Navigating the Clouds with Confidence: An Introduction to FedRAMP Compliance
Gone are the days of bulky servers and dusty storage rooms. Cloud technology has revolutionized data management, offering agility, ease of use, scalability, convenience, and cost-effectiveness to organizations of all sizes, including the mighty US government. However, with great power comes great responsibility, especially for organizations dealing with sensitive federal information. For instance, the convenience comes with data security concerns such as data breaches. Unfortunately, these breaches may have profound national security and citizen safety issues. As a result, there are many programs, policies, laws, and regulations with which organizations and service providers trusted with sensitive data must achieve compliance. One such program is FedRAMP. The US government requires all cloud services that federal agencies, defense contractors, healthcare organizations, etc., be FedRAMP-authorized. So, what is FedRAMP? What are FedRAMP compliance requirements? How can a CSP become FedRAMP certified? What steps should you take to ensure you’re following FedRAMP standards?
This article will serve as your guide to FedRAMP compliance. It will provide answers to all questions you may have had about this program, ensuring you navigate the clouds with confidence.
Defining FedRAMP
What is FedRAMP?
FedRAMP stands for “Federal Risk and Authorization Management Program.” Housed within the General Services Administration (GSA), FedRAMP is a cybersecurity risk management program for the acquisition and use of cloud services and products that US Federal agencies use. Thus, only FedRAMP approved SaaS, IaaS, and PaaS companies and Cloud Service Providers (CSPs) can work with federal agencies. Additionally, federal agencies seeking to use these services must also demonstrate FedRAMP compliance. The Federal Risk and Authorization Management Program compliance guidelines correspond with cloud computing technical guidelines outlined in NIST SP 800-53. It standardizes security requirements for the ongoing cyber security and authorization of cloud services in accordance with OMB Circular A-130, FISMA, FedRAMP Authorization Act as part of the National Defense Authorization Act (NDAA), and FedRAMP policy.
History of FedRAMP Program
How Long Has FedRAMP Been Around?
FedRAMP has been around since 2011. This was around the time cloud technologies were emerging as an alternative to traditional tethered software solutions. Cloud technologies have more benefits compared to outdated tethered systems. To harness these benefits, the then US CIO authored the “Federal Cloud Computing Strategy,” which instituted and advocated for a Cloud First Policy. This policy aimed to accelerate the pace at which the government would adopt cloud computing for its benefits. It required agencies to look at cloud-based solutions as a first choice before making any new investments. The administration would then work in close collaboration with GSA, NIST, US CIO council, DoD, and DHS, among others, in furtherance of the Cloud First Policy. This culminated in the development of FedRAMP on December 8, 2011.
While FedRAMP uptake was slow at first, it has seen a sharp increase in adoption since 2021. There are 327 FedRAMP-authorized services today, with others in different stages of the FedRAMP authorization process.
What is the Objective of FedRAMP?
FedRAMP’s mission is to be a government-wide program promoting “the adoption of secure cloud services across the federal government by providing a standardized approach to security and risk assessment for cloud technologies and federal agencies.” To achieve this mission, FedRAMP is guided by three main goals, including:
- To grow the use of secure cloud technologies used by government agencies by standardizing security assessment, authorization, and regular monitoring of cloud computing services.
- To enhance the framework by which the government secures and authorizes cloud technologies by having a repository of authorization packages of cloud services reviewed by the Joint Authorization Board (JAB), which can be leveraged government-wide.
- To build and foster strong partnerships with FedRAMP stakeholders through the use of standard contract language, which allows them to integrate FedRAMP requirements and best practices into acquisition.
FedRAMP reduced inconsistencies, duplicative efforts, and cost inefficiencies associated with the then security authorization process. Before it was established, each federal agency had its security requirements. Thus, each cloud service vendor had to meet different security requirements for each agency. They had to prepare different authorization packages for every agency they wanted to work with. Unfortunately, this resulted in lots of duplication for agencies and providers. FedRAMP provides a common security framework, streamlining the authorization process and introducing consistency.
Today, there are standardized FedRAMP requirements and evaluations, meaning agencies and cloud service providers can reuse authorizations. Agencies review a standard set of security materials against a single common baseline. Hence, a cloud service offering only needs to be authorized once, and any federal agency can use the security package. This aligns well with FedRAMP’s guiding principle: reuse, saving both the cloud service providers’ and agencies’ time, money, and effort.
When Is FedRAMP Required?
