Guide: What is NIST RMF?

Maintaining information security and privacy is a primary role for IT security professionals, compliance officers and risk managers in government agencies and non-government organizations. Unfortunately, there’s no one cure-all solution for cybersecurity concerns you can leverage to keep an organization’s IT system 100% immune to threats. That’s why implementing a risk management framework to help you sequentially identify and mitigate different data risks and create an incident response plan is so important.

And this is where the NIST Risk Management Framework (RMF) comes in. This framework has become the go-to solution for organizations worldwide as they seek effective measures of preventing data breaches, which exposed 422 million records globally in the third quarter or 2024 alone. Before we explain this framework and its overwhelming significance to IT systems, let’s first define what is NIST RMF and its history.

What is the NIST Risk Management Framework?

The NIST RMF was established under the Federal Information Security Modernization Act of 2014 (FISMA), which established a joint task force that included the National Institute of Standards and Technology (NIST). NIST was assigned the responsibility of creating a risk management and incident guideline framework to govern federal information processing standards and those agencies handling federal data and federal information systems.

NIST developed a seven-step Risk Management Framework, known as the NIST RMF. This establishes a comprehensive standard containing over 1,000 security controls that organizations can leverage to assess and manage cybersecurity risks to maintain data security and privacy.

The NIST RMF is primarily for federal agencies, entities/vendors handling government data and all government contractors. It helps these parties ensure their information systems comply with Federal Information Security Management Act (FISMA) requirements by guiding them to integrate cybersecurity risk management processes during the initial stages of a system’s lifecycle.

This framework has two main standards — NIST 800-53 Risk Management Framework and NIST Risk Management Framework 800-37. NIST 800-53 focuses mainly on security and privacy controls and implementation standards, while NIST 800-37 concentrates on providing implementation guidelines for developing a risk management program.

Consequences for Non-Compliance with FISMA Regulations

For federal agencies and contractors bound by FISMA requirements, non-compliance can result in the following:

• Contract termination: Non-compliance can cause the government to cancel ongoing contracts or debar organizations from applying to similar contracts in the future.
• Loss of federal funding: Organizations that receive federal funds may no longer enjoy grants to pursue projects that involve handling sensitive information.
• Excessive audit and oversight: The government may impose harsher regulatory oversights on non-compliant organizations and impede their turnaround time on project deliverables.
• Legal liability: If a non-compliant organization experiences a data breach, it may face legal implications from the affected entities.
• Steep remediation costs: Fixing an organization’s system after a data breach will cost it more than implementing NIST RMF guidelines from the start.
• Reputational damage: If data breaches strike a non-compliant agency or contractor, it’ll be viewed as unprofessional, and its customers and other third-party partners won’t trust it with their data.

Private-Sector Adoption

The success of the NIST risk assessment framework has resulted in businesses voluntarily implementing NIST RMF to enhance their information security and privacy protocols. Today, even private sector organizations that don’t process federal data and aren’t legally bound by FISMA laws apply NIST RMF guidelines to secure their business and customer data.

Having discussed what is NIST RMF and its history, let’s outline the main components and step-by-step process of implementing this framework.

Five Key Components of the NIST RMF

One main reason why NIST RMF is effective and adaptable to organizations of all types is because it’s well-segmented into components that build on each other. This makes implementation a well-structured and continuous process that organizations follow to execute a comprehensive and fail-proof framework. Let’s discuss each component.

Risk Identification

This initial process maps out the functions that are the lifeblood of an organization and pinpoints cybersecurity risks that can sabotage those critical functions. These risks could be legal, strategic, security or any other area of the business.

Establishing current risks to existing digital assets and information system processes shapes an organization’s perspective toward risk management. Risk identification and threat-hunting should be continuous because risks evolve with time as organizations grow.

Risk Measurement and Assessment

After outlining core risks to an organization’s processes you should measure and assess the risk magnitude of each. This also includes establishing which risks are negligible. This component is important because it lays the foundation for RMF execution and helps organizations identify which cybersecurity efforts and strategic risks they should prioritize according to the risk magnitude.

Risk Mitigation

Risk managers review the assessment results and priority risks that need action and develop risk prevention or reduction strategies. Typically, risk mitigation takes four routes:

• Risk avoidance: You avoid the risk by skipping the actions that trigger it. For instance, you can choose to skip a new system launch or update if there’s a malware risk.
• Risk transfer: You shift the risk to a third party through a formal, legally binding agreement. For instance, before launching a new system, engage a software compliance company to perform an audit to certify the system. Such engagements transfer some risks to the audit company.
• Risk acceptance: You acknowledge risk presence and concede that the damage/loss of the risk isn’t big enough to justify spending money and resources to prevent it.
• Risk control: You come up with mitigation strategies and recovery plans to control the risk and its associated losses. For instance, if there’s a malware risk because of a system update, you should invest in an effective antivirus software that scans and fixes potential malware before it spreads to your system.

Risk Reporting and Monitoring

The NIST RMF requires you to report risk profiles and control strategies to relevant stakeholders who would be affected in case of a breach. You must also continually monitor risks to identify and report new outliers that need further mitigation actions.

Risk Governance

This component ascertains that risk management strategies are well-implemented and integrated into an organization’s information system throughout its lifecycle. It also focuses on enhancing systems by implementing the improvements learned from successful mitigation strategies in the past.

