FedRAMP

The Key Differences between FedRAMP A-TO & P-ATO

ZenGRC Team · October 7, 2024 ·

The Federal Risk and Authorization Management Program (FedRAMP) helps U.S. federal agencies assess cloud service providers’ security more efficiently. It aims to protect government data and information systems and promote the adoption of secure cloud products and services by federal agencies.

FedRAMP standardizes security requirements and authorizations for SaaS, PaaS, and IaaS cloud services per the Federal Information Security Management Act (FISMA). All cloud service providers (CSPs) that process, transmit, or store government information must use the FedRAMP baseline security controls to obtain security authorization under FISMA.

Any CSP looking to work with a federal government agency must achieve FedRAMP authorization via an Agency Authority to Operate (ATO) or a Provisional Authority to Operate (P-ATO). ATO and P-ATO are the two pathways to achieve FedRAMP compliance for cloud vendors.

Both types of authorization indicate that the CSP has implemented the required cloud security measures to protect sensitive government data. That said, there are differences between these two authorization paths. Understanding FedRAMP is crucial to understanding the differences.

What is FedRAMP?

FedRAMP standardizes and simplifies FISMA compliance for Cloud Service Offerings (CSOs). Through a set of best practices and controls, FedRAMP provides agencies and vendors with a “standardized approach to security and risk assessment for cloud technologies and federal agencies,” to use the FedRAMP website‘s own words.

This government-wide program aims to:

Assure that all CSOs used by government agencies are adequately protected
Reduce duplication and cost inefficiencies around risk management
Create transparent security authorization processes to enable agencies to adopt secure cloud computing systems rapidly

The baseline controls that serve as the foundation for FedRAMP come from the National Institute of Standards and Technology (NIST), specifically in the security framework known as NIST 800-53. The controls in NIST 800-53 encapsulate multiple security and risk areas, including:

Access control
Configuration management
Contingency planning
Risk assessment

In addition to providing standardized security, assessment, and authorization requirements for cloud products and services, FedRAMP also provides:

Standardized authorization packages
A conformity assessment program with qualified independent, third-party security assessors
A repository for CSO authorization packages that any federal agency can access
Standardized contract “language” to help agencies seamlessly integrate FedRAMP requirements into CSO acquisitions

These artifacts are based on a security risk-based model, allowing agencies to leverage cloud system authorizations. All CSOs and CSPs must get FedRAMP authorization.

FedRAMP controls are designed, implemented, governed, and maintained by multiple U.S. government agencies, including the Department of Homeland Security (DHS), the Department of Defense (DoD), the General Services Administration (GSA), and, of course, NIST.

The FedRAMP Program Management Office (PMO) manages the program’s day-to-day operations. In addition, the Joint Authorization Board (JAB) issues a Provisional Authority to Operate (P-ATO) for cloud services and CSPs.

What is FedRAMP Authority to Operate (ATO)?

CSPs must first complete a rigorous authorization process to contract with U.S. federal agencies. An Authority to Operate (ATO) FedRAMP certification is one way to achieve authorization.

The ATO is a formal declaration by an agency authorizing the use of a CSO while explicitly accepting the risk of doing so. CSPs work directly with the agency’s security office and an Authorizing Official (AO) to obtain the ATO.

When applying for the ATO, CSPs provide a security authorization package to the agency. Before granting the ATO, the agency will provide a risk review of all the artifacts in the package following FedRAMP requirements.

The documentation is assessed independently, usually by a FedRAMP-accredited Third-Party Assessment Organization (3PAO) that acts on behalf of the federal agency. A 3PAO verifies the CSP’s security implementations and assesses the overall risk posture of its cloud environment to guide the agency’s security authorization decision.

The FedRAMP PMO recommends that agencies select an Independent Assessor (IA) from the FedRAMP 3PAO accreditation program. That’s not required, however; an agency can use a non-accredited IA for the ATO process as long as the agency can provide evidence of the IA’s independence via a letter of attestation.

Once the agency authorizes a CSP’s package, the agency emails the FedRAMP PMO. The PMO will instruct the CSP to submit the package for PMO review. During the review, the PMO will confirm that the package meets FedRAMP standards and publish it in the secure and access-controlled FedRAMP Secure Repository.