FedRAMP compliance is mandatory for any cloud service provider (CSP) that has developed a cloud service offering (CSO) intended for use by a federal agency. This also applies if the CSO will be used by Defense Contractors or Government Agencies that store, process, or transmit CUI over the cloud under DFARS -7012 (b)(2)(ii)(D). Whenever a federal agency sends or shares sensitive data over the cloud, it must be compliant with FedRAMP standards. If an agency partners with a Cloud Service Provider, they both have to work collaboratively to be authorized. Generally, FedRAMP is required whenever cloud services are used by U.S. federal agencies to handle federal information, ensuring that these services have undergone rigorous security assessments and are continuously monitored for compliance with federal security standards. This requirement supports the secure adoption of cloud technologies within the federal government, protecting sensitive information and assets.
What are the FedRAMP Governance Bodies?
Different executive branch agencies collaboratively work to develop, manage, and operate the FedRAMP program, including:
- Joint Authorization Board (JAB): The primary decision-making and governance body for the FedRAMP program and comprises CIOs from DoD, DHS, and GSA.
- FedRAMP Program Management Office (PMO): This is an office within GSA responsible for developing the FedRAMP program and managing day-to-day operations.
- Office of Management and Budget (OMB): This body issued the FedRAMP Policy memo defining key capabilities and requirements for the program.
- Department of Homeland Security (DHS): Responsible for managing the FedRAMP continuous monitoring strategy, including threat notification coordination, reporting structure, incident response, and data feed criteria.
- CIO Council disseminates FedRAMP information to the Federal CIOs and other agencies through cross-agency events and communications.
- National Institutes of Science and Technology (NIST): This entity issues guidance and advice to FedRAMP on FISMA compliance and helps develop standards for the accreditation of 3PAOs.
What is FedRAMP Compliance?
For a CSP to be FedRAMP compliant means they have met the FedRAMP security control requirements and have received a FedRAMP Authority to Operate (ATO). However, FedRAMP authorization can follow either the JAB process or Agency process. However, JAB process entails a provisional authorization. Additionally, the Joint Authorization Board selects 12 services every year for a JAB Provisional Authority to Operate (P-ATO). But what is the difference between a CSP and a CSO (cloud service offering)? The main difference between the two is that a CSP may have many service offerings for instance Azure or AWS while a CSO is a single or subset of these offerings. Some key aspects of being FedRAMP compliance include:
- Implementing and adhering to the FedRAMP security control requirements that span the full range of NIST SP 800-53 security controls. There are three baselines - Low, Moderate, and High - with higher baselines containing more stringent controls.
- Undergoing rigorous security assessments by an accredited Third Party Assessment Organization (3PAO), which examines the CSP's security policies, system security architecture, controls implementation, and ability to continuously monitor security.
- Receiving a JAB P-ATO or an agency ATO after review of the 3PAO's security assessment. An Authority To Operate indicates formal approval to operate and provide cloud services to government agencies.
- Maintaining the FedRAMP security baseline through continuous monitoring activities reviewed by the agency or JAB that granted the ATO. This involves vulnerability scanning, periodic reassessment, and transparent reporting.
- Providing visibility into their security controls and compliance via a System Security Plan that documents how controls are implemented. CSPs must also share security assessment reports.
Being FedRAMP compliant demonstrates that a CSP offers a standardized and thoroughly assessed approach to security that federal agencies can trust for their cloud deployments. Only CSPs with FedRAMP approval may work with government agencies.
What are the Levels of FedRAMP Compliance?
When a CSP is developing its FedRAMP authorization strategy, it must first determine the service offering’s risk impact levels. This usually is the answer to how damaging will a cybersecurity breach be. Depending on the information shared or the agency, the risk to the US citizen and federal government varies greatly. These levels of risk impact are based on the data a CSO transmits or stores and are outlined in FIPS 199 as High, Moderate, and Low impact. Additionally, CSOs span across three security objectives commonly called the CIA triad, namely:
Confidentiality
Access and disclosure of information includes means of protecting proprietary information and personal privacy.
Integrity
The information stored on the service offering must be adequately safeguarded from destruction or modification.
Availability
The information should be accessible in a reliable and timely manner.
The risk levels determine the number of controls required to maintain FedRAMP compliance. So, what are the categories of FedRAMP compliance? As listed above, FIPS 199 identifies three categories of FedRAMP compliance, including:
Low Impact
This is the most appropriate level of risk impact for systems where loss of confidentiality, integrity, and availability could result in limited adverse effects on the agency’s assets, individuals, and operations. The low Impact level includes approximately 125 controls. Currently, FedRAMP has two baselines for information systems with Low Impact data: Low baseline and LI-SaaS Baseline. Generally, LI-Saas Baseline includes low-impact SaaS applications that don’t store PII beyond what is required for a general login capability. The requisite security documentation is consolidated, and the necessary number of security controls that need testing and verification are lowered relative to the standard FedRAMP Low Baseline authorization. Requirements on LI-SaaS Baseline are accessible on the FedRAMP Tailored Website.