You should implement these five components in tandem to get optimal results. Remember that the implementation of these NIST RMF components is not a set-it-and-forget-it strategy you conduct once. It’s a continuous process you repeat throughout your system’s lifecycle, from development to disposal. Let’s explore the seven steps of RMF you should follow to execute a successful implementation.

Seven-Step Process of the NIST RMF

Most organizations follow these seven RMF steps sequentially to achieve the optimal results that this framework is designed to deliver. Let’s explore each step and the key tasks that happen in each:

1. Prepare

The main goal of this step is to prepare your organization’s system for the implementation of security and privacy risk strategies. All activities of this step are designed to lay a strong foundation for the execution and continuous monitoring of your designated risk-management strategies. The core tasks you perform are:

• Evaluating your organization’s risk magnitude and tolerance
• Crafting an official risk management strategy that includes risk control and continuous monitoring techniques
• Defining critical risk management roles and delegating responsibility to specific teams

2. Categorize

The primary aim here is to segment an organization’s system according to the impact level the segment would experience if the information processed, stored and transmitted by the system got breached. You conduct this impact analysis by following the CIA triad that summarizes the three pillars of information security—confidentiality, integrity and availability (CIA).

The core tasks include:

• Cataloguing the characteristics of the system
• Classifying the system based on security impact level (i.e., low, moderate or high)
• Authorizing officials assess and green-lighting your categorizations

3. Select

The goal here is to select ideal risk controls and customize them to individual categorizations. The key tasks involved in this step include:

• Referencing NIST SP 800-53 to identify and choose baseline controls
• Creating an in-house control selection process if you don’t use NIST SP 800-53
• Customizing chosen controls according to specific factors, such as risk tolerance, system threats and security and privacy threat levels
• Categorizing risk controls as common, hybrid or system-specific
• Harmonizing security and privacy plans with their matching system elements
• Creating a continuous system-monitoring strategy

4. Implement

Here’s where the rubber meets the road. You apply the security and privacy plans you selected according to their designated process. Besides executing your risk controls, the other primary task is documenting the implementation process, updating security controls and highlighting the input levels and expected outcomes of the process.

5. Assess

You monitor the performance of the security controls you’ve rolled out to gauge if you implemented them correctly and whether the results are up to par. The main tasks in this step are:

• Allocating the assessment process to a dedicated team with the expertise and capacity to conduct a bias-free appraisal
• Developing a comprehensive assessment plan
• Documenting assessment outcomes, observations, potential improvement areas and lessons learned
• Preparing a plan of action and milestones (POA&M) to correct any deficiencies observed

6. Authorize

Seek authorization to operate (ATO) once you’ve established that your risk mitigation plan is acceptable to all stakeholders. The core tasks in this step include:

• Preparing the appropriate documents needed for ATO approval (they include system security and privacy plan, POA&M, executive summary and assessment reports)
• Completing risk determination
• Denying or approving authorization
• Informing relevant officials and stakeholders of the authorization decision

7. Monitor

The main goal is to establish a monitoring strategy to continually appraise your information system to ensure it’s operating efficiently and scan new risks that may curtail the system’s performance. Key duties in this last step include:

• Monitoring and reporting the system’s performance
• Determining that risk levels and mitigation plans remain acceptable
• Updating pertinent documentation after each security assessment

NIST RMF Implementation Best Practices

The most effective RMF application strategy should be spot-on and customized to your organization’s risk categorizations. However, selecting the ideal risk management strategies is only the first step. Implementing them correctly is just as important. Follow these best practices to get it right.

Integrate the RMF Process Early and Keep Improving

Start integration during the initial phases of the system development lifecycle and keep optimizing until you phase out the system. Early integration is cost-effective and gives you ample time to conduct assessments and course-correct where necessary.

Seek Stakeholder and Management Buy-In

This mostly applies to organizations that aren’t required to follow FISMA law. In such entities, your NIST RMF implementation plans may face resistance from teams or individuals who downplay RMF effectiveness or dismiss it as only applicable to federal agencies. Selling the need for RMF implementation to such groups cultivates goodwill and makes the implementation process much smoother.

Document Each Step To Create a Chronological Audit Trail

Recording and archiving your RMF integration steps gives you a data-filled audit trail you can reference for future implementations. It also creates a source point for error correction and redundancy checks, which makes system assessments much easier.

Invest in Staff Reskilling and Upskilling

NIST RMF implementation is a team effort, given the many dependent components and steps. Staff in different departments have designated RMF roles to play, and they require expertise to fulfill the roles effectively. Training staff expedites RMF implementation and reduces errors.

Embrace Automation

Smart RMF automation solutions ease controls selection as they automatically filter through the over 1,000 controls designed by NIST. Smart systems also test the effectiveness of these controls and identify potential system vulnerabilities even when they’re subtly embedded in your system.

NIST RMF: The Parent of Risk Management and Incident Response

The efficiency of NIST RMF makes it a trusted risk assessment and management framework utilized by companies globally. While we’ve discussed RMF’s constituents and the implementation steps in detail, you’ll need expert assistance at some point to establish and implement risk strategies the right way. You’ll need professional knowledge of data analysis and application to run a successful campaign.

Fortunately, you can count on Onspring to implement NIST RMF and other necessary standards like the NIST Cybersecurity Framework. Contact us today, and let us be your resourceful RMF automation partner.