Once the AO authorizes a CSP environment for use by the agency, the agency formalizes the decision in an ATO letter, which is then given to the CSP system owner. Then, the CSP is added to the list of authorized CSPs on www.fedramp.gov.

Other agencies can rely on the authorization letter and security package from the Secure Repository to make their own procurement decisions for cloud products and to issue their own ATO to a CSP.

ATO Authorization Phases

The ATO application process varies depending on the CSO requesting authorization and the government systems it is requesting access. But in general, the ATO authorization process consists of four phases:

Establish CSP/Agency Partnership
In this first step, the agency reviews the CSP’s security authorization package and identifies areas where adjustments are required.
Perform Security Assessment
A FedRAMP-accredited 3PAO or a non-accredited IA performs the security assessment. After completing the security assessment, the agency may grant the ATO.
Complete Authorization
An agency’s ATO does not give the CSP blanket authority to work with all agencies. To work with other agencies, the CSP must go through steps 1 and 2 again. Other agencies can review the CSP’s authorization letter from the ATO-granting agency on the FedRAMP Secure Repository. They can compare the package to their security requirements to determine whether the CSO meets their security standards.
Perform Continuous Monitoring
Once a CSP receives the ATO, it must continuously monitor to maintain authorization. To this end, the CSP must submit a set of monitoring deliverables to the agency using the CSO.

Monitoring assures that the CSP’s security measures are still operating effectively and that its security authorization package is up-to-date. Monitoring also increases visibility into the CSO’s security posture and allows agencies to make informed risk management decisions.

If more than one agency uses the FedRAMP-ready CSO, the CSP must submit these deliverables to all agencies. The CSP must also conduct annual security assessments to assure alignment with security requirements and maintain its FedRAMP ATO.

What is FedRAMP P-ATO?

A CSP can also obtain FedRAMP authorization via a provisional authorization (P-ATO) through the Joint Authorization Board (JAB).

To get a P-ATO, the CSP works with the FedRAMP PMO through its Security Assessment Framework (SAF) and provides documentation in the security authorization package to the JAB. (Remember, in the case of ATO, the package is provided to the agency that will use the CSP’s CSO.)

For P-ATO, the JAB provides a risk review of these documents. An accredited 3PAO independently tests, verifies and validates the CSP’s security assessment package, and JAB then grants the P-ATO.

The JAB also informs federal agencies whether the CSO’s risk posture is acceptable for use at the designated data impact levels. The JAB, however, does not assume the risk for any agency. After vetting a CSP and assessing its security posture, the JAB may grant a P-ATO, but it is still an individual agency’s decision to grant the ATO.

Differences Between ATO and P-ATO

At first glance, the only difference between ATO and P-ATO seems to be the word “provisional,” but there’s a lot more to these ideas than that one word.

Whether the CSP gets ATO or P-ATO authorization, the CSP must obtain an authorization letter from the granting authority. For ATO, the letter is provided by the agency contracting with the CSP; the JAB signs the P-ATO letter.

Another difference between ATO and P-ATO is around continuous monitoring. The FedRAMP PMO manages continuous monitoring activities (yearly and monthly) for systems with a JAB P-ATO. The agency manages these activities for systems with an agency ATO and annually updates a CSP’s security authorization package in the FedRAMP Secure Repository.

A CSP that has earned a FedRAMP JAB P-ATO meets the program’s stringent security and authorization requirements. Agencies can trust that essential data security and cybersecurity measures are in place in the cloud environment, and the agencies don’t have to do their security risk assessments.

FAQs About FedRAMP ATO and P-ATO

How Long Does It Take to Get a FedRAMP ATO?

