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What You Need to Know About CMMC vs. FedRAMP: Key Differences
What You Need to Know About CMMC vs. FedRAMP: Key Differences

What You Need to Know About CMMC vs. FedRAMP: Key Differences

  • Updated on June 14, 2024
  • /
  • 7 min read

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The issue of CMMC vs FedRAMP can be a confusing one. Some businesses may need one or the other, while others may need both. With that in mind, here is a quick guide to what you need to know about CMMC vs FedRAMP.

CMMC FedRAMP
Purpose The main purpose of CMMC is to ensure that Defense Industrial Base (DIB)
contractors have sufficient cybersecurity to protect Controlled Unclassified
Information (CUI) and Federal Contract Information (FCI) across the
defense supply chain.
FedRAMP is focused on standardizing the security of cloud solutions
and services used by federal agencies. It ensures that cloud services meet
the federal government’s cybersecurity requirements.
Scope CMMC applies to any organization that handles CUI and FCI.
This includes both contractors and subcontractors in the Department
of Defense’s supply chain.
The scope of FedRAMP encompasses the security assessment, authorization,
and continuous monitoring of cloud services used by U.S. federal agencies.
It applies to all cloud service providers (CSPs) that handle federal data
Applies to CMMC is required for companies that want to do business with the
Department of Defense
All federal government agencies are required to use FedRAMP-compliant cloud
solutions, and contractors who work with the federal government are also
generally required to use FedRAMP-compliant cloud solutions.
Enforcement The Department of Defense enforces CMMC via the Cyber-AB FedRAMP is enforced by the General Services Administration (GSA) in
collaboration with the Joint Authorization Board (JAB), which includes
representatives from the Department of Defense, Department
of Homeland Security, and GSA.
Guidelines CMMC leverages other compliance standards including NIST SP 800-171,
NIST SP 800-172, FAR 52.204-21, and DFARS 252.204-7012. CMMC guidelines
focus on implementing and standardizing security controls throughout
an organization.
FedRAMP mandates that cloud service providers (CSPs) implement security
controls based on NIST SP 800-53, tailored to the impact level (Low, Moderate,
or High) of the data they handle. FedRAMP leverages existing compliance
frameworks, particularly NIST SP 800-53 for security controls, and FIPS 199 for
impact level categorization, ensuring that federal data in cloud environments is
protected according to federal standards.
Levels CMMC 2.0 has three levels:
Level 1 (Foundational)
Level 2 (Advanced)
Level 3 (Expert)The requirements to meet CMMC vary depending on the level required.
FedRAMP has three impact levels:

Low: Basic security controls; minimal risk; less stringent assessment.

Moderate: Comprehensive security controls; moderate risk; regular
assessment and continuous monitoring.

High: Extensive and rigorous security controls; high risk; the most
thorough assessment and monitoring protocols.

Certification Process Organizations must undergo a third-party assessment to achieve a specific
CMMC level. For Level 1 and some Level 2, organizations are required to
conduct an annual self-assessment, with senior official affirmation. For
critical Level 2 and Level 3, organizations must use a C3PAO for a third-party
assessment or undergo a government-led assessment for Level 3.
Organizations must undergo a third-party assessment to achieve a specific
CMMC level. For Level 1 and some Level 2, organizations are required to
conduct an annual self-assessment, with senior official affirmation. For critical
Level 2 and Level 3 organizations must use a C3PAO for a third-party
assessment or undergo a government-led assessment for Level 3.

What exactly is CMMC vs FedRAMP

CMMC stands for Cybersecurity Maturity Model Certification. It measures the effectiveness of an organization’s cybersecurity. CMMC is required for entities participating in the Defense Industrial Base (DIB) sector and the Department of Defense (DOD) supply chain.

FedRAMP stands for Federal Risk Authorization Management Program. It is a cloud-specific security certification. FedRAMP is required for all cloud service providers handling data for federal government agencies.

FedRAMP is mandatory for federal cloud services; CMMC certification is required for DoD contractors, influencing data center security.

The business benefits of CMMC vs FedRAMP

Acquiring CMMC certification is really only a business benefit if you specifically want to work in the DIB. FedRAMP, by contrast, is widely regarded as the gold standard in cloud security. It is therefore highly in demand by state and local agencies. Many businesses and other private organizations also request FedRAMP.

The framework of CMMC vs FedRAMPs

Even though CMMC and FedRAMP are both ultimately based on NIST specifications, their certification frameworks and processes are clearly different.

The framework of CMMC

At present, CMMC has five levels. This is due to be streamlined to three. These will be foundation, advanced, and expert.

The foundational level is for contractors handling Federal Contract Information (FCI). The advanced level is for contractors handling Controlled Unclassified Information (CUI). It is essentially a replica of NIST SP 800-171. The expert level is only required for contractors handling the most sensitive information. It will still be based on NIST SP 800-171 but will contain elements of NIST SP800-172.

The framework of FedRAMP

FedRAMP also has three main impact levels. These are high, medium, and low. There is a fourth level officially called Low-Impact Software-as-a-Service (Li-SaaS) and probably better known as FedRAMP Tailored. As its name suggests, however, this is exclusively for low-impact SaSS, particularly collaborative tools.