Moderate Impact
About 80% of the CSP applications for FedRAMP authorization are for Moderate Impact Systems. This level is most appropriate for service offerings where loss of confidentiality, integrity, and availability may result in serious adverse effects on an agency’s assets, individuals, and operations. To be authorized at a Moderate baseline, you must implement about 325 controls in NIST SP 800-53. Organizations that store, process, or transmit Controlled Unclassified Information (CUI) and Covered Defense Information (CDI) are required under DFARS -7012 (b)(2)(ii)(D) to use a service offering that has met FedRAMP Moderate baseline security requirements. Given the sheer number of organizations handling such data, CSPs should ensure that their offerings have at least implemented the 326 controls.
Additionally, CMMC 2.0 compliance at Levels 2 and 3 requires that organizations use a CSO that is authorized at a FedRAMP Moderate Baseline level or its equivalent. CMMC 2.0 stands for Cybersecurity Maturity Model Certification 2.0. What is FedRAMP moderate equivalent was further clarified by a DoD CIO memo. The large number of systems that require a FedRAMP Moderate Authorized CSO could be the reason why 80% of the applications are for this level.
High Impact
Although breaches to moderate impact data have serious adverse effects, those to systems that protect high-impact data can prove catastrophic or severe. For this reason, service offerings handling this data must implement about 425 cybersecurity controls. Cloud service providers operating in critical sectors like finance, law enforcement, healthcare, and emergency services are prime candidates for seeking a FedRAMP high ATO. In these sectors, even minor disruptions to data confidentiality, integrity, or availability can lead to catastrophic consequences, making robust security paramount. High-impact data includes “government’s most sensitive, unclassified data in cloud computing environments.”Thus, CSPs must develop, maintain, and monitor their strictest and most extensive security controls. In other words, high-impact data should be stored in the most secure FedRAMP cloud environment.
How Can a CSP Move Its CSO from FedRAMP Moderate to FedRAMP High?
Compared to achieving the initial FedRAMP authorization, the process of moving impact levels is relatively simple and straightforward. Generally, there are three main steps that CSPs to move one impact level up, including:
Receive Formal Approval from Your Sponsor
To start to a higher impact level, a CSP needs to first receive permission from its sponsor. If the existing sponsoring agency is unwilling to support the move to High, identify a new agency willing to sponsor your CSP at the desired impact level. This demonstrates continued government interest and facilitates the authorization process.
Complete the Significant Change Request (SCR) Form
Download and complete the SCR form available on the FedRAMP website. This document details the additional security controls required for High impact level compliance. It offers a clear checklist of new controls and changes to existing Moderate controls, ensuring a comprehensive understanding of the necessary enhancements.
Complete a Significant Change Assessment
The CSP should contract a 3PAO to undertake a Significant Change Assessment. If applicable, CSPs should conduct a Significant Change Assessment during their annual assessment for continued authorization. This strategic approach streamlines the process and reduces potential cost and time burdens.
By diligently following these steps and demonstrating a commitment to enhanced security, CSPs can successfully transition to FedRAMP High impact level, positioning themselves for lucrative opportunities within the federal government market.
What is the Difference Between FedRAMP Ready and FedRAMP Authorized?
What is the difference between a “FedRAMP Authorized” and a “FedRAMP Ready” cloud service offering? FedRAMP Authorized service offerings are authorized at an impact level at least once and can start working under FedRAMP compliance measures. A FedRAMP-authorized CSO has received the seal of Approval. In contrast, a FedRAMP ready cloud service offering may have implemented all the security measures to be FedRAMP compliant but hasn’t received the seal of Approval yet.
FedRAMP Ready
These CSOs have undergone a readiness assessment by a 3PAO and have submitted a Readiness Assessment Report (RAR) to the Joint Authorization Board ( JAB) and it has been approved. A CSO must receive a FedRAMP Ready designation before embarking on the Provisional ATO process through JAB.
FedRAMP Authorized
A FedRAMP authorized CSO has already completed the authorization process, either through JAB process or Agency process. Such a service offering has been FedRAMP ready, submitted a RAR to JAB, which has been approved, and received a final seal of Approval to begin working with federal agencies.
What Are FedRAMP Compliance Requirements?
For a CSP to be found FedRAMP compliant, they must meet some FedRAMP requirements. After implementing the required security controls, CSP must conduct an assessment, receive authorization, and maintain continuous monitoring of the implemented cybersecurity measures. So, how can you achieve FedRAMP authorization? What are the FedRAMP compliance requirements? Below are some steps you can follow to become compliant.
