CMMC 2.0 and FedRAMP are both essential frameworks for government agencies and companies that want to work with them. Yet each is designed for different purposes and target markets. 

Below, we’ll dive into the details of both CMMC 2.0 and FedRAMP to explore their requirements, key similarities and differences, and what it takes to get certified. Whether you're aiming to secure defense contracts or expand your cloud services to federal agencies, you’ll have a clearer picture of which framework fits your business needs and contractual requirements best.

What is CMMC 2.0?

The Cybersecurity Maturity Model Certification (CMMC) is a comprehensive framework established by the U.S. Department of Defense (DoD) to enhance the cybersecurity of contractors within the Defense Industrial Base (DIB).

The CMMC was created in response to several cybersecurity issues. One major concern was the increasing cyber threats targeting the DIB. Adversaries have been seeking to exploit vulnerabilities to steal sensitive information and intellectual property, with these threats growing in both frequency and sophistication.

Another issue was the inconsistent cybersecurity practices across the DIB. Prior to the CMMC, information security practices varied widely among contractors. Many did not have adequate measures in place to protect sensitive information, leading to breaches and compromised data.

Although there were already a number of federal frameworks for information security, like FedRAMP, the Department of Defense recognized the need for a robust and standardized approach specifically tailored to the Defense Industrial Base.

CMMC 2.0 involves three levels of compliance, depending on the level of data sensitivity, each with its own set of controls and practices:

• Level 1: Foundational. This level covers fundamental practices that every company should follow, like regularly updating antivirus software and controlling who has access to information. It's about getting the basics right to protect Federal Contract Information (FCI).
• Level 2: Advanced. Level 2 is more comprehensive and aligns with the NIST SP 800-171 standards. It’s designed for companies handling Controlled Unclassified Information (CUI). Here, you'll need to implement more detailed cybersecurity practices like encryption, incident response, and regular vulnerability assessments.
• Level 3: Expert. This is the highest level, aimed at companies dealing with the most sensitive information. It incorporates practices from NIST SP 800-172 and includes continuous monitoring, advanced threat detection, and proactive cybersecurity measures. It’s about being prepared for the most sophisticated cyber threats.

What is FedRAMP?

FedRAMP, which stands for the Federal Risk and Authorization Management Program, is a U.S. government-wide program that provides a standardized approach to security assessment, authorization, and continuous monitoring for cloud providers.

FedRAMP was introduced in 2011 and became law in December 2022 as part of the US National Defense Authorization Act. It encompasses 27 applicable laws and regulations, along with 26 standards and guidance documents, making it one of the most rigorous cybersecurity certifications globally.

As federal agencies transitioned from traditional software to cloud-based solutions, cloud service providers (CSPs) had to prepare authorization packages for each agency they wanted to work with. Authorization packages were inconsistent across agencies, resulting in a ton of manual, duplicate work for both the CSPs and the agencies.

FedRAMP addresses this issue by offering a consistent, standardized approach to streamline the authorization process. Utilizing a "do once, use many" framework, FedRAMP enables CSPs and federal agencies to reuse existing security assessments, significantly saving time and reducing duplicated efforts.

Like CMMC 2.0, FedRAMP categorizes authorizations into three impact levels based on the sensitivity and potential impact of data: Low, Moderate, and High, with different security requirements for each.

Does CMMC replace FedRAMP?

No, CMMC does not replace FedRAMP. Both programs serve different purposes and target different sectors within the U.S. federal government’s cybersecurity landscape. 

CMMC is specific to the defense sector, and is concerned with protecting CUI within the defense supply chain. FedRAMP applies to all federal agencies and is concerned with protecting any federal data stored or processed in cloud environments. 

Organizations involved with the DoD may need to comply with CMMC requirements, while those offering cloud services to any federal agency must comply with FedRAMP. 

In some cases, an organization that is FedRAMP compliant may not need to complete a CMMC 2.0 assessment. Recent FedRAMP reform measures included in the National Defense Authorization Act specify that if an organization is FedRAMP compliant, any federal agency can contract with them, including the DoD. FedRAMP includes a more comprehensive control set than CMMC 2.0, so if you are compliant with FedRAMP you are likely already compliant with CMMC 2.0 as well. 

How to decide which type of compliance you need:

• Choose CMMC 2.0 if your organization is part of the Defense Industrial Base or aims to engage in contracts with the DoD, and if protecting CUI and FCI within the defense supply chain is critical.
• Choose FedRAMP if your organization provides or plans to provide cloud services to federal agencies, and if meeting stringent cloud security requirements and protecting federal data in cloud environments is your primary concern.

Key similarities between CMMC 2.0 and FedRAMP

While each standard is designed for different sectors and purposes, CMMC 2.0 and FedRAMP share several similarities due to their overarching goal of enhancing cybersecurity. 