Three major components of your ATO trip will influence how long it takes to obtain permission. Furthermore, the authorization method you choose (JAB or Agency Sponsor) and the level you seek will influence your timetable. We propose organizing your chronology into four major sections:

Review of Readiness. Required for JAB authorization and frequently suggested for agency ATO preparation – anticipated to take 1 month.
Remediation. This is tough to quantify because each company is unique. Most businesses will require 4 to 6 months or more before they are ready (depending on commitment to acquire an ATO).
Complete security assessment. This is when a 3PAO will conduct an impartial review of your security measures, as well as extensive security testing and vulnerability scanning. Depending on your resources and commitment to acquiring an ATO, this procedure might take 2-4 months to complete.
The Authorization Procedure. This is the stage at which you collaborate with the JAB or agency/FedRAMP PMO to examine your authorization package and get an ATO. This procedure can take 2 to 3 months or longer, depending on how regularly and openly you communicate with the JAB, your agency and how accurate and thorough your authorization package is.

How to Obtain a FedRAMP Authorization

A FedRAMP Authorization can be obtained in two ways: as a provisional authorization through the Joint Authorization Board (JAB) or an authorization through an agency.

At any stage within the Agency permission process, agencies may interact directly with a Cloud Service Provider (CSP) for permission. CSPs who cooperate directly with an agency to get an Authority to Operate (ATO) will collaborate with the agency throughout the FedRAMP Authorization process.

Is FedRAMP Authorization Required?

FedRAMP is necessary for every CSP that has created a CSO for use with a federal agency.

FedRAMP rules must be followed whenever a federal agency distributes sensitive government data in the cloud. When an agency seeks a collaboration with a CSP, both parties must collaborate to get authorization.

What are the Best Practices for FEdRAMP Authorization?

Here are some best practices for attempting the many routes to authorization and attaining FedRAMP compliance:

Determine Your Impact Baseline

Your authorization level will depend on the services your CSP offers to federal agencies; this will also define how many security controls you must implement to get authorization.

Three impact baseline levels—low, moderate, and high—are used in the FedRAMP organization. These align with the potential consequences of a breach involving the agency’s information.

Filling the Federal Information Processing Standards Publication 199 (FIPS-199) form is the first step towards FedRAMP compliance. You can find out exactly what risk impact level you need to pursue by using the FIPS-199.

Select Your Authorization Pathway

FedRAMP authorization can be obtained through two primary channels: the Joint Authorization Board (JAB) or a particular Agency. An organization can obtain an Authorization to Operate (ATO) by agency authorization and a Provisional Authorization to Operate (P-ATO) through JAB authorization. The approach you choose should align with your business’s objectives, risk-impact level, and maturity.

Prepare Your POA&M

The initial stage of compliance, FedRAMP authorization, requires a lot of documentation. You must also finish the Plan of Action and Milestones (POA&M) and the FIPS-199. Under the National Institute for Standards in Technology (NIST) Special Publication 800-53, Security and Privacy Controls for Information Systems and Organizations, your CSO’s POA&M is a risk management strategy.

Align with Your Third-Party Assessment Organization (3PAO)

Visit the FedRAMP Marketplace for further details on federal agencies, a list of Third-Party Assessment Organizations (3PAOs), and a look at the already listed CSPs. To determine whether your company is ready for your ATO or P-ATO, you must work with a 3PAO to evaluate it and compile your Readiness Assessment Report (RAR).

Prepare for Continuous Monitoring

Following the receipt of your ATO or P-ATO, you have a schedule for continuous monitoring, or ConMon, as it’s known in FedRAMP. Monthly vulnerability scans are part of ConMon.

Planning out your monitoring schedule can help you prepare for this by going over your POA&M again, making sure the appropriate staff members are taking ownership of the controls, and creating an auditing and risk management strategy mainly made to keep your FedRAMP authorization.

Make sure to adequately prepare for this phase, which also necessitates keeping abreast of any updates to FedRAMP compliance standards and security measures applicable to your designated impact level. If you don’t, the JAB or the agency you’re working with may cancel your ATO.

Manage Compliance With ZenGRC

If you are a cloud vendor just starting your FedRAMP compliance journey, you need a tool to streamline the FedRAMP authorization process and make it less overwhelming. You need visibility into your control environment and access to information to evaluate your compliance program. With ZenGRC, you can get all this and more.

ZenGRC provides an integrated and automated system of record to help you stay up-to-date with FedRAMP requirements and ensure continual compliance monitoring. It eliminates tedious manual processes and spreadsheets to provide a fast, easy, prescriptive compliance solution.

