CMMC
DoD certification verifying cybersecurity for FCI and CUI
FISMA
U.S. federal law for risk-based cybersecurity management
Quick Verdict
CMMC certifies DoD contractors' cybersecurity for FCI/CUI via tiered assessments, while FISMA mandates federal agencies' risk-based programs using NIST RMF. Companies adopt CMMC for DoD contracts; FISMA for federal compliance and resilience.
CMMC
Cybersecurity Maturity Model Certification (CMMC) 2.0
Key Features
- Independent C3PAO and DIBCAC third-party assessments
- Three cumulative maturity levels for tiered assurance
- Exact alignment to NIST SP 800-171 controls
- Mandatory flow-down to supply chain subcontractors
- Precise scoping for enclaves and enterprises
FISMA
Federal Information Security Modernization Act of 2014
Key Features
- NIST RMF 7-step risk management lifecycle
- Continuous monitoring and diagnostics requirements
- NIST SP 800-53 tailored security controls
- Annual IG evaluations and OMB reporting
- FIPS 199 system impact categorization
Detailed Analysis
A comprehensive look at the specific requirements, scope, and impact of each standard.
CMMC Details
What It Is
Cybersecurity Maturity Model Certification (CMMC) 2.0 is a DoD certification program verifying cybersecurity protections for Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) in the Defense Industrial Base (DIB). It uses a tiered, risk-based model with three cumulative levels, mapping to FAR 52.204-21, NIST SP 800-171 Rev 2, and NIST SP 800-172.
Key Components
- 14 domains (e.g., Access Control, Incident Response) with 17 Level 1, 110 Level 2, and 24 additional Level 3 practices.
- Built on NIST controls; requires System Security Plans (SSPs) and evidence via interviews, examinations, tests.
- Certification model: self-assessments (Level 1/2), C3PAO (Level 2), DIBCAC (Level 3), valid 3 years with annual affirmations.
Why Organizations Use It
Mandated for DoD contracts, ensuring eligibility; reduces breach risks, enhances supply chain trust, provides competitive edge in bids. Builds resilience against APTs, lowers insurance costs.
Implementation Overview
Phased approach: scoping, gap analysis, remediation, assessment preparation. Applies to all DIB primes/subcontractors handling FCI/CUI; complex for SMEs, aided by enclaves. Requires C3PAO/DIBCAC audits, POA&Ms (180-day closure).
FISMA Details
What It Is
Federal Information Security Modernization Act (FISMA) of 2014 is a U.S. federal law establishing a risk-based framework for protecting federal information and systems. It mandates agency-wide information security programs using NIST Risk Management Framework (RMF), a 7-step process: Prepare, Categorize, Select, Implement, Assess, Authorize, Monitor.
Key Components
- NIST SP 800-53 controls (over 1,000 across 20 families) tailored by FIPS 199 impact levels (Low/Moderate/High).
- Continuous monitoring, System Security Plans (SSPs), Plans of Action and Milestones (POA&Ms).
- Oversight by OMB, DHS/CISA, Inspectors General (IGs); annual metrics aligned to NIST Cybersecurity Framework.
- Compliance via Authorization to Operate (ATO), no formal certification but independent audits.
Why Organizations Use It
Mandatory for federal agencies/contractors; reduces breach risks, enables market access (e.g., FedRAMP). Builds resilience, efficiency; differentiates vendors.
Implementation Overview
Phased RMF approach: inventory, categorize, implement controls, assess/authorize, monitor. Applies to federal executive agencies, contractors; scales by size via automation. Involves audits, reporting. (178 words)
Key Differences
| Aspect | CMMC | FISMA |
|---|---|---|
| Scope | DoD contractors protecting FCI/CUI via NIST controls | Federal agencies/systems via NIST RMF/800-53 controls |
| Industry | Defense Industrial Base (DIB) contractors/subcontractors | Federal executive branch agencies/contractors |
| Nature | Certification program with tiered levels (1-3) | Mandatory federal law with RMF implementation |
| Testing | Self-assess/C3PAO/DIBCAC every 3 years + annual affirmations | Continuous monitoring, annual IG assessments, RMF ATOs |
| Penalties | Contract ineligibility, debarment, remediation costs | IG reports, OMB directives, funding/contract loss |
Scope
Industry
Nature
Testing
Penalties
Frequently Asked Questions
Common questions about CMMC and FISMA
CMMC FAQ
FISMA FAQ
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