FedRAMP vs. CMMC: What’s the Difference for DoD Contractors?


With the growing importance of cloud-based services and cybersecurity in defense contracts, many small-to-medium businesses (SMBs) working with the Department of Defense (DoD) are left wondering: What’s the difference between FedRAMP and CMMC? As the DoD continues to tighten its cybersecurity requirements, understanding how these two certification programs differ is crucial for defense contractors looking to meet CMMC compliance and CMMC certification standards.

What is FedRAMP?

FedRAMP, or the Federal Risk and Authorization Management Program, is a government-wide program overseen by the General Services Administration (GSA). It authorizes cloud services for use by federal agencies and ensures that cloud service providers (CSPs) meet stringent cybersecurity standards to protect sensitive federal data. FedRAMP compliance is based on a tiered system with impact levels (Low, Moderate, and High), which reflect the risk to federal missions if data is compromised.

FedRAMP’s goal is to secure cloud environments where Federal Contract Information (FCI) and Controlled Unclassified Information (CUI) are handled. For DoD contractors, the Department of Defense requires CSPs to meet at least a Moderate Impact FedRAMP Authorization to handle CUI under Defense Federal Acquisition Regulation Supplement (DFARS) 252.204-7012.

What is CMMC?

The Cybersecurity Maturity Model Certification (CMMC), on the other hand, was created by the DoD to ensure cybersecurity practices within the Defense Industrial Base (DIB). CMMC requirements extend beyond cloud services to encompass all of a contractor’s systems, networks, and processes that handle FCI and CUI. Unlike FedRAMP, which is limited to cloud environments, CMMC covers the entire IT infrastructure used by defense contractors.

CMMC is structured in three levels:

  1. Level 1: Basic cybersecurity practices for contractors handling FCI.
  2. Level 2: Advanced practices for those handling CUI.
  3. Level 3: Comprehensive practices for contractors dealing with CUI related to critical DoD missions.

While FedRAMP is focused on cloud providers, CMMC certification applies to all defense contractors.

FedRAMP and CMMC: Key Differences

The major distinction between the two is scope. FedRAMP assesses only the CSPs’ infrastructure, while CMMC assesses the entirety of a contractor’s IT environment. Another key difference is how certifications are issued. FedRAMP authorizations come through federal agency sponsorship or the Joint Authorization Board (JAB), whereas CMMC certification can be issued by third-party assessment organizations (C3PAOs) for Levels 1 and 2, and directly by the DoD for Level 3.

The Overlap

Despite their differences, FedRAMP and CMMC are interconnected. DoD contractors handling CUI must ensure that any cloud service they use has a FedRAMP Moderate Authorization or proves “FedRAMP equivalency.” This ensures that the CSP provides adequate security for CUI in accordance with DFARS and CMMC requirements.Conclusion

Conclusion

In summary, while both FedRAMP and CMMC are designed to enhance cybersecurity, they serve different purposes. FedRAMP focuses on cloud service providers, while CMMC applies to all defense contractors. Understanding these differences is critical for any DoD contractor navigating the complex landscape of cybersecurity compliance.

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