, and telecommunications. This supply chain creates expanded attack surface where adversaries target contractors to reach federal systems. Supply chain risks include compromised products (malicious code in hardware, software, or firmware), vendor vulnerabilities (weak security at contractors providing access to federal data or networks), third-party breaches (contractor compromises exposing federal data), and counterfeit components (untrusted hardware infiltrating federal supply chain). FISMA addresses supply chain risks through vendor security requirements (contractors must meet FISMA-equivalent security), supply chain risk management (SCRM) processes evaluating vendor trustworthiness, continuous monitoring of contractor systems processing federal data, incident reporting requirements obligating contractors notify agencies of breaches, and controlled unclassified information (CUI) protections (NIST 800-171 for contractors handling CUI). Recent emphasis on supply chain security following SolarWinds has intensified federal focus. Executive Order 14028 mandates enhanced software supply chain security including software bill of materials (SBOM), secure development practices, and vendor attestations. Organizations seeking federal contracts must demonstrate robust security programs meeting FISMA standards. FISMA compliance proves contractor capability protecting federal data and systems enabling agencies mitigate supply chain risks. As federal government continues digital transformation leveraging cloud, AI, and emerging technologies, supply chain risk management through FISMA framework becomes increasingly critical ensuring trustworthy technology and services.

5. Continuous Improvement and Modernization

FISMA Reform Act of 2014 shifted focus from compliance-oriented "check-the-box" approach to continuous monitoring and risk-based management. Modern FISMA emphasizes continuous monitoring through automated tools providing real-time visibility into security posture, ongoing assessment of security controls, metrics and dashboards for leadership visibility, proactive threat hunting and anomaly detection. Risk-based approach with security investments prioritized based on risk to mission and data, controls tailored to actual threats and vulnerabilities, flexible implementation allowing innovation, and dynamic authorization adapting to changing risk. Technology modernization including cloud-first policies (Federal Risk and Authorization Management Program - FedRAMP), zero trust architecture principles, automation of security operations, and adoption of DevSecOps practices. This evolution from static compliance to dynamic risk management enables federal agencies maintain security in rapidly changing threat and technology environment. Organizations implementing modern FISMA approaches benefit from improved security posture through better visibility and faster response, operational efficiency through automation and streamlined processes, innovation enablement as security adapts to new technologies rather than blocking them, and continuous improvement culture with regular assessment and enhancement. FISMA compliance when done well is not burden but framework for building mature, effective security programs protecting federal missions while enabling technology innovation and operational efficiency.

6. Federal Contract Access and Competitiveness

For contractors and service providers, FISMA compliance increasingly determines federal market access. Federal IT spending exceeds $100 billion annually with significant portion awarded to contractors for systems development, infrastructure, cloud services, cybersecurity, and IT support. Agencies require contractors meet FISMA-equivalent security validated through security authorization processes, contract clauses mandating specific security requirements (DFARS, FAR clauses), continuous monitoring and reporting to agency, and incident response and breach notification. Contractors unable to achieve FISMA compliance face exclusion from federal opportunities, contract modifications restricting data access or system connections, potential contract termination for security failures, and reputational damage affecting future opportunities. Conversely, contractors demonstrating strong FISMA compliance gain competitive advantages including preferred vendor status for security-sensitive contracts, reduced agency due diligence burden (leveraging existing ATOs or FedRAMP authorizations), reputation as trusted partner, and expansion into higher-value, more strategic contracts requiring robust security. Organizations seeking to compete in federal market particularly for IT, cloud, and data services must prioritize FISMA compliance as fundamental business requirement. Investment in FISMA compliance unlocks federal market access enabling revenue growth while building security capabilities benefiting all customer relationships commercial and government.

Our FISMA Services

Glocert International provides comprehensive FISMA compliance services for federal agencies and contractors.

FISMA Readiness Assessment

We conduct comprehensive readiness assessments evaluating current security posture against FISMA and NIST requirements. Our assessment reviews security categorization (FIPS 199), baseline security controls (NIST 800-53), system boundaries and architecture, security documentation (SSP, policies, procedures), continuous monitoring capabilities, and authorization status. We deliver detailed gap analysis identifying compliance gaps by control family, risk assessment prioritizing remediation, roadmap to full FISMA compliance or ATO, and estimated timeline and resource requirements.