Compiling Initial FedRAMP Documents
The FedRAMP site has some documents, forms, and templates that any organization looking to achieve compliance can leverage. Organizations are encouraged to use these already available resources to start their FedRAMP authorization process. These resources can be helpful in assessment preparation, other steps towards authorization, and monitoring. After completing a FIPS 199 assessment, an organization can have a better sense of the relevant documentation. However, it is recommended that such an organization gathers preparatory templates and documents on the FedRAMP site and familiarizes itself with the most likely authorization path. This will mostly be on the basis of data it will be working with.
FIPS 199 Assessment
NIST developed the Federal Information Processing Standard 199 (FIPS 199) to categorize data transmitted and stored by cloud computing services. So, what are the security categorization levels of FIPS 199? There are three potential impact levels established by FIPS 199: low, moderate, and high impact. These levels of impact are relevant to securing Federal information and information systems for each of the above-stated security objectives. The impact level classification determines the security objective and impact level the CSP must implement. Hence, a FIPS 199 assessment helps a CSP determine their application’s impact level. Although most organizations that partner with federal agencies fall under the moderate impact category, you should conduct a FIPS 199 assessment to know where your application’s level of impact.
Readiness Assessment
Upon completing documentation, the organization seeking FedRAMP certification should hire an assessor to test its information systems to attest that implemented controls are effective. Organizations looking to receive a P-ATO from the JAB normally use a 3PAO for this purpose. Within the compliance world, a 3PAO stands for a Third-Party Assessment Organization. A 3PAO is an organization accredited by the American Association for Laboratory Accreditation (A2LA) to offer independent assessment. On the other hand, organizations seeking an Agency ATO can use a non-accredited independent assessor (IA). However, it is highly recommended that organizations pursuing Agency ATO use a 3PAO to test their systems.
When the 3PAO or IA completes the testing, they issue a security assessment report (SAR). This report contains information on threats, vulnerabilities, and risks discovered in the testing process. The assessors can also issue guidance on ways of mitigating security weaknesses found. However, the assessor accords the organization a chance to review the SAR. This is aimed at ensuring the 3PAO or IA has relevant and up-to-date information when creating the report. After review, the assessor shares the SAR with the JAB or the agency security team. Noting the security gaps in advance can be useful in streamlining the next steps in the FedRAMP compliance process. The other benefit of conducting a FedRAMP readiness assessment is that it helps a CSP establish a clear baseline of its risk and security posture.
Create and Execute a Plan of Action and Milestones (POA&M)
Many FedRAMP requirements come from NIST SP 800-53, and POA&M is among them. The organization seeking FedRAMP certification has to develop a POA&M that addresses or remediates the gaps identified in the security assessment report (SAR). Even if the CSP cannot immediately resolve the identified gaps, they must document them in an action plan and indicate timelines for revisiting every particular item. This demonstrates the cloud service provider’s dedication to mitigating risks and maintaining FedRAMP compliance. Ideally, the remediation should happen systemically. Additionally, the Agency or organization seeking FedRAMP approval has to document all activities completed during gap remediation. They should submit the Plan of Action and Milestones (POA&M) to the JAB or security team at the Agency they want to work with.
Follow JAB or Agency Authorization Process
As mentioned above, there are two pathways to obtaining a FedRAMP Authority to Operate: the Agency process and the JAB process. But how does the FedRAMP JAB process differ from the Agency process?
FedRAMP JAB Authorization Process
In a JAB process, the CSP is first evaluated as part of the FedRAMP Connect. But what is FedRAMP Connect? FedRAMP Connect is the process through which CSPs are assessed based on the JAB Prioritization Criteria and prioritized to work with the JAB. Any CSP interested in working with JAB should review the JAB Prioritization Criteria and Guidance document, Complete the FedRAMP Business Case, and forward it to info@fedramp.gov. This process results in a selection of 12 CSOs annually.
1. JAB Prioritization
The JAB prioritization criteria provide characteristics and benchmarks for the evaluation and selection of CSPs eligible to pursue a JAB P-ATO. What are the criteria for JAB prioritization? The prioritization criteria has three categories: FedRAMP ready, Demand, and preferred Characteristics.
Demand for CSP’s Product
The primary criterion for JAB consideration is the demonstrable existing demand for the CSO within the federal ecosystem. A CSP has to verify current or potential demand from the equivalent of six customers. JAB assesses demand through several categories:
A cloud service provider can provide evidence their CSO will be adopted within 12 months of ATO, including:
- Federal customers using your on-premise or commercial version that are interested in moving to your CSO or government version
- Government RFIs, RFPs, RFQs, and pending awards
- Business capture plan provided by CSP grounded by agency needs and spend
- Use by State, Local, Tribal, or Territorial Governments
- Use by FFRDCs and Labs
Do the tribal, local, or Federal Agencies already use the CSO? Does the cloud service offering has a standing agency authorization with a Federal agency? If so, JAB can infer there’s an existing demand for the CSO in governmental use.
