FISMA shapes how federal agencies buy software, run security assessments, and manage the vendors that handle government data. But for all its influence, it is often explained in ways that are either too abstract to act on or too buried in regulatory language to be useful.
Here are seven things every federal IT team should have a working understanding of, whether you are evaluating a new data collection platform, preparing for an audit, or just trying to get the right answer when someone asks.
1. FedRAMP Authorization at the Right Impact Level
This is the threshold question for any cloud-based tool handling federal data. FedRAMP authorization means the vendor has completed an independent third-party security assessment against NIST 800-53 controls, not just completed a self-assessment checklist.
Verify authorization status in the FedRAMP Marketplace directly. Confirm the listed impact level matches what your data collection workflow requires. An ‘In Process’ designation does not mean authorized.
2. Data Residency Within the Authorization Boundary
FedRAMP authorization covers a defined system boundary. Data that leaves that boundary may not carry the same protections. Ask vendors to document where data is stored, whether subprocessors are used, and whether all components fall within the FedRAMP authorization boundary.
Some federal programs have additional data residency requirements under agency policy or executive order. Confirm the vendor’s documented practices against those specific requirements, not just general FedRAMP standards.
3. Encryption Standards for Data in Transit and at Rest
Federal systems must use encryption meeting the standards in NIST SP 800-175B. In practice, that means TLS 1.2 or higher for data in transit and AES-256 or equivalent for data at rest.
Ask vendors to specify their encryption algorithms and key management practices explicitly. A vendor that confirms data is encrypted without specifying the algorithm or key rotation policy is not providing what you need for documentation or audit response.
4. Detailed Audit Logging with Export Capability
The NIST 800-53 AU control family requires federal systems to generate, protect, and retain logs sufficient to reconstruct relevant events. For a data collection platform, that means logging form submission events, configuration changes, user access, and data retrieval.
Verify that logs are tamper-evident, retained for a period satisfying your agency’s log retention policy, and exportable for SIEM integration. A platform that provides a basic activity log but cannot export structured data to your security infrastructure creates a gap that is difficult to close after deployment.
5. Role-Based Access Control with Permission Audit Trails
Who can create, modify, and view forms should be controlled at a granular level and documented in a way that survives staff turnover and audit scrutiny. Look for role-based access control at the form, folder, and field level, with a permission audit trail showing when access was granted or revoked and by whom.
For agencies subject to HSPD-12, also verify whether the platform supports PIV/CAC authentication. Many general-purpose form tools do not, which creates workarounds that add operational complexity and access control gaps.
6. Configuration Change Management and Approval Workflows
A form that collects federal data is part of an information system. Changes to that form are configuration changes subject to your agency’s change management process. The platform should support configuration audit trails recording what changed, when, and by whom, and ideally should support approval workflows requiring sign-off before form changes go live.
Without this capability, answering basic change management questions during a security review becomes a manual forensics exercise.
7. Documented Incident Response and Breach Notification Timelines
Federal agencies have specific obligations to report security incidents to CISA within defined timeframes. Meeting those obligations depends on vendors notifying you quickly when incidents affect your data.
The vendor’s data processing agreement should specify a contractual notification timeline. Ask whether the vendor has had any reportable incidents in the past 24 months and how those were handled. A vendor’s incident response track record is more useful than their stated policy.
8. Section 508 Accessibility Compliance
Federal agencies are legally required to make electronic information and technology accessible under Section 508 of the Rehabilitation Act. Public-facing forms must meet WCAG 2.1 accessibility standards, including keyboard navigation, screen reader compatibility, and sufficient color contrast.
Ask vendors for a Voluntary Product Accessibility Template (VPAT). A VPAT is the standard format for accessibility documentation in federal procurement and provides a structured basis for evaluation.
FormAssembly is FedRAMP Authorized and produces Section 508-compliant forms by default. Procurement teams can request FormAssembly’s System Security Plan and VPAT to support agency ATO processes and accessibility reviews.