• Foundation in NIST standards: CMMC is primarily based on NIST 800-171, while FedRAMP is strongly influenced by NIST SP 800-53. This common foundation in NIST leads to similar or overlapping controls for areas like access control, incident response, configuration management, and audit and accountability. 
• Third-party assessments: For the most part, both frameworks require third-party assessments to verify compliance. CMMC 2.0 Levels 2 and 3 should be completed by certified Third-Party Assessment Organizations (C3PAOs)and all FedRAMP levels mandate assessments are done by accredited Third-Party Assessment Organizations (3PAOs). 
• Continuous monitoring and improvement: Both frameworks also emphasize the need for continuous monitoring and improvement of cybersecurity practices. This includes Plan of Action & Milestone (POA&M) tracking.
• Supply chain security: CMMC 2.0 focuses on protecting sensitive data within the defense supply chain, and FedRAMP focuses on the broader federal supply chain.
• Ongoing risk management: Both frameworks emphasize risk management practices to identify, assess, and mitigate risks to information systems.

Key differences between CMMC 2.0 and FedRAMP

While CMMC and FedRAMP share important similarities, they differ significantly in scope, certification process, and purpose. Let’s unpack these differences to better understand which framework is most applicable to your business. 

Purpose and scope

CMMC 2.0 aims to enhance the cybersecurity practices of contractors and suppliers within the DIB, specifically to protect CUI and FCI. It covers a wide range of cybersecurity practices and controls across three maturity levels, each with different requirements based on the sensitivity of the information handled.

FedRAMP focuses specifically on the security of cloud services and provides a standardized approach to security assessments, authorization, and continuous monitoring. The framework provides a standardized set of security controls based on NIST SP 800-53 for cloud products and services, and is applicable to all federal agencies.

Certification levels and process

CMMC 2.0 has three maturity levels, each with different requirements based on the sensitivity of information handled. Certification involves either self-assessment or third-party certification based on the compliance level and DoD contract specifications. Periodic assessments are required to maintain certification. 

FedRAMP does not have maturity levels, but rather three baselines, Low, Moderate, and High, which are all standardized sets of security controls that CSPs must implement to obtain authorization. FedRAMP level required for authorization will depend on sensitivity of data and the agency that is the authorizing official. All CSPs must also undergo a rigorous third-party assessment by an accredited 3PAO to obtain authorization, as well as provide regular reports to the authorizing federal agency to maintain compliance. 

Implementation cost

CMMC 2.0 includes revisions designed to make certification more accessible to a wider variety of organizations. Level 1 involves significantly less effort and resources than higher levels, which demand more stringent controls and comprehensive assessments. This tiered approach allows smaller organizations to achieve CMMC Level 1 certification and bid on DoD contracts. 

FedRAMP generally involves significant initial investment for the assessment and authorization process, along with ongoing costs for continuous monitoring and compliance. 

CMMC 2.0 vs FedRAMP: Choosing the right framework

When deciding between CMMC 2.0 and FedRAMP for your business it’s important to consider your current customer requirements, future business goals, and available resources. 

Contractual requirements and target market

If your business contracts with the DoD or plans to operate within the DIB, you will need to comply with CMMC 2.0. This includes suppliers and subcontractors handling CUI, FCI, or both. 

If you’re a cloud service provider for any federal agency, pursue FedRAMP authorization. This includes SaaS, SaaS, and IaaS solutions. 

Current compliance status

If you’re already compliant with a different federal framework, transitioning to either CMMC 2.0 or FedRAMP may be more straightforward based on the relationships between the various federal standards. 

NIST 800-53 is the grandaddy of federal frameworks. It provides a comprehensive catalog of security and privacy controls for federal information systems and organizations, except those related to national security. NIST 800-53 is extensive (over 1,000 controls across 20 control families, as of Rev. 5) because it is designed to address a wide array of federal information systems, regardless of their specific function or the type of data they handle.

FedRAMP uses a subset of NIST 800-53 controls tailored for cloud environments. These controls are mapped out to different impact levels (Low, Moderate, High) based on the potential impact of a security breach. FedRAMP ensures CSPs meet stringent security requirements before they can be used by federal agencies.

NIST 800-171 is another derivative of 800-53 designed to protect CUI in non-federal systems and organizations. It is designed for contractors and other non-federal entities that work with federal agencies but do not fall under the same comprehensive security requirements as federal agencies themselves. The 110 controls in NIST 800-171 are derived from a larger subset of NIST 800-53 controls that are most relevant to the protection of CUI.

CMMC 2.0 is essentially built on the controls in NIST 800-171, but are specific to the DoD. 

If your business is already compliant with NIST 800-171, transitioning to CMMC 2.0 may be more straightforward because NIST 800-171 rev. 2 controls are included within CMMC Level 2. 

FedRAMP encompasses a broader control set than CMMC 2.0, and it leverages NIST 800-53 for baseline security control guidance. If your business already follows NIST 800-53 or cloud security standards like ISO 27001, aligning with FedRAMP requirements may be the clearer path.

Conduct a gap analysis to compare your existing security controls with CMMC 2.0 and 

FedRAMP requirements and gauge the amount of time, effort, and resources it would take to implement any additional controls, keeping in mind that FedRAMP includes a more comprehensive control set than CMMC 2.0.