RMF Implementation and ATO Support

We guide organizations through Risk Management Framework (RMF) process from categorization through authorization and continuous monitoring. Services include FIPS 199 security categorization, control baseline selection and tailoring, System Security Plan (SSP) development, security control implementation, security assessment and testing, authorization package preparation, authorizing official engagement, and Authority to Operate (ATO) achievement. RMF implementation results in formal ATO authorizing system operation based on acceptable risk validated security posture.

NIST 800-53 Security Control Implementation

FISMA requires implementation of security controls from NIST 800-53 across 20 control families. We provide implementation guidance for all control families including Access Control, Awareness and Training, Audit and Accountability, Security Assessment and Authorization, Configuration Management, Contingency Planning, Identification and Authentication, Incident Response, Maintenance, Media Protection, Physical and Environmental Protection, Planning, Personnel Security, Risk Assessment, System and Services Acquisition, System and Communications Protection, System and Information Integrity, Program Management, and Privacy Controls. Implementation includes technical controls (technology deployment), operational controls (procedures and processes), and management controls (policies and governance).

System Security Plan (SSP) Development

SSP is core FISMA documentation describing system, security controls, and implementation. We develop comprehensive SSPs including system description and boundaries, security categorization justification, control selection and tailoring rationale, control implementation descriptions, responsible roles and points of contact, security architecture diagrams, interconnection descriptions, and contingency planning. SSP serves as primary document for security assessment and authorization supporting ATO decision while providing operational reference for system security management.

Security Assessment and Testing

FISMA requires independent assessment of security controls. We conduct security assessments including Security Assessment Plan (SAP) development, control testing (technical, operational, management), vulnerability scanning and penetration testing, configuration compliance verification, evidence collection and analysis, findings documentation and risk determination, Security Assessment Report (SAR) development, and remediation recommendations. Assessment validates control effectiveness, identifies weaknesses, and provides authorizing official with information for risk-based authorization decision.

Continuous Monitoring Program

FISMA Reform emphasizes continuous monitoring providing ongoing visibility into security posture. We establish continuous monitoring programs including automated security tool deployment (vulnerability scanning, configuration management, SIEM), continuous control assessment procedures, security metrics and dashboards, change control processes, annual assessment requirements, Plan of Action and Milestones (POA&M) management, and ongoing authorization (FISMA metrics reporting). Continuous monitoring maintains authorization while providing early detection of security issues enabling proactive remediation before incidents occur.

Incident Response Planning

FISMA requires incident response capabilities. We develop incident response programs including Incident Response Plan (IRP) development, incident detection and analysis procedures, containment, eradication, and recovery processes, US-CERT reporting procedures (federal agencies must report to US-CERT within timeframes based on severity), evidence preservation and forensics, communication and notification, and lessons learned and improvement. Incident response planning ensures organizations prepared to detect and respond effectively to security incidents meeting FISMA reporting requirements while minimizing damage.

FISMA Audit and IG Inspection Preparation

Federal agencies undergo annual FISMA audits by Inspector General. We prepare organizations for IG inspections including documentation organization and readiness, mock audits simulating IG assessment, evidence package preparation, staff training on audit response, remediation of anticipated findings, and audit support during actual inspection. IG audit preparation increases likelihood of favorable findings, reduces remediation burden, and demonstrates security program maturity to oversight bodies.

Risk Management Framework (RMF) Process

FISMA compliance implemented through Risk Management Framework (RMF) defined in NIST SP 800-37. RMF comprises seven steps:

Step 1: Prepare

Establish organizational context and resources supporting risk management. Activities include identifying stakeholders and roles, establishing risk management strategy, identifying and prioritizing assets and systems, and defining common controls (inherited from organization level). Preparation creates foundation for RMF execution establishing governance, resources, and strategic direction.

Step 2: Categorize

Categorize information system based on impact analysis per FIPS 199. Determine impact to confidentiality, integrity, and availability if information or system compromised (Low, Moderate, or High impact). Document categorization in security categorization memo. Categorization drives control baseline selection - higher impact systems require more stringent controls. Critical step determining security rigor applied to system.

Step 3: Select

Select baseline security controls from NIST 800-53 based on categorization (Low, Moderate, or High baseline). Tailor controls to organization and system context (add, remove, modify controls based on risk). Supplement with additional controls for specific threats or requirements. Document control selection in System Security Plan (SSP). Selection balances security requirements with operational needs and resources creating customized control set appropriate for system risk.

