Bluedog Inc.
September 2023
THE 30,000 FOOT VIEW OF RMF
IMPLEMENTATION
…Understanding an implementation of NIST’s RMF is not daunting,
when seen from above
Abstract
The Risk Management Framework
(RMF) is an integral component of
information security management,
primarily associated with NIST's SP
800-37 guide, as a part of the
broader E-Government Act of
2002, seeks to enhance the
management of electronic
government services and
processes.
RMF guides federal agencies
through a well-defined seven-step
process, ensuring the security,
authorization, and effective
management of IT systems.
Notably, RMF Revision 2 stands
out as the first NIST publication to
holistically address both privacy
and security risk management
within a single, integrated
methodology.
These steps include preparation,
categorization, security controls,
authorizing systems, and
monitoring. Implementing these
steps ensures a comprehensive
approach to information security
and risk mitigation, aligning with
regulatory requirements and the
commitment to safeguard data
confidentiality, integrity, and
availability. NIST's RMF brings
standardization and improved
reciprocity across government
controls and language, enabling
risk-focused solutions tailored to
diverse components and systems.
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The Risk Management Framework (RMF)
is primarily linked with National Institute
of Standards and Technology (NIST) SP
800-37 guide, "Applying the Risk Management Framework to
Federal Information Systems: A Security Life Cycle Approach.” This
has be integrated into Federal Information Security Management Act
(FISMA) compliance since 2004. FISMA was signed into law in 2002,
creating a requirement for federal agencies to develop, document, and
implement an information security and protection program. FISMA is
part of the larger E-Government Act of 2002 introduced to improve
the management of electronic government services and processes.
Most recently, RMF has been incorporated into Department of
Defense (DoD) instructions, prompting numerous organizations to
formulate new compliance guidelines related to RMF.
RMF outlines a cyclical process utilized for the initial securing of
systems through the attainment of Authorization to Operate (ATO)
and the continuous integration of risk management, commonly
referred to as continuous monitoring. The second revision of RMF
marked a significant milestone as it was the first NIST publication to
encompass an integrated methodology for managing both privacy and
security risks.
Get Ready — The Prepare step is a recent addition to the Risk
Management Framework introduced in Revision 2. This step draws
guidance from various sources, including NIST publications and
requirements outlined in the Office of Management and Budget
(OMB) policy. In some cases, organizations may have already
implemented certain tasks from this step as part of their existing risk
management programs.
The primary goals of the Prepare step are to reduce complexity during
RMF implementation, align with IT modernization objectives,
optimize the allocation of security and privacy resources, prioritize
security activities based on critical assets and systems, and enhance
privacy safeguards for individuals.
Categorizing information systems is an administrative process that
involves gaining a comprehensive understanding of an organization.
Once established, these boundaries serve as the basis for identifying all
information types associated with the system. Various factors, such as
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the organization's mission, roles and of reporting in conjunction with the Plan of Action & Milestones
responsibilities, the system's operating (POA&M) to track and manage any failed controls, ensuring
environment, intended use, and remediation efforts are promptly addressed.
connections to other systems, can The final step in the RMF process involves continuous monitoring of
influence the final determination of security controls. This ongoing monitoring allows organizations to
the security impact level for the maintain the security authorization of an information system in an
information system. ever-evolving operating environment. Given the dynamic nature of
Security controls are essential threats, vulnerabilities, technologies, and mission/business processes,
safeguards or countermeasures continuous monitoring is crucial for staying ahead of potential security
implemented within an organizational incidents. While automated support tools are not mandatory, they can
information system to protect its enhance risk management by enabling near real-time monitoring and
confidentiality, integrity, and providing standardized reporting for Authorization to Operate (ATO)
availability, as well as that of the status. Automated tools help identify configuration drift and other
information it handles. The assurance security concerns associated with unexpected changes in core
factor plays a crucial role in instilling components and their configurations.
confidence that these security controls Incorporating these steps into an organization's risk management
are effective in practice. Organizations practices ensures a comprehensive approach to information security
must select and tailor security controls and risk mitigation. This framework not only helps protect sensitive
to align with their specific security data but also supports the organization's compliance with regulatory
requirements and documentation. requirements and its commitment to safeguarding the confidentiality,
This step involves describing how each integrity, and availability of information systems and data. It allows a
control is employed within the focus on risk to address the diversity of components, systems and
information system and its operational custom environments as opposed to using a one-size-fits-all solution.
environment.
After all is said-and-done, assessing
security controls is a critical phase
that involves using appropriate
assessment procedures to determine
the extent to which controls are
correctly implemented, functioning as
intended, and producing the desired
outcomes in terms of meeting security
requirements. This step is
instrumental in identifying any
potential vulnerabilities or weaknesses
in the security posture of the system.
The authorization of information
system operation hinges on a
comprehensive assessment of the risks
posed to organizational operations,
individuals, assets, other
organizations, and the nation.
Additionally, this step entails the use

Learn More
For reference, see NIST Special Publications 800-53A, 800-53, 800-137; NISTIR 8011, NISTIR 8212 . Contact us to
find out how Bluedog's consulting services can help improve security and process controls to drive the success of your
organization — visit www.Bluedog.net
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