Does a FedRAMP authorized cloud service deployed by federal agencies use the CSO? JAB may infer there’s at least potential for demand beyond its integration with other products.
If the CSO meets OMB-defined organizational priorities, JAB will infer that some demand exists. This includes CSOs with features and functionalities addressing federal security mandates or agency deficiencies.
Federal agencies may demand CSOs with specific capabilities aligned with the expressed needs of individual agencies. However, CSPs should submit a “Proof of Demand” worksheet demonstrating how their offering meets the JAB criteria, including:
- A list of relevant customers across federal, state, local, and tribal levels.
- Business use cases outlining specific needs addressed by the solution.
- Letters of interest from agencies, indirect customers, or evidence of related RFPs.
Preferred Characteristics
While this is not mandatory for prioritization, JAB prefers the characteristics for Government-wide solutions. They are used in evaluations where FedRAMP ready and demand criteria does not provide a clear prioritization decision. A CSO must meet one of the following factors:
- Provide high security, resulting in lower risk for Federal information
- Designed for the federal government
- Meet Government needs
- Have a demonstrable track record of secure implementations and managed risks
These Criteria are outlined in prefered characteristics section of the JAB Prioritization Criteria and Guidance [PDF] manual.
FedRAMP Ready
A FedRAMP Ready designation is an indication that a 3PAO affirms that a CSP’s CSO is ready for the authorization process. The 3PAO authors the Readiness Assessment Report (RAR) and submits it to FEDRAMP PMO for review and approval. But what is a RAR FedRAMP? It is a document outlining a CSP’s ability to meet the FedRAMP security requirements. While FedRAMP ready CSPs aren’t required to submit a “Business Case”, its heavily weighted criterion in the JAB authorization process. Even without being FedRAMP ready, a CSP may be selected to work with JAB. However, it must achieve FedRAMP ready status within 60 days of selection or be deprioritized.
By understanding the prioritization criteria outlined above, CSPs can effectively position their offerings for successful evaluation and authorization within the FedRAMP program.
2. Conduct a Readiness Assessment
Invite a FedRAMP Approved 3PAO to conduct a formal Readiness Assessment and prepare the Readiness Assessment Report (RAR). The 3PAO submits the RAR to the FedRAMP PMO for review. The CSO then remediates any identified gaps in its security posture. If the FedRAMP PMO is content with the CSO’s implementation of the security controls, they approve and designate them FedRAMP ready. You can find FedRAMP-ready products on the FedRAMP marketplace.
3. Hire a 3PAO to Conduct a Full Security Assessment
Finalize the System Security Plan (SSP) and engage an accredited 3PAO to conduct a Full Security Assessment of the CSO. In this step, the CSO is deemed FedRAMP ready and prioritized to work with JAB. The 3PAO will develop the Security Assessment Plan (SAP), perform a full assessment of the service offering, and develop a Security Assessment Report (SAR) based on security gaps identified in the CSO.
4. Develop a Plan of Action and Milestones
Review the SAR and develop a Plan of Action and Milestones (POA&M) to track and manage security risks identified therein. The cloud service provider should use the POA&M to remediate the identified system security risks. Additionally, they should complete FedRAMP documentation (SSP, SAP, SAR, and POA&M) and a month of continuous monitoring deliverables using the FedRAMP approved templates provided on the site.
5. Submit Full Security Package and Begin the JAB Authorization Process
Submit its Full security package to JAB at least 2 weeks before the JAB kickoff stage. At this stage, the 3PAO, FedRAMP, and CSP review the CSO’s system security capabilities, risk posture, and architecture. After the kickoff meeting, JAB can give the green light for a CSO to continue with the authorization process. It can also give a no-go decision. If a green light is issued, JAB embarks on an in-depth review of the CSO’s security authorization package. At this stage, the 3PAO and CSP address comments and questions from JAB reviewers in a timely manner. Throughout the JAB authorization process, monthly continuous monitoring deliverables must be prepared and submitted to the Board.
After JAB completes its review, the assessor and CSP should remediate any outstanding security gaps. Once all issues have been resolved, JAB issues a formal authorization decision. If the decision is in favor, the Board issues a provisional Authority to Operate (P-ATO).
Agency Authorization Process
The other path to FedRAMP certification is by following the agency process. In this option, the CSP can work directly with a federal agency to get an ATO for its service offering. The agency process can be divided into 3; preparation, authorization, and continuous monitoring. The CSP can follow the following steps:
Preparation
Readiness Assessment (Optional)
Hire an accredited 3PAO to perform an optional readiness assessment and develop a RAR. Although this is optional, it is recommended highly as it is a best practice. The RAR should be reviewed by FedRAMP PMO with the CSP remediating any identified gaps. This culminates in a FedRAMP ready designation.