Take advantage of ZenGRC to optimize the health of your FedRAMP compliance program. Schedule a demo to get started.

What is a FedRAMP Certification?

Libby Bevin · December 10, 2023 ·

Cloud service providers (CSPs) that want to compete for U.S. federal government contracts must first obtain FedRAMP certification — akin to a seal of approval from the federal government, that the CSP’s cybersecurity meets basic standards.

FedRAMP certification benefits small and large CSPs by boosting security, increasing efficiency, and smoothing the path to doing business with U.S. government agencies.

So what is FedRAMP, exactly, and how can your CSP achieve certification? This article will explore those questions.

What Is FedRAMP?

The Federal Risk and Authorization Management Program, or FedRAMP, standardizes the processes that U.S. government agencies use to evaluate and purchase cloud-based IT services.

The goal of FedRAMP is to ensure that federal data existing on the cloud is protected to an appropriately high degree. The required FedRAMP level of security is set by legislation. In addition, 14 other statutes and regulations apply, and 19 standards and guidance documents exist that CSPs must follow. In other words, understanding FedRAMP is no easy task.

FedRAMP Certification vs. FedRAMP Compliance

A CSP can approach FedRAMP in two ways: certification or compliance. The two terms are definitely not the same thing.

FedRAMP certification involves undergoing a full security assessment and FedRAMP authorization process under the Joint Authorization Board (JAB). CSPs going this route need to draft a System Security Plan (SSP) that thoroughly documents their security controls, undergo readiness assessments, and work with accredited Third-Party Assessors (3PAOs) to perform required audits and produce a final Security Assessment Report (SAR) for review by the JAB.

Once certified, rigorous continuous monitoring is required, including submitting monthly updates and annual assessments and developing a Plan of Action and Milestones (POA&Ms) to address any vulnerabilities you have. Becoming FedRAMP-certified signals alignment with stringent cloud security standards for government customers.

CSPs can also go the route of FedRAMP compliance. Here, you simply self-attest to FedRAMP security controls without formal 3PAO verification.

FedRAMP certification delivers more validation (through an external audit) but requires more time and resources. Compliance, on the other hand, can be an interim option to demonstrate baseline security. Both can aid CSPs in instilling trust during competitive federal pursuits.

Why Is FedRAMP Certification Important?

FedRAMP certification is important because without it, you’re not likely to win any business with the U.S. federal government (nor most state and municipal governments, too, since they tend to follow the feds’ lead on cybersecurity protocols).

The FedRAMP Marketplace lists FedRAMP-approved cloud service providers. When federal government agencies want a new cloud solution, they first look to this marketplace. For those agencies, selecting an already authorized product is much easier than starting the approval process with a new cloud provider. You’re far more likely to do business with government agencies when listed in the FedRAMP Marketplace.

FedRAMP certification can also help you advance your business in the private sector because the FedRAMP Marketplace is open to the public. Many private companies searching for a trusted CSP start by checking which vendors are on the FedRAMP Marketplace.

Some potential clients might need to be educated about FedRAMP, but most larger businesses know about FedRAMP, especially if they do business with the federal government. Requiring FedRAMP certification could become a deal-breaker as you try to close business with more mature companies.

When Is FedRAMP Required?

FedRAMP compliance or certification is required for any CSP offerings intended for adoption by U.S. federal government agencies per mandates from the General Services Administration (GSA).

When a federal agency plans to use a cloud-based product or service for moderate or high-impact data, it must choose a provider that follows FedRAMP standards. CSPs must then either pursue the formal FedRAMP authorization process and certification through the JAB or self-attest to FedRAMP security control implementation. Even for low-impact data usage, federal agencies increasingly expect some FedRAMP alignment from CSPs before procurement. (FedRAMP certification is also essential for any CSP servicing the Department of Defense.)

Beyond the federal government, state and local agencies also favor FedRAMP-aligned cloud solutions, underlining the standard’s centrality to public sector business.

What Are FedRAMP Compliance Requirements?

