Mastering the Risk Management Framework (RMF): Your Ultimate Guide to DoD Compliance

Mastering the Risk Management Framework (RMF)

The Defense Industrial Base (DIB) supply chain is vital to our nation’s security and prosperity. It includes a vast array of entities, from government agencies to IT contractors providing software, applications, and cloud services. Given the critical nature of these services, the regulations governing these companies and their products are stringent. This is where the Risk Management Framework (RMF) comes into play. In this guide, we’ll explore the RMF, its actionable steps, and the importance of risk management for Department of Defense (DoD) contractors. We’ll also discuss why it’s crucial to work with experts in managing your risk.

What is RMF?

The NIST Risk Management Framework is a process that integrates essential security, risk management, and privacy controls into your IT systems. Developed by the Department of Defense and maintained by the National Institute of Standards and Technology (NIST), RMF is a foundational set of regulations that emphasizes risk management and assessment as a necessary practice for DoD agencies and contractors in the DoD supply chain.

NIST Special Publication 800-37 defines the specifics of RMF, outlining a 7-step process for organizations maintaining critical information systems as part of their work with the DoD. The 7 steps of the RMF process are:

Prepare: Conduct essential activities to help your organization manage security, privacy, and risk.
Categorize: Identify and label potential organizational risks based on their potential impact on your operations and stakeholders, including the loss of data confidentiality and system availability.
Select: Choose, configure, and document security and privacy controls based on insights and determinations from the previous step.
Implement: Put the selected controls and associated plans into action.
Assess: Determine the correctness, operation, and effectiveness of the implemented security controls.
Authorize: Make and document assessments of the potential security and privacy risks associated with the implemented controls, and determine if those risks are acceptable based on compliance and security needs.
Monitor: Continuously monitor implemented controls for changes in effectiveness or vulnerability.

These steps operationalize the general concept of risk management by expecting that agencies and contractors under the DoD umbrella undergo standardized self-assessment and security management procedures regularly. RMF audits are typically conducted annually, with the expectation that organizations are continuously monitoring their systems and assessing and justifying their risk.

Why Is Risk Assessment So Important in Modern Cybersecurity?

It’s important to note that RMF is a risk management framework. While it covers controls and practices related to cybersecurity, its true purpose is to ensure that businesses are managing risk alongside implementing cybersecurity technologies.

The difference between cybersecurity and risk management is crucial. Implementing the latest cybersecurity controls or checking off boxes on a compliance list does not necessarily mean that you are managing risk. Risk refers to the potential threats, vulnerabilities, and exposures that the information in your system faces based on different controls, practices, and configurations. Risk can encompass various types of threats, from concrete threats to confidential data to the loss of reputation or standing for the government or your company. Importantly, risk can never be eliminated. Instead, risk management helps organizations determine and articulate the balance between a cybersecurity posture and potential security threats.

RMF, therefore, demands that any contractor working with the DoD supply chain have a standing process for understanding, documenting, and justifying the potential for risk based on decisions made regarding cybersecurity.

There are several practices and components that you can implement to ensure that you are operating within the steps outlined above:

Risk Identification: The basis for assessment, identification is the process of identifying threats, vulnerabilities, and security gaps and determining the likelihood of their impacting your organization.
Risk Governance: Formal, documented, and organization-wide documentation of your organization’s risk governance plans, including acceptable risk, regulatory compliance, and remediation strategies.
Risk Measurement: How you rank and categorize potential threats based on likelihood, severity, industry-specific issues, and other factors.
Documentation and Reporting: RMF calls for continuous monitoring, and as such, your risk management will include continuous documentation, audits, and reporting of how you are assessing risk. This is especially true in cases where you upgrade systems or as new threats emerge.
Mitigation: This includes the remediation of vulnerabilities and minimization of potential risk through new security controls and practices.

How Do You Implement RMF for Your Business?

The best way to prepare for and adopt the RMF framework is to follow the seven steps listed above. More specifically, this includes practices like:

Hiring and maintaining a Risk Management Officer: Even if your risk assessment strategy is a single person, having someone on board who understands the demands of RMF and risk management more broadly is invaluable. This person can serve as a dedicated point-person for that work if you work with outside security or risk management agencies.
Formalize your company’s posture: Balance business growth and security risk. In some cases, security controls are non-negotiable, and you must implement them. More often than not, however, you will have to make decisions about what controls and systems to adopt, what not to implement, and how the difference can help or hinder both the growth of your business and your vulnerability.
Take the “Prepare” step seriously: The Prepare step was added during Rev. 1 to help streamline the process and support agencies and contractors who wanted to successfully meet RMF requirements. It is a step that will ask you to adopt some of the risk management components outlined in the previous section before attempting RMF compliance.
Work with skilled auditors and experts: Adhering to RMF and implementing good risk management practices does not have to fall on your shoulders alone. Working with security and risk experts can help you with the preparation of your systems and the continued monitoring of your risk posture.

Conclusion

Risk management is a practice that any IT company working with sensitive data should undertake. With RMF and DoD contracting, however, risk management is a necessary part of your operations. By understanding and implementing the RMF, you can ensure that your organization is well-prepared to manage and mitigate risks effectively.

For more information, you can refer to the NIST Risk Management Framework.