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Risk Management Frameworks (RMF) for DoD Contractors

The Risk Management Framework (RMF) provides guidelines for taking a risk-based approach to information system security and privacy for federal agencies, related contractors and subcontractors. It includes steps to identify and integrate best-practice security controls and privacy policies, as well as requirements for embedding processes to identify and mitigate emerging cybersecurity risks. The RMF provides seven steps to introduce a comprehensive risk management program into an organization. 

To safeguard federal information networks and connected systems of federal contractors, organizations will need to adopt a risk-based approach to their system development and deployment lifecycle. Therefore, an in-depth understanding of RMF is vital for any Department of Defense (DoD) contractor.

This guide explores the Risk Management Framework (RMF), what it means for DoD contractors, the steps an organization needs to take to be RMF compliant, and how Titania Nipper can help assess and maintain RMF compliance.

What is the Risk Management Framework (RMF)?

The Risk Management Framework (RMF) is a set of guidelines deployed for a risk-based approach to information system security and information privacy. The framework is comprehensive and is used to design and embed risk management processes within the information system development and deployment lifecycle. It allows organizations to scale cybersecurity defenses depending on the level of threat and encourages ongoing monitoring of system security.

The RMF is maintained by the National Institute of Standards and Technology (NIST) as part of its Federal Information Security Modernization Act (FISMA) duties. The RMF document draws from specific NIST publications which outline system security controls. 

FISMA makes it a requirement for US government agencies to embed cybersecurity programs and policies for IT risk assessment. FISMA covers both federal systems and non-federal systems that may process assets on behalf of federal agencies. This makes FISMA compliance extremely relevant to DoD contractors and subcontractors. FISMA aims to standardize the level of IT security across federal agencies and contractors and encourage a risk-based approach to cybersecurity policies. For DoD contractors, the RMF is a key tool for achieving this risk-based approach.

7 steps for RMF compliance for DoD Contractors

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1. Prepare the organization to embed the Risk Management Framework

The first step is to prepare all areas of the organization to embed the Risk Management Framework (RMF). This includes performing initial risk management tasks to contextualize the organization and its security risks and notifying all levels of the organization of their roles and responsibilities.

The preparation phase is focused on both the system and the organization. Reviewing existing controls and system security risks helps organizations understand the system-wide standards of security. This helps stakeholders identify and define common controls on an organization-wide level.

Tasks to complete during the preparation phase include:

  • Communication with all levels of the organization about RMF compliance and responsibilities
  • Establishing roles and responsibilities for the integration of the risk management system
  • Mapping system and network boundaries and creating an inventory of assets and devices
  • Identifying and recording baselines for common controls across systems and the entire organization
  • Preparing the allocation of resources to protect high-value systems and assets.

2. Categorize the system based on risk

In this step, organizations will categorize different systems in line with the type of information being processed and the level of risk of a cybersecurity incident. Documenting system characteristics and categorizing the security needs of each system component is an important step towards embedding the Risk Management Framework. Organizations can then understand the level of security controls, or the volume of resources required for each system. Categorization also means all system elements are within the same descriptive framework.

The process explores the potential impact an incident may have on areas of the system. Some systems may handle more sensitive information or are critical to the ongoing performance of the organization. These systems are deemed high risk as they pose the biggest potential impact to the organization if adversely targeted.

Tasks to complete during the categorization phase include:

  • Categorize information systems by type and the potential adverse impact from cybersecurity incidents
  • Provide each system with a risk value of low, moderate, or high, for different security objectives
  • Outline an overall risk level for individual systems that considers information types, security objects, and potential risks.

3. Select relevant controls from NIST SP 800-53

NIST SP 800-53 is a collection of security and privacy controls developed to safeguard government and non-federal information systems. It was developed by the National Institute of Standards and Technology (NIST) as part of its FISMA requirements. The controls aim to protect the integrity of systems and any user data they may contain. NIST 800-53 compliance is a requirement for federal and government agencies, but also contractors who operate on federal networks and systems.

Organizations must select and embed relevant controls from the publication to safeguard user privacy and system security. The controls focus on strengthening the integrity, confidentiality, and availability of federal systems. Controls and requirements are selected in line with the risk assessment in the categorization step. The selected controls will inform privacy and security plans. Required controls will be outlined in the contractual agreement with DoD contractors.