To demonstrate FedRAMP compliance, cloud service providers (CSPs) must implement the baseline security controls defined by National Institute of Standards and Technology (NIST) Special Publication 800-53. The core requirements include:

Documenting information security in a System Security Plan (SSP)
Performing annual self-assessments of deployed security controls
Establishing robust configuration management protocols
Enabling continuous monitoring of systems and networks
Developing detailed incident response and contingency plans
Instituting stringent access control mechanisms
Providing role-based security training
Maintaining detailed audit logs and records

Additionally, based on the chosen CSP compliance path, you may need to publish SSPs to FedRAMP Connect or undergo a 3PAO assessment. Beyond initial compliance, staying current on changing FedRAMP requirements and maintaining validated security over time is mandatory.

What Is the FedRAMP Certification Process?

FedRAMP certification is a long, complex, and potentially expensive process. Unlike FISMA (Federal Information Security Management Act), which allows organizations to perform their own assessments, FedRAMP certification must be performed by a certified 3PAO.

A cloud services provider can get certified in one of two ways, according to FedRAMP.gov:

A Joint Authorization Board (JAB) provisional authorization to operate is known as a P-ATO.
An Agency Authority to Operate, or an ATO.

Joint Authorization Board (JAB) Provisional Authorization

The Joint Authorization Board consists of representatives from the U.S. Department of Defense (DoD), the U.S. Department of Homeland Security (DHS), and the General Services Administration (GSA). The JAB sets the FedRAMP accreditation standards and reviews authorization packages, including results from the assessments done by the 3PAOs.

In this case, the CSP has to prove a demonstrated demand for its service by many agencies. Therefore, the JAB P-ATO is good for CSPs offering services that multiple agencies might want to use.

Agency Authority to Operate

The second way a CSP can obtain certification is via an Agency Authority to Operate. This is done through a specific agency, which grants the CSP the final Authority To Operate (ATO).

As part of the agency certification or ATO authorization process, a CSP works directly with an agency sponsor, which will review the CSP’s security package. This approach is best for cloud service providers that have developed niche offerings for only a few federal agencies.

To decide which type of security authorization suits your CSP offering, review both processes and consider the system deployment model, technology stack, market demand, and impact level.

Federal agencies categorize CSPs’ cloud service offerings into three impact levels: low, moderate, and high. These levels refer to the severity of potential harm in the event of a breach. The higher the level, the more security and data protection the CSP must provide.

Even if a CSP doesn’t work with government agencies, adopting FedRAMP security controls as part of its business plan will provide potential customers with the peace of mind that comes from knowing they’re working with a provider the U.S. government has carefully vetted.

How long does it take to get FedRAMP certification?

The time necessary to achieve FedRAMP certification isn’t set in stone. Instead, it varies based on several factors.

First is the complexity of the system being certified. Simple systems usually undergo assessment and certification faster than complex ones. Adequate preparation is another crucial factor.

Another factor is the initial assessment phase conducted by the 3PAO. This evaluation period, and how promptly an organization responds to feedback, can affect the overall timeline significantly.

All that said, a good rule of thumb is that FedRAMP certification typically takes six to 18 months — but that estimate can vary (greatly) based on the unique characteristics of the system seeking certification, the responsiveness of the organization undergoing the process, and the efficiency of the assessment and approval phases.

FedRAMP Certification Best Practices

CSPs can follow several best practices to demonstrate their cybersecurity maturity and improve the odds that an Authorizing Official (AO) will approve your offering.

Select and Implement Technical Security Controls

Implement as many technical FedRAMP restrictions as possible. Remember, the AO will be trying to find reasons to doubt your security controls. (This is especially true if you’re using third-party tools and have a lot of API connections to different services.)

Pipeline Security for CI/CD

In theory, the Continuous Integration Continuous Deployment (CI/CD) software development method should improve and simplify security by incorporating automated testing early in development. Unfortunately, too many firms use CI/CD as an excuse to release shoddy code based solely on the results of a few difficult-to-configure automated security tests.

As a result, AOs have a healthy skepticism about CI/CD methodologies. Development teams can help AOs be more comfortable with this software development and deployment approach by demonstrating increased security maturity across the development pipeline.

