How to Conduct a Cyber Risk Assessment for FISMA Compliance

November 26, 20234 min read

Conducting a cyber risk assessment for Federal Information Security Modernization Act (FISMA) compliance is a multi-step process that involves thorough planning, assessment, evaluation, and documentation of an information system’s security controls and inherent risks within a federal organization. Here’s a detailed guide on how to perform a cyber risk assessment to meet FISMA requirements.

Preliminary Preparations

Understanding FISMA Requirements

  • Familiarize yourself with the FISMA legislation and the National Institute of Standards and Technology (NIST) guidelines, especially NIST SP 800-53 for security controls and SP 800-30 for risk assessment methodologies.
  • Determine the FISMA categorization level of the information system (low, moderate, or high impact) based on the potential consequences of a security incident.

Assemble a Team of Experts

  • Identify a cross-functional team that includes IT professionals, security experts, risk management personnel, and stakeholders.
  • Designate a Chief Information Security Officer (CISO) or a similar role responsible for overseeing the risk assessment process.

Define the Scope of the Assessment

  • Clearly describe the boundaries of the information system, including hardware, software, data, processes, and personnel involved.
  • Include any third-party services or connections that may impact the system’s security posture.

Risk Assessment Process

Step 1: Risk Identification

  • Inventory all information system assets and resources.
  • Identify potential threats to the information system such as cyber-attacks, natural disasters, and human errors.
  • Detect vulnerabilities within the system that could be exploited by threats.

Step 2: Threat and Vulnerability Analysis

  • Use automated tools and manual methods to conduct vulnerability scans and security assessments.
  • Consider using threat intelligence services to understand emerging cybersecurity threats.
  • Assess the current security controls and their effectiveness in mitigating threats.

Step 3: Likelihood and Impact Determination

  • Estimate the likelihood of potential threats exploiting system vulnerabilities.
  • Assess the impact of potential incidents on the organization’s operations, assets, individuals, other organizations, and the nation.

Step 4: Control Analysis

  • Review existing security controls and determine if they are appropriately implemented.
  • Evaluate whether the controls are effective in reducing the risk to an acceptable level.

Step 5: Risk Determination

  • By combining the results from the likelihood and impact assessment, categorize the levels of risk for each threat and vulnerability pair.
  • Identify the risk appetite and tolerance levels set by the organization to aid in prioritization.

Risk Treatment and Documentation

Selecting Risk Responses

  • For each identified risk, decide on a response: mitigate, accept, transfer, or avoid.
  • For mitigation, select and recommend additional security controls or enhancements to existing controls.

Creating the System Security Plan (SSP)

  • Document the assessment findings and the chosen security controls in the SSP.
  • Update the SSP to include strategies for continuous monitoring and how the system addresses the identified risks.

Plan of Action and Milestones (POA&M)

  • Develop a POA&M that outlines tasks to address deficiencies in the information system’s security controls.
  • Include resources required, assigned responsibilities, and target completion dates for each task.

Final Steps

Review and Approval

  • Submit the SSP, risk assessment report, and POA&M to the designated authorizing official (AO).
  • The AO reviews the documents, making the final decision to authorize the system to operate.

Continuous Monitoring and Updates

  • After authorization, continue periodic assessments and monitoring to detect new risks and changes in the risk profile.
  • Update the SSP, risk assessment reports, and POA&M as necessary reflecting changes in the environment, technology, or operations.

Conducting a comprehensive cyber risk assessment is an ongoing process essential for maintaining FISMA compliance. It requires a vigilant approach to new threats and system changes, and an understanding that risk management is a continuous process aimed at securing federal information systems against evolving threats.