Navigating the landscape of federal compliance can be a daunting task for any organization. Whether you are a contractor working with the Department of Defense, a cloud service provider for federal agencies, or a business handling sensitive information, understanding the right compliance requirements is essential to maintain your business relationships and protect your organization's from the penalties of non-compliance.
Below, we’ll demystify federal compliance by providing an overview of key information security frameworks including CMMC 2.0, FedRAMP, NIST SP 800-53, and NIST SP 800-171. Let’s dive into the purpose and applicability of each framework, and review practical tips to help you identify which standards apply to your business.
What is federal compliance?
Federal compliance refers to the laws, regulations, and guidelines established by the federal government. Applicable organizations must ensure that their practices and operations conform to these requirements to avoid legal penalties, work with federal agencies, and maintain good standing.
Federal compliance covers a broad range of areas, including:
- Healthcare: Regulations like HIPAA protect patient data and privacy.
- Finance: Laws such as the Sarbanes-Oxley Act (SOX) and the Dodd-Frank Wall Street Reform and Consumer Protection Act ensure financial transparency and accountability.
- Employment: Guidelines set by the Equal Employment Opportunity Commission (EEOC) and the Fair Labor Standards Act (FLSA) ensure fair labor practices.
- Environmental: Environmental Protection Agency (EPA) regulations, such as the Clean Air Act and Clean Water Act, protect the environment.
- Data privacy: Compliance with Federal Trade Commission (FTC) regulations, such as the Safeguards Rule, promote data privacy and protection.
- Taxation: Internal Revenue Service regulations ensure accurate tax reporting and payment.
- Information security: Federal standards for information security, such as FISMA, FedRAMP, and NIST frameworks, are designed to protect sensitive information, ensure data integrity, and secure systems against threats.
Because they are designed to help protect sensitive government information and critical infrastructure, federal standards for information security provide some of the most stringent and comprehensive requirements. Implementing these requirements can help any organization strengthen its cybersecurity practices and meet other business objectives, like winning contracts with federal agencies.
The Ultimate Guide to Federal Frameworks
Get an overview of the most common federal frameworks, who they apply to, and what their requirements are.
Key federal frameworks and who they apply to
Navigating federal compliance can be a major challenge. There are numerous federal regulations and standards, each designed to address specific industries or aspects of security, privacy, and operational practices. Understanding which ones apply to your business can be daunting.
Plus, many regulations and frameworks are similar or have overlapping requirements. For instance, NIST 800-53 and NIST 800-171 share some controls but are applied differently depending on the type of data and organization. CMMC and NIST 800-171 are both designed to protect CUI, but apply to organizations working with different federal agencies.
Not to mention the fact that compliance standards and regulations are frequently updated to address new threats and technological advancements. Keeping up with these changes and ensuring your business remains compliant is a continuous effort.
Let’s get a quick overview of the major federal frameworks for information security to help clarify their purpose and who needs to comply with each one.
Cybersecurity Maturity Model Certification (CMMC) 2.0
The CMMC 2.0 framework is designed to ensure that contractors and subcontractors working with the Department of Defense have adequate cybersecurity controls in place to protect sensitive data, namely Controlled Unclassified Information (CUI) and Federal Contract Information (FCI).
The standard is broken into three maturity levels, ranging from basic cyber hygiene (Level 1) to advanced (Level 3). It applies to all DoD contractors and subcontractors that handle CUI and FCI.
Federal Risk and Authorization Management Program (FedRAMP)
FedRAMP provides a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services used by federal agencies.The framework is based on NIST 800-53 controls and applies to all cloud service providers that offer services to federal agencies.
NIST Special Publication 800-53
NIST 800-53 is considered best practice for organizations with a strong security focus, and provides a catalog of security and privacy controls for federal information systems and organizations to ensure comprehensive protection. It primarily applies to federal agencies and their contractors, but Is widely adopted by private sector companies. Control baselines are tailored to different impact levels (low, moderate, high) based on the system’s criticality.
NIST Special Publication 800-171
Similar to CMMC 2.0, NIST 800-171 specifies requirements for protecting CUI in non-federal systems and organizations. It applies to non-federal organizations that handle CUI, including contractors and subcontractors working with federal agencies (CMMC 2.0 is specifically for DoD contractors and subcontractors). NIST 800-171 involves 110 security requirements derived from NIST 800-53 controls.
NIST Privacy Framework
The NIST Privacy Framework offers a set of guidelines to help organizations manage privacy risks and build customer trust. The framework is built around five core functions: Identify, Govern, Control, Communicate, and Protect. It is a voluntary framework that can be used by any organization, regardless of size, sector, or jurisdiction.