Avoid Infrastructure-as-Code (IaC)-based approaches

Infrastructure-as-Code (IaC)-based approaches generally make dealing with massive infrastructures and deployments easier. That said, orchestration technologies such as CloudFormation, Azure ARM, Terraform, or similar solutions to deploy templates can run the risk of spreading known vulnerabilities throughout your infrastructure.

As a result, be aware that an IaC-based strategy will be met skeptically. Document and be prepared to address all IaC templates in use, how they’re chosen and managed, what images those templates refer to, and why those images should be trusted. You’ll also have to show that you have a solid strategy for scanning templates and recognizing their weaknesses.

Formal Threat Modeling

Software threat modeling is a field significantly more advanced than standard risk assessment. Potential attack techniques are linked to system operations and specific code parts in threat modeling.

For example, your team should consider how every stage in user authentication could be exploited or whether your software is subject to more obscure injection-type flaws. You can also use the threat modeling approach to show you know your IaC templates and security-related configurations inside and out.

This level of modeling demonstrates your understanding of your infrastructure and code.

Postponing Development Deployments to Federal Clients

Many CSPs believe that applying FedRAMP regulations uniformly across their federal and non-federal customers is too tricky. As a result, they create dedicated settings for government clients, and the commercial production environment serves as a test environment.

While this may delay the delivery of features to federal clients, it often lowers an AO’s perceived risk. If you go this route, apply security patches to both environments as soon as they become available.

Manage FedRAMP Compliance With ZenGRC

Officials from the Defense Department have stated that the objective of FedRAMP certification is to keep compliance costs low. ZenGRC can help you achieve cost-effective compliance with complicated cloud security standards and frameworks.

ZenGRC templates make self-assessments easier. Our central dashboard gives you a unified picture of all your compliance frameworks, revealing where gaps in your cybersecurity program exist and how to solve them.

Schedule a demo today to see how ZenGRC can help you achieve “Zen-mode” compliance!

What is FedRAMP?

Libby Bevin · November 22, 2023 ·

The Federal Risk and Authorization Management Program, commonly known as FedRAMP, represents the U.S. federal government‘s strategic initiative to transition to cloud computing while ensuring the security and integrity of cloud services. FedRAMP offers a unified framework for assessing, authorizing, and continuously monitoring the security of cloud services and products provided by Cloud Service Providers (CSPs). By establishing a standardized, risk-based approach, FedRAMP streamlines the process for federal agencies to adopt cloud technologies. This not only simplifies their engagement with cloud-based solutions but also ensures a consistent level of security across all federal cloud deployments. Understanding FedRAMP is essential for CSPs seeking to do business with federal agencies and for government entities looking to leverage the power and flexibility of cloud computing within a secure and compliant framework.

FedRAMP offers a unified approach to secure cloud-based solutions

FedRAMP was first introduced in 2011 by the Office of Management and Budget, in a memo sent to the chief information officers of other government agencies. Essentially, FedRAMP pushed those agencies toward increasing their security standards and using secure cloud-based technology, rather than spending money on new on-campus infrastructure which would quickly become obsolete anyway.

As more and more federal agencies adopted a “cloud first” technology strategy, and cloud offerings became more sophisticated and interconnected, the need for better cybersecurity and continuous monitoring became obvious.

Before and after FedRAMP

Before FedRAMP, each federal agency managed its own security assessment by following guidance loosely set by the Federal Information Security Management Act (FISMA).

After FedRAMP, each individual agency could achieve the same high standard for security by picking a cloud solution that was already FedRAMP-compliant. That simplified the selection of technology vendors and subcontractors. By working with a business that has already achieved FedRAMP compliance, the agency is assured that the cloud solution offered is safe.

What is required to be FedRAMP certified?

