Organizations seeking to work with the US government today must navigate a growing array of compliance requirements. Among the most prominent security frameworks are the Cybersecurity Maturity Model Certification (CMMC) and Federal Risk and Authorization Management Program (FedRAMP), each playing a critical role in securing federal information and systems.
Despite their overlap in design to protect sensitive government data and ensure robust cybersecurity practices, they serve different purposes, apply to different types of vendors, and follow distinct compliance processes. In this article, we’ll define both CMMC and FedRAMP, and highlight their benefits, key similarities, and notable differences.
What is CMMC?
CMMC is a Department of Defense (DoD) program that was developed to protect against cyber-attacks attempting to exfiltrate certain types of data created and/or maintained by the Defense Industrial Base (DIB). More specifically, the data it protects pertains to Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) which is stored, processed, or transmitted by defense contractors and the entire defense supply chain, often referred to as the DIB. The Office of the Under Secretary of Defense for Acquisition & Sustainment [OUSD(A&S)] within the DoD developed the CMMC Framework in collaboration with DoD stakeholders, University Affiliated Research Centers (UARCs), Federally Funded Research and Development Centers (FFRDC), and industry partners.
Under the supervision of the DoD in conjunction with Cyber AB, the accreditation body overseeing the CMMC ecosystem, this certification expands upon previously established initiatives. Since September 2017, defense contractors have been mandated to adhere to the controls outlined in NIST SP 800-171, as stipulated Defense Federal Acquisition Regulation Supplement (DFARS) 252.204-7012. The implementation of DFARS 7019 further necessitated that these contractors conduct self-assessment and report their score in the Supplier Performance Risk System (SPRS). However, concerns arose regarding the accuracy and honesty of the attestations made by these organizations, and the overall cybersecurity practices required by organizations to protect this important information – CUI and FCI.
Consequently, CMMC was established, mandating levels of security and compliance via maturity levels as defined in future DoD contracts (subject to the finalization of the 48 CFR regulation). Anticipated regulations will require that DIB contractors implement specific cybersecurity protection standards and, when required, obtain CMMC certification thorough an assessment by a Certified Third-Party Assessment Organization (C3PAO) to qualify for a DoD contract award. Other federal agencies such as GSA have signaled that CMMC may be required for suppliers pursuing specific federal contracts, though those requirements would not fall under the current or expected DFARS clauses.
Benefits of CMMC Compliance
CMMC certification comes with notable benefits as the framework integrates a variety of cybersecurity standards and best practices, aimed at:
- Proactively improving DIB cybersecurity to address emerging threats
- Ensuring accountability while reducing obstacles for compliance with DoD regulations
- Fostering a collaborative culture of cybersecurity and resilience
- Upholding public trust through adherence to high professional and ethical standards
Compliance with CMMC also strengthens overall security posture, reduces risk, and helps organizations better meet evolving cybersecurity standards.
What is FedRAMP?
FedRAMP is a comprehensive government initiative that establishes a uniform method for security assessment, authorization, and ongoing monitoring of cloud products and services. In recent years, as the adoption of cloud solutions has surged, it has become increasingly vital for organizations utilizing cloud technologies – and engaging with federal agencies – to implement strong cloud security measures.
Initially, however, numerous federal agencies adhered to their own standards for obtaining an authority to operate (ATO), which caused confusion and rendered the ATO approval process challenging, inconsistent, and prolonged for both businesses and agencies. To address this issue, the government established FedRAMP, which offers a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services across the government. This framework was developed through the collaboration of several agencies, including the General Services Administration (GSA), the National Institute of Standards and Technology (NIST), the Department of Homeland Security (DHS), the National Security Agency (NSA), and DoD, among others.
Benefits of FedRAMP Compliance
There are numerous advantages for Cloud Service Providers (CSPs) and federal agencies seeking to engage in business partnerships to pursue FedRAMP compliance. The most notable benefits include:
- Substantial savings in both cost and time due to a “do once, use many times” framework
- A standardized method for risk-based management
- Increased transparency between agencies and CSPs
- Better consistency and quality in the Federal security authorization process
Additionally, due to FedRAMP’s rigorous approach to security assessment and continuous monitoring, compliance with the framework ensures that CSPs, their cloud service offerings (CSOs), and federal agencies meet strict cybersecurity requirements, protecting sensitive data and reducing risk of data breaches.
CMMC vs. FedRAMP: Key Differences
CMMC and FedRAMP are mutually exclusive and have entirely different applicability. Notably, FedRAMP targets a specific product or a grouped offering, which is the CSO that is operated by the CSP and provided to customers, whereas CMMC focuses on how an organization protects specific data types (FCI, CUI) in an organization, a business unit, or a specific enclave within the organization. Aside from rare and unique contract provisions, FedRAMP and CMMC will not be required for the same assessment scope, product, or offering. It is possible that CSPs may have a CMMC requirement. However, in contrast, CSOs will not have a CMMC requirement and may have a FedRAMP requirement instead, which is driven by several DFARS clauses.
FedRAMP Authorization requires sponsorship by a federal agency in which said agencies review the security assessment package generated by the CSP and 3PAO to grant an ATO followed by a review from the FedRAMP Program Management Office (PMO) and issuance of the CSO’s FedRAMP Authorization. While CMMC has a PMO within DoD, it does not review the output of assessment to determine certification and, instead, oversees the implementation and effectiveness of the CMMC program.
FedRAMP and CMMC (in most instances) will require an assessment by a third-party assessment organization. While FedRAMP requires all assessments to be performed by an accredited 3PAO, the CMMC level written into a contract, RFP, or solicitation will dictate whether an assessment performed by a Certified Third-Party Assessment Organization (C3PAO) is needed.
Moving Forward with your CMMC or FedRAMP Assessment
Understanding the requirements and expectations outlined in DFARS 252.204-7012 and the new context within the CMMC regulations—not to mention the well-established FedRAMP Program—is certainly no easy feat.
While CSPs and DIB organizations navigate the applicability of these requirements, it's important to focus on contractual requirements, regulations, the data that is being processed, and how these services are provided to the DIB.
Our experience as a leading FedRAMP 3PAO and CMMC C3PAO could be of further assistance as you prepare for your CMMC or FedRAMP assessments. Organizations may choose to have Schellman perform a readiness assessment using the CMMC and FedRAMP requirements and standards prior to undergoing full assessment under the appropriate framework. If you’d like to proceed with one of these readiness assessments or learn more about how Schellman can help, contact us today and we’ll get back to your shortly.
In the meantime, discover additional CMMC and FedRAMP insights in these helpful resources:
About Tim Walsh
Tim Walsh is a Manager in Schellman's Federal Practice overseeing both the emerging CMMC assessment program and the established FedRAMP assessment program. Prior to joining Schellman in 2019, Tim worked as a Systems Engineer for a Defense Contractor specializing in the design of physical security systems for Naval installations across the United States. Tim also led and supported various other projects, including software development of an inventory and logistics program used in support of Naval vessels as well as participating in Internal Research & Development (IRAD) of critical operations.