NIST Cybersecurity Framework (CSF)
NIST CSF offers a robust framework to help organizations manage and reduce cybersecurity risks. It provides a structured way for organizations to align cybersecurity activities with their business requirements and risk tolerance based on six functions: Governance, Identify, Protect, Detect, Respond, and Recover. NIST CSF compliance is mandatory for U.S. federal government agencies and certain federal agencies might mandate the use of the NIST CSF for their contractors, but the framework can be voluntarily adopted by any organization as a security best practice.
Criminal Justice Information Services (CJIS)
The CJIS Security Policy is a framework established by the FBI to protect sensitive criminal justice information (CJI) at the federal, state, and local levels. It sets minimum security requirements for the handling, transmission, and storage of CJI, ensuring that law enforcement agencies and their contractors maintain the confidentiality, integrity, and availability of this information. Law enforcement agencies, contractors, and any organization handling CJI must comply with CJIS Security Policy requirements. This compliance is typically assessed through regular audits conducted by the FBI or designated state agencies.
Texas Risk and Authorization Management Program (TX-RAMP)
TX-RAMP is a framework developed by the Texas Department of Information Resources (DIR) to ensure that cloud services used by Texas state agencies meet specific security requirements. The goal is to protect state data by standardizing the risk assessment and authorization process for cloud service providers (CSPs). Texas state agencies are prohibited from using cloud services that are not TX-RAMP authorized to ensure that all cloud services handling state data are vetted and secure.
| Framework | Purpose | Who it applies to |
|---|---|---|
| NIST 800-53 | Development of secure and resilient federal information systems | Mandatory for federal agencies and contractors as well as any organization that carries federal data |
| FedRAMP | Protection of federal information in the cloud | Mandatory for any organization that provides cloud computing products and services to government agencies |
| NIST 800-171 | Management of controlled unclassified information (CUI) to protect federal information systems | Mandatory for federal contractors, vendors, and service providers that store or share CUI |
| CMMC 2.0 | Protection of CUI and FCI that is shared with contractors and subcontractors of the DoD | Mandatory for any company and contractor that is working or wants to work within the Defense Industrial Base (DIB) |
| NIST CSF | Comprehensive and personalized security weakness identification | Mandatory for federal contractors and government agencies and recommended for commercial organizations |
| The NIST Privacy Framework | Identification and management of privacy risk | Recommended for organizations or agencies that handle privacy-related information or are also following NIST CSF |
| CJIS | Protection of the sources, transmission, storage, and generation of Criminal Justice Information (CJI) | Mandatory for any organization with access to, or that operates in support of, criminal justice services and information |
| StateRAMP | Provide a standardized approach for verifying the security of cloud service providers used by state and local governments | Cloud service providers that offer services to state and local governments or educational institutions |
| TX-RAMP | Ensures cloud service providers used by Texas state agencies comply with state-specific security and risk management requirements | Cloud service providers that wish to offer their services to Texas state agencies |
| NIST AI RMF | Provide organizations with guidelines for managing risks related to the development, deployment, and use of AI systems | Voluntary framework for organizations involved in the development, deployment, and use of AI systems |
Which federal framework is the right fit for your business?
Which compliance framework applies to your organization boils down to two factors: the type of data you handle and your business model.
Type of data
The information your organization handles will be a major indicator for which framework you’ll need to comply with.
If you handle FCI or CUI and either hold or want to bid on DoD contracts, you’ll need to be CMMC certified. If you handle CUI in non-federal systems, you’ll need NIST 800-171 compliance.
If you provide cloud services to federal agencies, FedRAMP is applicable, while NIST SP 800-53 is typically mandated for federal information systems or organizations working with federal agencies.
If your organization holds any Criminal Justice Information (CJI); or Criminal History Record Information (CHRI) then you will need to be compliant with CJIS.
If your organization works with Texas state agencies, universities, institutions, or entities then you need to be compliant with TX-RAMP to ensure you’re meeting the state’s security and privacy requirements, facilitating secure and efficient cloud service usage within the public sector.
Business model
Federal agencies will have specific mandates based on the type of information and systems you manage. NIST SP 800-53 is typically mandated for federal information systems, while NIST SP 800-171 applies to CUI in non-federal systems.
Review your contracts and agreements with federal agencies. They often specify which compliance frameworks you must adhere to. For DoD contracts, CMMC 2.0 requirements will be outlined. For cloud services, FedRAMP requirements will be specified.