Step 4: Implement

Implement selected security controls in information system and organization. Deploy technical controls (security tools, configurations), establish operational controls (procedures, processes), and document management controls (policies, plans). Implementation includes configuration management ensuring controls consistently applied and maintained. Document control implementation details in SSP. Implementation demonstrates commitment to security requirements translating policy into operational reality.

Step 5: Assess

Independent assessment of security controls determining effectiveness. Develop Security Assessment Plan (SAP), conduct control testing (examine documentation, interview personnel, test functionality), identify deficiencies and weaknesses, assess risk of findings, and document results in Security Assessment Report (SAR). Assessment provides authorizing official with objective evaluation of security posture supporting risk-based authorization decision. Identifies areas requiring remediation before authorization or documented as risk acceptance.

Step 6: Authorize

Senior agency official (Authorizing Official - AO) makes risk-based decision authorizing system operation. Review authorization package (SSP, SAR, POA&M), consider residual risk and mission needs, and issue authorization decision: Authority to Operate (ATO) for acceptable risk, Denial of Authorization for unacceptable risk, or Authorization to Use (ATU) for temporary operation with conditions. ATO grants permission to operate system for defined period (typically 3 years with continuous monitoring). Represents agency acceptance of residual risk based on implemented controls and mission requirements.

Step 7: Monitor

Continuous monitoring of security controls, system changes, and threat landscape. Activities include ongoing control assessment, vulnerability scanning and remediation, configuration management and change control, security status reporting, POA&M management and remediation tracking, and annual assessment or reauthorization. Monitoring maintains authorization between formal reassessments enabling early detection of security degradation or emerging risks. Provides information for ongoing authorization decisions including authorization termination if risk becomes unacceptable or reauthorization at end of authorization period.

FIPS 199 Security Categorization and Impact Levels

FISMA requires systems categorized based on potential impact if confidentiality, integrity, or availability compromised. FIPS 199 defines three impact levels:

Low Impact

Limited adverse effect on operations, assets, individuals, other organizations, or national security. Generally applies to systems with publicly available information, routine administrative functions, and low sensitivity data. Requires Low baseline controls from NIST 800-53 (approximately 125 controls). Examples: Public websites, general employee email, routine administrative systems.

Moderate Impact

Serious adverse effect causing significant degradation in mission capability, financial loss, harm to individuals, or serious damage. Applies to systems handling sensitive but unclassified information, PII, financial data, or supporting critical operations. Requires Moderate baseline (approximately 250 controls). Most federal systems fall into Moderate category. Examples: Agency financial systems, benefits administration, case management, most mission applications.

High Impact

Severe or catastrophic adverse effect causing severe degradation or loss of mission capability, major financial loss, severe harm or loss of life, or severe impact to national security. Applies to systems with classified information, critical infrastructure, national security systems, or emergency services. Requires High baseline (approximately 325+ controls plus extensive enhancements). Examples: National security systems, classified information systems, critical infrastructure control systems, emergency response systems.

Overall system impact level: High-water mark across confidentiality, integrity, and availability. If any dimension rated High, entire system categorized High requiring High baseline controls. This ensures adequate protection for most sensitive aspect of system.

Benefits of FISMA Compliance:

Legal Compliance

Meets mandatory federal law requirements avoiding audit findings, OMB oversight, and congressional scrutiny.

Data Protection

Protects sensitive federal data including classified information, PII, and mission-critical data.

Cyber Defense

Implements robust security controls defending against sophisticated nation-state and cybercriminal threats.

Federal Market Access

Enables contractors to compete for federal contracts requiring FISMA-equivalent security.

FISMA Services Pricing

Our FISMA services pricing is transparent and based on your system complexity, impact level, and current security maturity. We offer competitive rates with no hidden fees.

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What's Included in FISMA Pricing:

Comprehensive FISMA readiness assessment
FIPS 199 security categorization
NIST 800-53 control selection and tailoring
System Security Plan (SSP) development
Security control implementation guidance
Security assessment and testing (SAP, SAR)
Authorization package preparation
Authority to Operate (ATO) support
Continuous monitoring program setup
Incident response planning
POA&M development and management
IG audit preparation and support
Annual reassessment support

Note: FISMA pricing varies based on system impact level (Low, Moderate, High—higher levels require more controls and effort), system complexity (architecture, integrations, technology stack), number of systems requiring authorization, current security maturity and existing documentation, agency-specific requirements and tailoring, whether seeking new ATO or reauthorization, and timeline constraints. Contact us for detailed, no-obligation quote tailored to your specific FISMA requirements.