Achieving FedRAMP certification, which authorizes a cloud service for use by federal agencies, involves a rigorous and comprehensive process. The requirements to become FedRAMP certified include:

Documentation of Security Controls: Cloud Service Providers (CSPs) must document their security controls in a System Security Plan (SSP). This plan should align with the FedRAMP security control baseline, which is based on the NIST (National Institute of Standards and Technology) SP 800-53.
Third-Party Assessment Organization (3PAO): CSPs need to engage with a FedRAMP-accredited 3PAO. The 3PAO conducts an independent assessment of the CSP’s security controls to ensure they meet FedRAMP standards.
Security Assessment Plan (SAP): The 3PAO creates a SAP, detailing how the assessment will be conducted. This plan includes testing procedures and evaluation criteria.
Security Assessment: The 3PAO executes the SAP, rigorously testing and assessing the CSP’s security controls. This involves both a review of documentation and operational testing of controls.
Security Assessment Report (SAR): Upon completing the assessment, the 3PAO provides a SAR, which includes findings, risks, and recommendations. This report is critical for the authorization decision.
Plan of Action and Milestones (POA&M): If the assessment uncovers any weaknesses or deficiencies, the CSP must develop a POA&M. This document outlines how the CSP plans to address and mitigate identified vulnerabilities.
Authorization Package Submission: The CSP submits the SSP, SAP, SAR, and POA&M to the FedRAMP Program Management Office (PMO) for review.
Agency Authorization: A federal agency (or the Joint Authorization Board, JAB, for a JAB Provisional Authority to Operate) reviews the authorization package. If the agency or JAB is satisfied that the CSP meets all requirements, they grant an Authorization to Operate (ATO).
Continuous Monitoring: Once certified, CSPs must engage in continuous monitoring and reporting to maintain their FedRAMP authorization. This involves regular updates, vulnerability scans, and adherence to changing guidelines.

FedRAMP certification demands a high standard of security and continuous compliance, reflecting the critical importance of protecting federal data and systems. For CSPs, this certification not only opens the door to federal contracts but also signifies a strong commitment to security that can be advantageous in the broader market.

Requirements of cloud-based providers in the FedRAMP marketplace

To become FedRAMP authorized, a CSP must be reviewed and approved by the Joint Authorization Board (JAB), a board consisting of all the agencies that originally signed on to FedRAMP.

Each year, the JAB selects about a dozen cloud service providers and solutions to work with. If a provider passes a detailed scrutiny and testing program, it receives what’s called a Provisional Authority to Operate (P-ATO).

The heart of FedRAMP is the National Institute of Standards and Technology (NIST) Special Publication 800-53, which provides a catalog of information security controls selected to improve cybersecurity in cloud computing environments.

FedRAMP authorization gives a stamp of approval to the CSP, signaling to government agencies that the cloud solution is safe and has the necessary authorization to keep the agency in FedRAMP compliance.

Three steps to get and maintain FedRAMP compliance

FedRAMP authorization consists of three security baseline levels through which all CSPs must progress, where the final level is a commitment to ongoing monitoring by a third-party assessment organization:

A preparation phase, which includes a basic security assessment, readiness assessment, and a full cloud security assessment;
A JAB authorization phase with a full review of the cloud solution’s functionality (this takes 12 to 13 weeks);
A final commitment to ongoing JAB monitoring of the cloud solution. This is especially important because ongoing monitoring means that authorized cloud products must stay current on cybersecurity threats, or they will lose their FedRAMP authorization.

Fedramp.gov has a detailed outline of the process as experienced by cloud service providers, federal agencies, and third-party assessment organizations (3PAOs).

The three levels have increasingly stringent security requirements and standards that are tied to the types of data that CSPs are managing. Requirements for better security increase as a CSP moves through the levels.

The role and makeup of the Joint Authorization Board (JAB)

The JAB is made up of chief information officers from the Department of Defense (DoD), Department of Homeland Security (DHS), and the General Services Administration (GSA).

The JAB is responsible for establishing FedRAMP accreditation standards and for reviewing proposed new FedRAMP requirements. Those new requirements are developed on an ongoing basis as new risks to information systems come around.

The JAB also reviews authorization packages, including results from the assessments done by third-party assessment organizations (3PAOs). The JAB may grant provisional authorization for CSPs to operate, but the federal agency using the service still has responsibility for granting the cloud service provider the final authority to operate (ATO).

