The first step to preparing for a FISMA assessment is to perform a gap assessment to identify where you are in preparation to meet the strict requirements. This gap will cover a variety of topics, including:
- Rundown of what is required for FISMA
- Review of each security control in the defined categorization level to determine – based on interviews – level of implementation
- Explanation of the intent of each control and what will need to be provided as supporting evidence during the assessment.
- Quick way to determine overall readiness for FISMA
Preparing for FISMA is no small undertaking. If one has not gone through a regulatory compliance assessment before, it may take some time to develop the suite of documentation to provide to the assessors. Fortreum team members are well versed in FISMA requirements at respective agencies and can help support you in this development activity.
- Obtain agency-specific templates
- Validate FIPS 199 security categorization level
- Develop FISMA security package, including:
- System Security Plan
- Contingency Plan
- Configuration Management Plan
- Incident Response Plan
- Privacy Impact Assessment
- Boundary validation as part of documentation development
- Full program development to ensure IT service offering is ready for assessment and authorization
An independent assessment is required to validate the security posture of the IT service. This can be performed by the agency themselves, or via an independent third party such as Fortreum.
- Security control review of the in-scope security controls from NIST SP 800-53.
- Vulnerability scanning of operating systems and databases
- Penetration testing for FISMA High systems
- Results of all testing activities are documented in a Security Assessment Report (SAR), with risk levels appropriately assigned to identified weaknesses
- Recommendation to the authorization official on next steps
Obtaining a FISMA authorization step one, but maintaining it requires continual support. Each agency performs continuous monitoring a little differently, including taking it completely in-house or outsourcing it entirely to the service provider.
- Includes periodic spot checks, as defined by the federal agency
- Process to ensure the security posture does not degrade over time
- Retesting required at least every 3 years, but in some cases may be required annually
- Leveraging automation will help validate that the security posture is properly being maintained over time