Risk Management Framework (RMF)

SteelToad can help your organization implement a Risk Management Framework, providing  a unified, repeatable method for understanding and controlling organizational risk. By implementing the steps as a continuous lifecycle rather than a one-time certification effort, SteelToad will help organizations maintain a defensible security posture and ensure their information systems remain aligned with federal standards and modern threat conditions.

RMF Overview

The NIST Risk Management Framework (RMF) was developed to create a universal framework that federal agencies must use to protect information systems. It is a comprehensive, flexible, repeatable, and measurable seven-step process. The seven steps - prepare, categorize, select, implement, assess, authorize, and monitor - are designed for any organization to use to manage information security and privacy risk. NIST has built a catalog of security controls (SP 800-53) to be used in developing security and privacy plans for an organization. Although the risk management framework follows a standard structure, it is applied differently across organizations based on their individual needs.

The NIST RMF has replaced previous risk management certification processes used by federal agencies and is currently used across all federal information systems. Although required for federal agencies, it is increasingly adopted by private organizations because of its effectiveness in minimizing risk.

Why RMF is Necessary for Organizations

The Risk Management Framework, published by the National Institute of Standards and Technology (NIST), is a relatively new set of standards and guidelines, but it has proven to be one of the most effective risk management approaches available. Federal agencies must implement RMF and obtain authorization to operate, but private organizations are not required to follow RMF. Nonetheless, RMF offers a strong structural template for efficient risk management.

Managing organizational risk is essential to protecting information and operational processes. RMF can be applied to both new and existing systems and can support organizations of any size or category. It simplifies what would otherwise be a complex process by providing structure: what to do, in what order, and how to maintain security over time. It integrates information security and privacy into a unified lifecycle where risk is identified, managed, and continuously monitored. When followed properly, RMF establishes a systematic approach to managing risk in the most effective way possible.

NIST also uses a public review process that includes feedback from both private and public sector organizations to ensure that all FISMA security standards and guidelines are accurate and implementable. Risk management is an essential part of operating in the modern cyber environment, and the NIST RMF makes it both accessible and actionable.

Although RMF is required for federal agencies and for organizations handling large or sensitive information systems, many private organizations still do not use RMF. Risk management may appear overwhelming or time-consuming to implement, but in the long term a strong risk-based foundation becomes critically important. RMF can strengthen a private organization by improving investor confidence, building resilience against threats, enabling better decision-making, and allowing leadership to focus on organizational objectives with risk properly addressed.

One of the most important ways it can help an organization in the private sector is by improving its reputation.  It actively allows an organization to work towards preparing for and building overall resilience against threats, for making better risk-based decisions, and for focusing more on the goals of the organization with risk covered – all factors that will help a private organization in the market.

The Development of RMF by NIST

RMF is the framework for complying with a broad set of guidelines and standards developed by NIST to unify information security and privacy management into a single risk management system. Based on the Federal Information Security Modernization Act (FISMA), RMF was created to ensure that federal agencies use a common framework to manage risk effectively. FISMA established the requirements for a risk management program, and RMF provides the structured approach for implementing that program and achieving authorization.

According to NIST, RMF was developed to create reciprocity and consistency in risk management across federal agencies, while still allowing flexibility for agency-specific needs. A universal framework strengthens overall federal information security, reducing the likelihood that vulnerabilities in one agency could affect others.

Before RMF, NIST operated under a process known as Certification and Accreditation (C&A). For example, the Department of Defense used the DoD Information Assurance Certification and Accreditation Process (DIACAP). These processes required organizations to apply security controls and standards to information systems. RMF differs in that it is aligned with FISMA requirements and uses the NIST Special Publication 800-53 security control catalog. In short, RMF consolidates and simplifies earlier forms of risk management.

RMF was first developed by the Department of Defense and then adopted by the rest of the federal government after publication as NIST SP 800-37 Revision 1 in February 2010. This version transitioned federal agencies away from the C&A process, but it lacked a dedicated privacy structure and included only six steps. In December 2018, NIST released Revision 2, adding the Prepare step and expanded privacy-related common controls. RMF now serves as the primary framework for protecting information systems within the United States government.

Incorporating RMF - Is There Only One Way?

The essence of RMF is that it is a risk-based process. Different organizations will plan differently, select and implement different sets of controls, and may repeat steps as needed. RMF is a framework rather than a rigid checklist, so organizations must adapt it to their specific information security needs. The NIST SP 800-53 catalog contains more than 1,000 controls; no organization will use them all. Each organization selects controls based on its system categorization and risk tolerance.