Pre-Authorization
Alternatively, a CSP may skip the readiness assessment part and formalize its partnership with an agency by fullfilling designation requirements outlined on FedRAMP Marketplace. This is called pre-authorization. It should also prepare for the authorization process by making the necessary procedural and technical adjustments aimed at addressing federal security requirements. Additionally, the CSP should prepare security deliverables needed for authorization. By this stage, the CSP should have met the requirements outlined here. Finally, the CSP should get ready for and conduct a kickoff meeting where background and functionality of the cloud service among other things will be discussed.
Authorization
Full Security Assessment
The CSP must prepare and complete an SSP before hiring a 3PAO for a Full Security Assessment. Additionally, their Agency customer must have reviewed and Approved the SSP. The CSP’s 3PAO must also have prepared a SAP which must have input from the CSP’s authorizing agency. Only then can CSP hire a 3PAO to conduct an independent audit of their service offering. After testing the CSP’s system, the assessor develops a SAR detailing their findings. The SAR includes the 3PAO’s recommendation for FedRAMP Authorization. The CSP reviews the SAR and develops a POA&M with input from the 3PAO. The POA&M document outlines how the CSP will address the gaps identified during testing.
Agency Authorization process
The 3PAO and CSP sends the CSO’s full security package to the agency security team. The Agency reviews the security authorization package. However, this may include a debrief with the FedRAMP PMO. A remediation might be required depending on the findings of the agency review. It is at this step phase that the agency implements, tests, and documents customer-responsible controls. It also conducts a risk analysis, accepts risks and based on its risk tolerance, issues an ATO. Once the CSP obtains an ATO letter for use of the service offering, the following will take place:
- The CSP will upload the complete security package, except security assessment material, and Authorization package checklist to FedRAMP’s Secure Repository. The security package includes POA&M, SSP and its attachments, and the Agency ATO letter.
- Undergoing rigorous security assessments by an accredited Third Party Assessment Organization (3PAO), which examines the CSP's security policies, system security architecture, controls implementation, and ability to continuously monitor security.
Finally, the FedRAMP PMO reviews the Security assessment materials for inclusion to the FedRAMP marketplace. Additionally, the CSO’s listing on the FedRAMP marketplace is updated to a FedRAMP Authorized designation
Continuous Monitoring
The CSP should institute measures for continuous monitoring of its service offering. Additionally, they should provide security deliverables such as updated POA&M, Vulnerability scans, incident reports, annual security assessments, etc. to all agency customers. CSPs can post their monthly continuous monitoring materials using the FedRAMP Secure Repository. This eases the sharing and accessibility with agency representatives.
Maintain Continuous Monitoring
Upon receiving a formal Authorization ( ATO or P-ATO) for its service offering, the CSP should institute internal continuous monitoring mechanisms. The federal agencies a CSP works with also monitor the service offering externally. To remain FedRAMP compliant, the cloud service provider must provide evidence that some critical controls are operational monthly or yearly. Penetration testing (pen testing) and vulnerability scanning are vital in meeting this FedRAMP compliance requirement. Organizations can make continuous monitoring easier by automating controls and using the proper risk management and compliance tools where possible. For instance, they can schedule vulnerability scanning at a set frequency, eliminating the need for an employee to start or run a scan manually. CSPs can also configure security and other logs to be automatically saved and instantly backed up.
Differences Between FedRAMP JAB and Agency Authorization Process
You may have noted that the FedRAMP Certification process differs between these two paths. However, they mainly differ on various fronts, including the need for readiness assessment, outcome, and who the OSC is working with.
1. Who the OSC Works With
If the CSP chooses to work with a federal agency directly, they will follow the agency process. However, if it chooses to work with the FedRAMP Joint Authorization Board, it will pursue the JAB process.
2. Need For Readiness Assessment
OSCs pursuing the agency process aren’t required to conduct a 3PAO readiness assessment. A Full Security Assessment will suffice. However, following the JAB Route to FedRAMP authorization, CSPs must complete a 3PAO readiness assessment and a 3PAO Full Security assessment.
3. FedRAMP Authorization
The agency route results in a FedRAMP Authority to Operate (ATO). On the other hand, if a CSP follows the JAB path to authorization, it obtains a Provisional Authority to Operate (P-ATO).
4. Impact Level
The Agency Authorization route is most appropriate for CSOs categorized as low impact under FIPS 199. On the other hand, the JAB Authorization path is the most suitable for Service Offerings classified as Moderate or High Impact.
5. FedRAMP Connect
Entering the JAB authorization requires the CSP to meet the stringent requirements. The CSP must also produce evidence of demand for their product in government space, including business cases and potential demand via specific agencies. Even after all this, JAB will select 12 CSPs to enter the program. JAB Process is more restrictive, and any other CSO looking to gain a P-ATO through this process must do so through FedRAMP Connect. On the other hand, any provider can obtain an ATO for their CSO using the Agency process, provided the agency needs the service offering and the solution meets the agency-specific security requirements.
