USGov RMF Series: Achieving FISMA Compliance (ATO) for Defense Agencies

In previous posts, FISMA Compliance For Intelligence Agencies, we explored how intelligence agencies can achieve Federal Information Security Modernization Act (FISMA) compliance using the ICD 503. In this post, we will dive into how defense agencies approach FISMA compliance. Specifically, we will focus on how these agencies align their risk management practices with the DOD Instruction 8510.01 - RMF For DoD Systems.

Understanding the DoD 8510.01 RMF

The general RMF process, as defined by the National Institute of Standards and Technology (NIST), is a structured approach to identifying, assessing, and managing risks to information systems. The DoD has tailored this framework (DoD RMF 8510.01) specifically for defense systems to align with mission requirements and regulatory demands. It encompasses six key steps:

1. Categorize Information System
2. Select Security Controls
3. Implement Security Controls
4. Assess Security Controls
5. Authorize Information System
6. Monitor Security Controls

Defense agencies must follow these steps meticulously to ensure that they meet both FISMA and DoD-specific security requirements.

Step 1: Categorize Information System

The categorization process involves identifying the types of information that the system processes, stores, or transmits. It defines the potential impact levels (low, moderate, or high) on confidentiality, integrity, and availability. Defense agencies use NIST Special Publication (SP) 800-60 and DoD-specific guidance to categorize their systems according to mission-criticality and risk.

Key Considerations:

• Ensure that the system categorization aligns with DoD mission-critical functions.
• Engage with mission owners and stakeholders to accurately assess the system’s impact on operations.

Step 2: Select Security Controls

Once the system is categorized, the next step is to select appropriate security controls. The DoD RMF process leverages NIST SP 800-53 as the primary control catalog, but it also incorporates additional DoD requirements such as those outlined in DoD Instruction (DoDI) 8500.01 and the Defense Information Systems Agency (DISA) Security Technical Implementation Guides (STIGs).

Key Considerations:

• Leverage automated tools like the Enterprise Mission Assurance Support Service (eMASS) for selecting, tracking, and reporting security controls.
• Ensure controls are tailored to the specific defense agency environment and the system’s risk profile.

Step 3: Implement Security Controls

After selecting the required security controls, the next step is implementing them in the information system. For defense agencies, the implementation phase must ensure that technical, operational, and managerial controls are configured according to both DoD and NIST guidance.

Key Considerations:

• Use DISA STIGs and Security Requirements Guides (SRGs) to ensure systems are securely configured.
• Establish baselines for continuous monitoring and system hardening.
• Document the implementation of controls in system security plans (SSP) using eMASS.

Step 4: Assess Security Controls

The assessment phase evaluates the effectiveness of the implemented controls. Defense agencies must conduct security testing and evaluations to ensure that controls are functioning as intended. Independent assessors or security control assessors (SCA) are responsible for reviewing the controls and identifying any weaknesses.

Key Considerations:

• Perform vulnerability scanning, penetration testing, and system assessments based on DoD guidelines.
• Engage SCAs to provide an objective assessment of the security controls.
• Address and remediate vulnerabilities or weaknesses identified during assessments.

Step 5: Authorize Information System

Once the assessment is complete, the authorizing official (AO) reviews the security controls assessment and determines whether the system is ready for operation. The AO evaluates residual risks and decides whether to grant an ATO, interim ATO (IATO), or deny authorization.

Key Considerations:

• Provide the AO with comprehensive risk management documentation, including SSPs, risk assessments, and POA&Ms (Plan of Action and Milestones).
• Prepare for additional scrutiny, especially in systems handling sensitive or classified information.

Step 6: Monitor Security Controls

After obtaining an ATO, defense agencies must continually monitor their systems to ensure ongoing FISMA compliance. Continuous monitoring involves real-time assessments of system performance, threat intelligence updates, and periodic reassessments of controls.

Key Considerations:

• Utilize tools like eMASS and continuous monitoring solutions for tracking vulnerabilities and configuration changes.
• Update security plans and risk assessments as the system environment evolves or new threats emerge.
• Conduct annual security reviews and FISMA assessments to maintain compliance.

Achieving FISMA Compliance through DoD RMF

Achieving FISMA compliance using the DoD RMF process requires strict adherence to DoD guidelines and federal security standards. The process is highly methodical, and defense agencies need to coordinate closely with various stakeholders, including system owners, assessors, and authorizing officials, to ensure that risks are properly managed and controls are effectively implemented.

By following the RMF process, defense agencies not only meet FISMA requirements but also enhance the security posture of their information systems. The result is a well-governed system that is resilient to cyber threats and capable of supporting the critical mission of national defense.

Conclusion

Defense agencies seeking FISMA compliance must leverage the DoD RMF process to achieve an ATO. The process provides a comprehensive approach to categorizing, selecting, implementing, assessing, authorizing, and monitoring security controls. Through meticulous documentation, assessment, and continuous monitoring, defense systems can be secured in line with both DoD and federal standards, ensuring compliance with FISMA and maintaining national security.