With FedRAMP, each government agency categorizes the level of security it requires for each type of data it handles. FedRAMP-compliant CSPs can bid on any project at the level for which they are certified (or below).

FedRAMP is based on NIST SP 800-53 but is both broader and deeper. It is broader in the sense that it expands upon the NIST SP 800-53 controls and deeper in the sense that it is focused purely on the cloud. CMMC, by contrast, applies in any environment.

Achieving compliance with CMMC vs FedRAMP

The DOD recognizes FedRAMP audits (and ISO 27001 audits) for any relevant aspects of CMMC compliance. With that said, there are still major differences between the process for achieving compliance with CMMC vs FedRAMP.

Achieving compliance with CMMC

As the system currently stands, third-party certification is required for levels one, three, and five. Levels two and four do not require certification.

When the system changes, level one will require an annual self-assessment. Level two will require tri-annual external assessments. Some programs will require annual external assessments. Level three will require triannual government-led assessments.

Achieving compliance with FedRAMP

At present, there are no known plans for changes to the FedRAMP compliance system. This can be achieved either through validation with any government agency or through validation from the Joint Advisory Board (JAB).

The main difference between the two processes is that the agency process starts with partnership establishment. The JAB process starts with a readiness assessment and FedRAMP Connect. In the agency process, businesses have the option to undertake a readiness assessment. It’s highly recommended that they do so, but it is still optional.

The following stages of the process are the same for both routes. They are a full security assessment, the authorization process itself, and then continuous monitoring via ongoing security audits.

Compliance frameworks are converging through continuous monitoring and AI governance tools. By 2026, expect standard shared controls across enterprises.

Technically, only the agency process results in a full authorization to operate (ATO). JAB can only provide a provisional authorization to operate PATO. In reality, the two authorization processes have equal standing.

Timescale and costs for achieving CMMC vs FedRAMP

It’s very difficult to provide hard-and-fast guidance on the timescale and/or costs for achieving CMMC vs FedRAMP. This is because they will depend partly on what level you want to achieve and partly on where you are now.

As a rough guideline, however, CMMC levels 1 and 2 (or foundation) and FedRAMP low can, in principle, both be achieved in about three months. CMMC levels 3 and 4 (or advanced) and FedRAMP medium can be achieved in 6-12 months. CMMC level 5 (or expert) and FedRAMP high are both likely to take at least 12 months.

 

Read More:

Is CMMC Cloud Certification Worth The Effort?

Should You Become FedRAMP PaaS Compliant?

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Frequently Asked Questions


  • What are the main differences between CMMC and FedRAMP compliance?
    CMMC (Cybersecurity Maturity Model Certification) focuses on protecting Controlled Unclassified Information (CUI) across the Department of Defense (DoD) supply chain. It applies to defense contractors and measures security maturity across five levels, from basic hygiene to advanced practices. FedRAMP (Federal Risk and Authorization Management Program) standardizes security for cloud service providers working with federal agencies. It certifies cloud systems at Low, Moderate, or High impact levels. FedRAMP (Federal Risk and Authorization Management Program) standardizes security for cloud service providers working with federal agencies. It certifies cloud systems at Low, Moderate, or High impact levels.
  • How do CMMC and FedRAMP impact cloud security requirements?
    Both CMMC and FedRAMP strengthen cloud security, but they go about this task in different ways. FedRAMP sets a unified framework of controls based on NIST 800-53 to ensure cloud service providers maintain consistent security to government-approved standards. CMMC extends beyond cloud environments. It requires defense contractors to implement cybersecurity organization-wide best practices to safeguard Controlled Unclassified Information (CUI). When cloud solutions are used in defense contracts, there is often an overlap between FedRAMP and CMMC. This means that using FedRAMP-certified cloud providers usually helps organizations meet parts of their CMMC requirements.
  • What types of organizations need to meet CMMC and FedRAMP standards?
    CMMC applies to all contractors and subcontractors within the Department of Defense supply chain that handle Federal Contract Information (FCI) or Controlled Unclassified Information (CUI). FedRAMP compliance is required for cloud service providers (CSPs) offering cloud products or services to federal agencies. Organizations handling FCI and/or CUI belonging to the DoD in a cloud environment will typically need to comply with both standards. This means they will need to be CMMC-compliant themselves and use FedRAMP-compliant CSPs.
  • How does FedRAMP compliance affect federal contracts?
    FedRAMP compliance provides assurance to federal agencies that their cloud-based data and workloads are managed under consistent, government-approved security standards. It is therefore mandatory for any cloud service provider (CSP) seeking to host federal data. Federal agencies can only use CSPs that have achieved a FedRAMP Authorization to Operate (ATO) at the appropriate impact level. Achieving FedRAMP compliance not only enables CSPs to serve government clients but also streamlines future federal contract bids through reciprocity across agencies. Noncompliance, on the other hand, can immediately disqualify a vendor from consideration.
  • How does CMMC compliance evolve with security threats?
    CMMC is closely aligned with the NIST standard and, like NIST, it is designed to adapt to changes in the cybersecurity landscape. The standard is periodically updated to reflect developments such as emerging attack vectors, new technologies, and lessons learned from previous incidents. In addition to implementing the updated standards, organizations are required to review and update their practices regularly. This ensures their defenses remain strong enough to cope with all relevant cyberthreats.

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