Tasks to complete during this phase of control selection include:

  • Selecting and tailoring security and privacy controls based on the needs and risks of individual system areas or environments. This is based on the information collected during the categorization step.
  • Identifying enhanced controls for high-risk system elements or unique organizational requirements.
  • Documenting controls to evidence compliance with any privacy and security requirements.

4. Implement and document the deployed controls

In this phase, the organization must embed and implement the selected security and privacy controls. The controls should be documented in the relevant privacy and security plans, which should be updated as controls are deployed. 

The previous step selected and tailored the relevant security and privacy controls. This phase ensures the controls are properly implemented and operating correctly.

The owner of the system will have responsibility for the deployment of the security controls. Requirements for DoD contractors will be outlined in their contracts or agreements. Deployment of controls will be reflected by the level of risk outlined by the categorization step.

Tasks to complete during this phase of control implementation include:

  • Deploying each control selected in the previous step and outlined by the security and privacy plans
  • Update the relevant security and privacy plans as each control is implemented.

5. Assess that the controls are functioning

In this step, organizations will determine whether the controls implemented in the previous phase are functioning correctly. Organizations will need to assess whether these controls are operating as expected and meeting system and organization security requirements.

This phase requires the initial steps of selecting an assessment team and developing an assessment plan. Once the plan is approved, each control can then be reviewed and assessed.

Reports on the outcome of assessment for each control should be reviewed, with further steps taken to resolve any found issues. Organizations can leverage automated system audit tools, such as Titania Nipper, to assess each control efficiently. A plan of action with milestones (POAM) should be deployed for any controls that are not functioning correctly.

Tasks to complete during the assessment phase include:

  • Developing an assessment plan for both security and privacy controls
  • Assigning an assessment team to carry out the assessment plan and review of controls
  • Assessing each control and producing reports to document compliance or issues
  • Updating security plans if controls are changed because of the assessment
  • Producing a POAM to address any unresolved issues with controls.

6. Authorize the operation of the system

In this step, a senior member of the organization will approve the level of control in light of security and privacy considerations. The individual will make the decision based on a package of documents including an executive summary, assessment reports, privacy and security plans, and any plan of action with milestones.

After determining the risk to systems and information has been properly planned for, the senior official will authorize the control or operation of the system. This step provides a level of accountability for security controls, drawing from the entire Risk Management Framework.

The tasks to complete during the authorization phase include:

  • Collecting and packaging the documents and plans outlined in the previous steps, including an executive summary
  • A member of senior management determines whether the security and privacy safeguards are adequate to protect the organization’s operations and assets
  • Authorization must be issued before the system becomes operational.

7. Monitor ongoing system risk and deployment of controls

The final step is the ongoing monitoring and maintenance of system security and information privacy. Systems will need to be continuously monitored in line with an established strategy and process. Security controls should be regularly assessed as part of this strategy. Activity logs will also be reviewed, and the ongoing risk assessment reports provided to senior management.

Ongoing monitoring is a key element of a successful Risk Management Framework. Controls and policies can be adapted to meet emerging threats, and the ongoing effectiveness of controls can be assessed and maintained.

The tasks to complete during this final step include:

  • Deploying a program to continuously monitor systems and controls over time
  • Adapting systems when required to meet emerging threats, new vulnerabilities, and updated technology
  • Improving the efficiency of monitoring through automated auditing tools to provide real-time insights into risk management.

Automate RMF assessment with Titania Nipper

Titania Nipper is a firewall and network configuration audit tool that can accurately assess network device controls from NIST 800-53, the source of security controls for RMF. Nipper can automate the assessment of NIST 800-53 controls relating to network devices with key benefits including risk prioritization, precise remediation with exact technical fixes as well as flexible, configurable easy to read reports. This makes assessing and maintaining RMF compliance straightforward.

The tool is trusted by federal agencies to demonstrate compliance and troubleshoot vulnerabilities. Nipper’s accuracy-advantage and trusted risk criticality rating make it a must-have tool for cyber leaders focused on establishing a defendable network by accurately detecting and remediating exploitable misconfigurations and non-compliances with trusted RMFs in routers, switches and firewalls.