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Before getting into specific A&A process and guidance, it is first helpful to review exactly what constitutes a "Federal Information System" so that you have a better understanding of when FISMA applies and when it may noto you know when FISMA or other federal security frameworks (e.g. FedRAMP, CUI) may apply. The following definitions and clarification clarifications are based on guidance provided by the Office of Management and Budget (OMB) as well as internal interpretations on the matter that have been published since 2001 when FISMA became law.

OMB initially defined an information system a Federal Information System as:  A discrete set of information resources organized for the collection, processing, maintenance, transmission, and dissemination of information, in accordance with defined procedures, whether automated or manual. (defined in OMB circular A-130, (6)(q)). OMB also later clarified that Federal Information Systems are those that are used or operated by an agency or by a contractor of an agency, or other organization on behalf of an agency (44. U.S.C. § 3544(a)(1)(A)).

Since these definitions can be somewhat vague or misinterpreted, many people often assume that a federal information system only includes those that are physically housed or operated within a federally-owned or federally-operated facility, and that any information system that is housed elsewhere (i.e., at a contractor's location, at a hosting provider's location, or by a cloud service provider) are not federal information systems. This is not necessarily the case. In fact, a better determination can be made by examining accountability and control of a system's information and who is directing whether the government directed the establishment or operation of the system. For example, if an agency of the federal government has directed or mandated (i.e., through a contractual arrangement or through other means of federal funding – sometimes to include grants) , the creation or operation of an information system, or if the government owns will have access to the system or will likely take possession of the data that is used in the system, then FISMA would apply to that systemmost likely applies. Contracting with a non-federal organization to host or operate your system does not exclude the system from FISMA regulations. If you are uncertain about whether yours is a federal information system, please contact the the NCI ISSO's office for clarification.

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