6. Risk Acceptance
JAB cannot accept risks on behalf of other agencies. That is why the JAB process to FedRAMP authorization results in a provisional ATO. On the other hand, agencies can define risk acceptance levels, which is why CSOs following the Agency route to authorization achieve an Authority to Operate.
What Does It Take to Be FedRAMP Certified?
Besides asking yourself how to get FedRAMP certified, you must look for ways to remain so. Achieving FedRAMP certification, a cornerstone of federal security compliance, necessitates a comprehensive and rigorous approach, particularly for high-risk impact CSPs. However, successful authorization unlocks access to the FedRAMP Marketplace, connecting the CSP with a vast network of potential federal agency partners.
Costs and Considerations
While acknowledging the inherent thoroughness of the FedRAMP certification process, risk management teams should also factor in the ongoing expenditure associated with maintaining certification. Continuous monitoring and adaptation to evolving guidance are essential to sustained FedRAMP compliance. Regarding finances, achieving FedRAMP compliance can be a significant investment, necessitating collaboration across the organization. Engaging a 3PAO for full security assessments adds further potential costs, especially if remediations are required.
Long-Term Value Proposition
Despite these initial hurdles, the benefits of a secure relationship with the federal government can significantly outweigh the risks and expenses involved. For instance, by demonstrating a commitment to stringent security standards, FedRAMP certified CSPs position themselves as trusted partners for sensitive government data and operations. This would place them in a vantage position to win contracts.
What Are the Benefits of FedRAMP Certification?
Becoming FedRAMP authorized requires a significant time and resource outlay. However, any CSP with FedRAMP Certification can attest that its benefits outweigh the costs. Below are some of the benefits of FedRAMP authorization for CSPs and Federal Agencies:
1. Trusted Service
A FedRAMP certification accords federal agencies with a secure and trusted cloud service that meets heightened security requirements. The certification serves as a public testament to the provider’s adherence to stringent security protocols, ensuring government data’s confidentiality, integrity, and availability. Consequently, agencies can establish secure and reliable cloud-based collaborations with greater confidence. Additionally, a CSO that has achieved FedRAMP certification can be trusted by its customers and federal agencies.
2. CSOs Can Reuse FedRAMP Assessment
Your CSO only needs a single assessment to obtain an ATO from various agencies. Once the assessment is complete, it is posted on the OMB Max Repository, where the other federal agencies can review the security package and issue an ATO based on that one review.
3. Streamlined Security Assessments
FedRAMP authorization serves as a passport to working with multiple federal agencies. By achieving and maintaining FedRAMP certification, CSPs eliminate the need for redundant security assessments across different agencies. This translates to enhanced efficiency and reduced administrative burden for CSPs and government entities.
4. Improved Security
Achieving FedRAMP certification signifies a steadfast commitment to robust security protocols. The FedRAMP program mandates stringent security controls and continuous monitoring, ensuring that CSP platforms consistently meet rigorous compliance standards. This increases confidence and reduces security risks for federal agencies utilizing cloud services.
Benefits of Using FedRAMP Authorized CSPs
What are the benefits of working with a FedRAMP-authorized CSP? Why should you partner with a FedRAMP Authorized CSP instead of one designated FedRAMP ready or without a designation? Below are some of the benefits:
1. Cost-Effective
Any CSO that has passed the FedRAMP authorization process must fully implement the required security measures. This means you will avoid the costly and time-intensive due diligence yourself by choosing a CSO from the FedRAMP marketplace. Since the necessary due diligence was done when the service provider underwent the FedRAMP authorization process, you can rest assured and confident of their security controls. You need not check every single control yourself.
2. Mitigates Risk
A FedRAMP certified CSO has implemented the security controls required at a particular impact level, helping mitigate any risk of a data breach. Hence, you can remain compliant with government standards such as CMMC 2.0, HIPAA, and PCI DSS while reducing the risk of sensitive data falling into the wrong hands. If a CSO is FedRAMP authorized, you can trust they have taken the appropriate measures to safeguard your data. It also helps you avoid non-compliance consequences such as loss of business, hefty fines, or, in extreme cases, prison time.
3. Verified by a Third-Party
Not many organizations have the resources or time to verify that a CSP has met all the FedRAMP controls at a particular impact level. Hence, leaving such verification to those with expertise, 3PAOs is probably best. When 3PAOs assess an organization’s implementation of the FedRAMP controls, you can be sure it will be thorough. JAB and FedRAMP PMO may review the documentation to ensure no vulnerabilities are ignored.