Frequently Asked Questions (FAQ)

Find answers to common questions about FISMA compliance:

What is FISMA and who must comply? ▼

FISMA (Federal Information Security Management Act) is U.S. federal law requiring federal agencies and contractors develop, document, and implement information security programs protecting federal information and systems. Based on NIST standards including NIST 800-53 (security controls), NIST 800-37 (Risk Management Framework), FIPS 199 (security categorization). Who must comply: Federal civilian agencies (executive branch, independent agencies—mandatory legal requirement), Department of Defense (DOD RMF aligned with FISMA), Intelligence Community (ICD 503 aligned with NIST), Federal contractors and service providers (must meet FISMA-equivalent security for systems processing federal data), State/local government (when operating federal programs or receiving federal grants). FISMA enforced through OMB oversight, Inspector General audits, GAO investigations, congressional reporting. Non-compliance results in audit findings, restrictions, budget impacts. For contractors, FISMA compliance prerequisite for federal contracts particularly IT, cloud, data services. Organizations must achieve Authority to Operate (ATO) through Risk Management Framework demonstrating adequate security controls and acceptable risk.

What is Risk Management Framework (RMF)? ▼

RMF is process for implementing FISMA defined in NIST SP 800-37. Seven steps: 1. Prepare: Establish context, resources, risk management strategy. 2. Categorize: Security categorization per FIPS 199 (Low, Moderate, High impact based on confidentiality, integrity, availability). 3. Select: Select baseline controls from NIST 800-53 based on categorization. Tailor controls to organization/system. 4. Implement: Implement selected security controls (technical, operational, management). 5. Assess: Independent assessment of controls determining effectiveness. Security Assessment Report (SAR) documents findings. 6. Authorize: Authorizing Official makes risk-based decision: ATO (Authority to Operate), Denial, or ATU (Authorization to Use). ATO grants permission to operate typically 3 years. 7. Monitor: Continuous monitoring maintaining authorization through ongoing assessment, vulnerability scanning, change control, POA&M management, annual assessments. RMF structured approach ensuring consistent, risk-based security across federal systems. Results in formal ATO authorizing system operation based on acceptable risk.

What are FIPS 199 impact levels and how determined? ▼

FIPS 199 security categorization determines system impact level based on potential adverse effects if confidentiality, integrity, or availability compromised. Three levels: Low Impact: Limited adverse effect. Public information, routine functions, low sensitivity. ~125 controls. Examples: public websites, general email. Moderate Impact: Serious adverse effect. Significant mission degradation, financial loss, harm to individuals. Sensitive but unclassified information, PII, financial data. ~250 controls. Most federal systems. Examples: financial systems, benefits administration, mission applications. High Impact: Severe or catastrophic adverse effect. Severe mission loss, major financial loss, loss of life, national security impact. Classified information, critical infrastructure, emergency services. ~325+ controls. Examples: national security systems, critical infrastructure. Determination: Assess potential impact to confidentiality, integrity, availability separately. Overall system categorization = high-water mark (highest rating across three dimensions). If any rated High, entire system categorized High. Impact level drives control baseline—higher impact requires more stringent controls. Critical determination affecting security rigor and cost.

What is Authority to Operate (ATO) and how obtained? ▼

Authority to Operate (ATO) is formal authorization by senior agency official (Authorizing Official - AO) permitting information system to operate based on acceptable risk. ATO demonstrates security controls implemented and assessed, residual risk understood and accepted, system authorized for defined period (typically 3 years with continuous monitoring). Obtaining ATO: Complete RMF process: Categorize system (FIPS 199), select security controls (NIST 800-53 baseline), implement controls, document in System Security Plan (SSP), conduct independent security assessment (Security Assessment Report - SAR), remediate or document findings in Plan of Action and Milestones (POA&M), prepare authorization package (SSP, SAR, POA&M), present to Authorizing Official, AO makes risk decision: ATO, Denial, or conditional authorization. ATO duration: Typically 3 years. Requires continuous monitoring maintaining authorization between formal reassessments. Material changes (architecture, threat environment, controls) may require reauthorization. Without ATO: System cannot legally process federal data or connect to federal networks. ATO prerequisite for federal system operation demonstrating acceptable security posture. For contractors, ATO or equivalent security authorization required for federal contracts.

