USGov RMF Series: Achieving FISMA Compliance for Federal Contractors

In previous posts, we have discussed achieving FISMA compliance from the perspective of federal agencies and cloud service providers (CSPs). However, federal contractors are also required to meet stringent compliance requirements to handle sensitive government data securely. Compliance frameworks like the Federal Acquisition Regulation (FAR), Defense Federal Acquisition Regulation Supplement (DFARS), and the Cybersecurity Maturity Model Certification (CMMC) play a critical role in ensuring that contractors align with FISMA requirements and remain eligible for federal contracts.

In this post, we will explore how federal contractors can achieve FISMA compliance by meeting the additional security requirements imposed by FAR, DFARS, and CMMC. These frameworks are essential for securing contracts across different sectors:

• FAR Regulations – for safeguarding Federal Contract Information (FCI).
• DFARS Requirements – for protecting Controlled Unclassified Information (CUI) within the Department of Defense.
• CMMC Certification – a maturity model aimed at certifying contractors’ cybersecurity practices when working with the DoD.

1. FAR

The Federal Acquisition Regulation (FAR) is a set of rules governing how the federal government procures goods and services. FAR Clause 52.204-21, “Basic Safeguarding of Covered Contractor Information Systems,” requires contractors to implement minimum security controls to protect Federal Contract Information (FCI). These controls are derived from NIST SP 800-171 and focus on safeguarding systems from unauthorized access.

FAR compliance is mandatory for contractors handling FCI but is just a starting point. For contractors dealing with Controlled Unclassified Information (CUI) or working with defense-related projects, additional measures are required.

2. DFARS

The Defense Federal Acquisition Regulation Supplement (DFARS) applies to contractors working with the Department of Defense (DoD). DFARS Clause 252.204-7012, “Safeguarding Covered Defense Information and Cyber Incident Reporting,” mandates that contractors must implement the security requirements outlined in NIST SP 800-171 to protect CUI.

In addition to safeguarding CUI, contractors must report any cyber incidents that could affect DoD systems or information. Achieving DFARS compliance involves conducting a gap analysis of your current security practices against NIST SP 800-171 and implementing the required controls.

3. CMMC: The Evolving Standard for DoD Contractors

The Cybersecurity Maturity Model Certification (CMMC) is a framework designed to ensure that contractors have the necessary cybersecurity measures in place to protect CUI. Unlike FISMA, which relies on self-assessments, CMMC requires third-party assessments to certify compliance with different maturity levels, depending on the sensitivity of the information.

CMMC v2.0 streamlines the certification process by aligning with NIST SP 800-171 and categorizing contractors into three levels:

• Level 1: Basic cyber hygiene for contractors handling FCI, aligned with FAR 52.204-21.
• Level 2: Advanced protection for CUI, based on NIST SP 800-171.
• Level 3: Enhanced protection for contractors handling highly sensitive data.

Contractors seeking to do business with the DoD must achieve the appropriate CMMC level, with CMMC Level 2 being the most relevant for contractors working with CUI.

Steps for Federal Contractors

To achieve FISMA compliance and meet the additional requirements of FAR, DFARS, and CMMC, contractors should take the following steps:

• Understand Your Data Environment: Identify whether your contract requires handling FCI or CUI and whether you work with defense-related projects. This will determine whether FAR, DFARS, or CMMC applies and to what extent.

• Implement NIST SP 800-171 Security Controls: NIST SP 800-171 is central to DFARS and CMMC compliance. Conduct a thorough assessment to ensure your information systems meet the control requirements. Some key areas include access control, incident response, system and communications protection, and risk management.

• Perform a Gap Analysis: Conduct a gap analysis against the required security controls (NIST SP 800-171 or NIST SP 800-53) to identify areas needing improvement. This analysis will highlight the steps you need to take to achieve compliance.

• Implement Security Policies and Procedures: Develop and maintain security policies and procedures that align with the FISMA, FAR, DFARS, and CMMC frameworks. Ensure your staff is trained in these policies to maintain compliance and security awareness.

• Prepare for CMMC Assessment (if applicable): If you are a DoD contractor, ensure you are ready for a CMMC assessment. This includes conducting internal audits, gathering necessary documentation, and engaging a third-party assessment organization (C3PAO) for certification.

• Report Cyber Incidents Promptly: Under DFARS, contractors must report cyber incidents within 72 hours of discovery. Ensure that your incident response plan includes a process for timely reporting and follow-up actions.

Conclusion

Achieving FISMA compliance for federal contractors involves navigating the complex requirements of FAR, DFARS, and CMMC. By aligning your cybersecurity practices with these frameworks, you ensure the protection of sensitive information and position your organization for success in the federal marketplace. Understanding the intersection of these requirements and taking a proactive approach to compliance will help contractors meet the evolving demands of federal cybersecurity standards.