4. Peerless Data Security
For many organizations, particularly those dealing with CUI, FedRAMP compliance is essential. Hence, you must ensure all the CSPs you’re working with have met the standards of the FedRAMP Program. If you don’t take the required measures to secure data, it can fall into the wrong hands. Government data is often attractive to cybercriminals, making data security something of concern to Federal contractors and agencies. With the increased use of cloud technologies, organizations should work with FedRAMP-authorized CSPs to protect their data.
5. Always Up-To Standards
A FedRAMP-authorized CSP must have implemented a set number of controls based on the level of impact of the data their CSO will be handling. However, implementing these controls during the authorization process isn’t enough. To maintain compliance, CSPs must continuously monitor and assess their systems for vulnerabilities. They are supposed to submit monthly or annual deliverables to JAB. Like with any other compliance, FedRAMP compliance is not a one-time thing. It is an ongoing process. Working with an authorized service provider means you won’t worry about deteriorating or outdated data security measures.
Does your organization work with sensitive data such as CUI? Do you process, store, or transmit the data over the cloud? It is in your best interest to work with a FedRAMP-authorized CSP. By not doing so, you might be placing your organization and data at risk. For instance, CMMC 2.0 requires that if you are using a CSP, they must be authorized at a FedRAMP moderate baseline or equivalent.
Confidence In the Cloud Begins with FedRAMP!
Although the FedRAMP process is both thorough and rigorous, once a CSO obtains authorization, options to expand the service offering throughout different government agencies and offices are unlimited. FedRAMP provides confidence to federal agencies looking to adopt cloud solutions that they’ll be using a secure platform. As explained above, there are many benefits to ensuring your CSO is authorized and listed on FedRAMP Marketplace. Does your contract or solicitation contain a DFARS 7012 clause? Do you use a CSP to process, store, or transmit CUI? Per CMMC 2.0, you must ensure the service offering is authorized as FedRAMP Moderate or High on the FedRAMP Marketplace.
Frequently Asked Questions
FedRAMP General Questions
FedRAMP stands for Federal Risk and Authorization Management Program and provides a standardized approach to security authorizations for Cloud Service Offerings (CSOs).
By standardizing approach to security assessment, authorization and monitoring for CSOs, FedRAMP ensures consistent security standards for cloud services, safeguarding federal data.
A FedRAMP P-ATO or ATO doesn’t expire. However, it requires continuous security monitoring with specific tests, reports, and metrics. If a CSO falls short of this continuous monitoring at any time, JAB or the issuing agency may revoke your ATO.
A FedRAMP compliant CSO means one that has met the FedRAMP security control requirements and have received a FedRAMP Authority to Operate (ATO).
To maintain an authorization which meets FedRAMP requirements, CSPs should continously monitor and regularly assess their security controls and demonstrate that their CSO’s security posture is continuously acceptable.
Yes, FedRAMP is mandatory for all executive agency cloud deployments and service models at the High, Moderate, and Low risk impact levels.
FedRAMP vs. Other Standards or Frameworks
FIPS is a series of computer security standards that provides specific guidance to agencies and Federal contractors in accordance with FISMA. On the other hand, FedRAMP is a government-wide program that provides a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services.
No, FedRAMP is a compliance framework while SOC 2 is a reporting framework. When you search FedRAMP vs. SOC 2, you’ll realize the two are different in terms of governance, security objectives, assessment framework, target market, and what happens on successful audit.
No, FedRAMP and NIST are two separate but interdependent entities. FedRAMP uses the NIST procedures and guidelines to provide standardized security requirements for cloud services
No, NIST 800-171 itself does not directly require FedRAMP. However, the relationship between them is nuanced. SP 800-171 borrows heavily from SP 800-53, which FedRAMP is based.
- For IaaS, PaaS, or SaaS providers doing business with the government, FedRAMP authorization is mandatory. This applies regardless of the data classification involved.
- If you, not the government, operate a system that stores or processes CUI for them, you must comply with NIST SP 800-171.
- If you’re adefense contractor and handling CDI, CTI and other specific types of data, should comply with DFARS 7012 that mandates FedRAMP authorization for CSPs.
FedRAMP is not mandatory for CMMC 2.0 certification. However, OSAs and OSCs using CSPs to store, process, or transmit CUI must ensure their CSOs are FedRAMP authorized at a Moderate or Higher Baseline, or Moderate Equivalent.
ISO 27001 requires adherence to standard requirements, prioritizing risk identification and self-implemented controls. In contrast, FedRAMP ATO certifies CSOs for use based on RMF and NIST SP 800-53 compliance. ISO 27001 certification lasts three years, focusing on active management while a FedRAMP ATO itself remains active and ongoing and you’re required to provide monthly or yearly deliverables to the Agency or JAB.
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