What is continuous monitoring and why required? ▼

Continuous monitoring provides ongoing visibility into security posture maintaining authorization between formal assessments. FISMA Reform Act of 2014 emphasized continuous monitoring shifting from periodic point-in-time audits to real-time security awareness. Components: Automated security tools (vulnerability scanning, configuration management, SIEM, log analysis), ongoing control assessment (sample testing of controls), security metrics and dashboards (leadership visibility), change control (tracking system changes and security impact), POA&M management (remediation tracking), annual assessment (formal reassessment of controls), incident monitoring (detection and response). Benefits: Early detection of security degradation or vulnerabilities, faster response to threats and changes, informed ongoing authorization decisions, reduced reassessment burden (leveraging continuous data vs. starting fresh), operational efficiency (automation reduces manual assessment). Requirements: FISMA and OMB require continuous monitoring programs for all federal systems. Agencies report FISMA metrics quarterly to OMB including vulnerability scanning, POA&M status, incident statistics. Continuous monitoring maintains ATO demonstrating to AO that security posture remains acceptable. Failure to maintain continuous monitoring can result in ATO suspension or termination requiring system shutdown until security restored.

How can Glocert help with FISMA compliance? ▼

Glocert provides comprehensive FISMA services: Readiness assessment evaluating current security against FISMA/NIST requirements with gap analysis and roadmap; RMF implementation guiding through all seven RMF steps from categorization through authorization; Security categorization conducting FIPS 199 analysis determining impact level; Control implementation implementing NIST 800-53 controls across all families (technical, operational, management); SSP development creating comprehensive System Security Plans; Security assessment conducting independent assessments with SAP and SAR; ATO support preparing authorization packages and engaging authorizing officials; Continuous monitoring establishing automated monitoring programs with metrics and dashboards; Incident response developing plans and US-CERT reporting procedures; IG audit preparation preparing for Inspector General inspections; Ongoing support annual assessments, reauthorization, POA&M management. Expertise: FISMA and OMB policy, NIST frameworks (800-53, 800-37, FIPS 199), RMF and ATO process, federal security requirements, IG audit expectations. Experience with federal civilian agencies, DOD contractors, FedRAMP providers achieving and maintaining FISMA compliance and ATOs.

Why Choose Glocert for FISMA?

Federal Cybersecurity Expertise

Glocert International specializes in FISMA compliance, bringing deep expertise in Federal Information Security Management Act and OMB policy, NIST standards (800-53, 800-37, 800-171, FIPS 199), Risk Management Framework and ATO process, federal security requirements and best practices, Inspector General audit expectations and preparation, and continuous monitoring and automation. We understand both regulatory requirements and practical implementation challenges helping federal agencies and contractors achieve compliance efficiently while building effective security programs protecting sensitive federal data.

End-to-End RMF Support

FISMA compliance requires navigating complex RMF process from initial categorization through authorization and ongoing monitoring. We provide integrated services across entire RMF lifecycle including security categorization and control selection, System Security Plan development, control implementation across all families, independent security assessment and testing, authorization package preparation and AO engagement, ATO achievement, continuous monitoring program implementation, annual reassessments and reauthorization, and POA&M management and remediation tracking. Comprehensive support ensures smooth progression through RMF achieving ATO efficiently while maintaining authorization long-term.

Proven Federal Success

We've successfully helped federal agencies and contractors achieve FISMA compliance including federal civilian agencies (executive branch, independent agencies), DOD contractors requiring FISMA-equivalent security, FedRAMP cloud service providers, state and local governments operating federal programs, and grant recipients handling federal data. Experience spans various impact levels (Moderate and High systems), system types (applications, infrastructure, cloud, mobile), and authorization contexts (new ATOs, reauthorizations, continuous monitoring). Track record demonstrates ability to achieve ATOs and maintain compliance meeting federal security requirements.

Related Services

Federal organizations implementing FISMA often need complementary services. Glocert International also provides FedRAMP authorization (cloud service security authorization aligned with FISMA), NIST 800-171 compliance (controlled unclassified information protection for contractors), NIST 800-53 assessment (security control implementation and testing), penetration testing and security assessments, incident response planning and tabletop exercises, and security awareness training programs. We coordinate multiple engagements providing integrated federal cybersecurity addressing FISMA alongside other compliance requirements efficiently.

Achieve Federal Security Excellence

Contact us today to learn more about our FISMA compliance services and how we can help you achieve ATO, meet federal security requirements, and protect sensitive government data.

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