Selection, implementation, and continuous monitoring will vary significantly across organizations. Continuous monitoring strategies differ based on system architecture, risk posture, and operational needs. RMF provides the structure, but the organization must execute the process internally in a way that fits its environment.

The RMF Design and Implementation Process

Prepare

• Essential activities that prepare the organization to manage security and privacy risks

• Description.

  • Establish organization-wide risk management roles

  • Define risk tolerance

  • Conduct organization-wide risk assessments

  • Identify common controls

  • Develop a strategy for continuous monitoring

Categorize

• Determine/categorize the impact of risk to a system’s process/task with respect to confidentiality, integrity, and information involved with the system. Advise risk management based on this impact.

•  Details

  • Categorize information systems based on risk impact

  • Determine risk impact relative to confidentiality, integrity, and availability

  • Document system characteristics and seek approval of categorization decisions

Select

• Select the set of NIST SP 800-53 controls to protect the system based on risk assessments.

• Details

  • Select NIST SP 800-53 controls based on risk assessments

  • Designate controls as system-specific, common, or hybrid

  • Allocate controls to system components

  • Develop a continuous monitoring strategy

  • Approve security and privacy plans

Implement

• Implement the selected NIST SP 800-53 controls and document how they are deployed

• Details.

  • Implement selected controls and document deployment details

  • Update security and privacy plans to reflect the implemented controls

Assess

• Assess to determine if the NIST SP 800-53 controls are in place, operating as intended, and producing the desired results.

• Details

  • Determine whether controls are implemented correctly and operating as intended

  • Develop an assessment plan and obtain approval

  • Produce an assessment report

  • Complete required remediation actions

  • Update security and privacy plans

  • Develop a plan of action and milestones (POA&M)

Authorize

• Senior officials make risk-based decisions to authorize the system to operate.

• Details

  • A senior official issues a risk-based decision to authorize operation

  • Review the authorization package, including plans, assessment results, and POA&M

  • Determine and document risk acceptance

  • Approve or deny authorization

Monitor

• Continuously monitor 800-53 control implementation and risks to the system.

• Details

  • Continuously assess control implementation and risk

  • Analyze monitoring results

  • Maintain reporting mechanisms for security and privacy concerns

  • Conduct ongoing authorization activities as required

Implementing RMF in an Organization

Implementing RMF may appear difficult at first, but the process varies across organizations and is iterative. If an organization does not reach compliance in one step, it can adjust and try again. Because RMF is a lifecycle rather than a one-time task, steps may be repeated as needed.

RMF is a risk-based process, meaning that different organizations will have to use different controls, thus changing the framework from organization to organization. This makes it harder to implement but effective upon compliance, as an organization can be certain that the controls that were selected and approved are the right choice. Implementing RMF will also vary based on how an organization performs on certain steps along the way, because steps are often repeated if they need to be adjusted. RMF is a lifecycle, not just paperwork that can be completed once and forgotten about.

These are the steps to implement and reach compliance:

• First, prepare by performing risk analyses and informing all organizational levels of the risks relevant to their systems and roles.

• Next, categorize information systems according to the type of information processed and the associated level of risk, allowing the organization to begin identifying appropriate baselines and controls that are more important than others.

• Once categories have been selected, then the relevant controls from the Special Publication 800-53 must be selected.  Select the appropriate controls from NIST SP 800-53 based on system categorization and identified risks.

• After controls are selected, they must then be implemented. For example, a common control selected and implemented may be SP 800-53 PM-9, titled “Security and Privacy Controls for Information Systems and Organizations”. It requires that the organization develops comprehensive strategies for managing security risks to both operations and assets, and also privacy risks to individuals resulting from processing of personal information. This step in the process of becoming compliant within RMF is the most important, because without it, the risk management process in the organization wouldn’t change at all.

• After the controls are implemented, they are assessed. Organizations essentially need to ensure that the controls are working as intended. Assess the controls to ensure they operate as intended. If controls are ineffective, return to implementation or selection as needed.

• If all goes well with the fourth and fifth steps of the process, then the next step in the process is to finally authorize the system to operate, meaning that the controls have been successfully chosen and implemented properly. The assessment team/operator has determined that the organization is compliant, and then a senior official determines whether the system meets the risk requirements for operation.

• Once the organization is operating normally with the Risk Management Framework implemented successfully, all that’s left to do is continuously monitor the system and the controls. The strategies previously developed need to be adhered to indefinitely, and the system should be regularly assessed to ensure it is keeping up with the standards of RMF.

Summary

The RMF ultimately provides a unified, repeatable method for understanding and controlling organizational risk. By implementing the steps as a continuous lifecycle rather than a one-time certification effort, organizations maintain a defensible security posture and ensure their information systems remain aligned with federal standards and modern threat conditions.