FedRAMP certification is a must for CSPs that want to do business with the U.S. government

Although obtaining FedRAMP certification can be difficult, accreditation is necessary for cloud service providers that want to expand their work with the U.S. government. The FedRAMP program management office runs the website FedRAMP.gov , which is where you should start if you want to seek FedRAMP certification. The site has several templates that can help you develop a plan of action and a system security plan, which are necessary to satisfy FedRAMP compliance standards and bring you one step closer to capturing more contracts in the public sector.

How much does it cost to go through FedRAMP?

The cost of going through the FedRAMP (Federal Risk and Authorization Management Program) process can be significant and varies widely depending on several factors. These costs are generally incurred by the Cloud Service Providers (CSPs) seeking certification. Key factors influencing the total cost include the complexity of the cloud service, the level of FedRAMP certification being pursued (e.g., FedRAMP Ready, FedRAMP Moderate, FedRAMP High), the existing state of the CSP‘s security posture, and the need for third-party consulting or assessment services.

Preparation Costs: This includes the costs associated with developing, implementing, and documenting the necessary security controls to meet FedRAMP requirements. It might also involve the cost of hiring consultants or additional staff to assist in this process.
Third-Party Assessment Costs: Hiring a FedRAMP-accredited Third-Party Assessment Organization (3PAO) to conduct the required assessment is a significant part of the expense. The cost for 3PAO services can vary based on the complexity of the assessment and the level of assistance required.
Remediation Costs: If the 3PAO identifies areas that need improvement, the cost of remediation efforts to address these gaps must be considered.
Ongoing Compliance Costs: Maintaining FedRAMP certification requires continuous monitoring and regular reporting, which involves ongoing costs for personnel, technology, and potentially third-party services to ensure continuous compliance with FedRAMP requirements.

On average, the cost of achieving and maintaining FedRAMP certification can range from several hundred thousand to a few million dollars. For many CSPs, these costs are seen as a long-term investment, allowing them to compete for government contracts and demonstrating a high level of commitment to cloud security, which can be a market differentiator in the commercial sector as well. It’s advisable for organizations considering FedRAMP certification to conduct a detailed cost-benefit analysis and consider seeking advice from experienced consultants or vendors who have gone through the process.

FAQs About FedRAMP

What is the difference between NIST and FedRAMP?

NIST (National Institute of Standards and Technology):

Role: NIST is a non-regulatory federal agency under the U.S. Department of Commerce. It develops and publishes standards, guidelines, and best practices across various domains, including cybersecurity.
Frameworks: NIST provides comprehensive frameworks like NIST SP 800-53, which outlines security controls for federal information systems and organizations.
Applicability: NIST’s guidelines are used across different sectors, providing foundational standards and best practices for cybersecurity, risk management, and information security.

FedRAMP (Federal Risk and Authorization Management Program):

Role: FedRAMP is a government-wide program that standardizes security assessment, authorization, and continuous monitoring for cloud products and services used by U.S. federal agencies.
Specificity for Cloud Services: While it uses NIST SP 800-53 as a foundation, FedRAMP tailors these standards specifically for cloud services, adding additional requirements and a structured approval process for cloud service providers (CSPs).
Focus: FedRAMP’s primary focus is on ensuring cloud services used by federal agencies meet stringent security requirements.

Why is a FedRAMP certification important?

FedRAMP certification is significant for several reasons, especially for CSPs and government agencies in the United States:

Standardized Security for Federal Data: FedRAMP provides a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services. This ensures that all cloud services used by federal agencies meet rigorous security standards, safeguarding federal information.
Enhanced Trust and Credibility: For CSPs, obtaining FedRAMP certification can significantly enhance their credibility and trustworthiness in the eyes of government clients. It demonstrates a serious commitment to maintaining high security standards.
Market Access: FedRAMP certification is a prerequisite for any CSP that wants to do business with federal agencies. Without this certification, CSPs are effectively barred from a significant market segment.
Reduced Redundancy and Cost: FedRAMP employs a “do once, use many times” framework, which means that once a service is certified, all federal agencies can leverage this certification. This reduces the need for separate certifications for each agency, saving time and resources for both CSPs and government agencies.
Risk Management: FedRAMP helps in identifying, assessing, and managing risks associated with cloud services. It provides a comprehensive set of controls and continuous monitoring processes that help in mitigating potential security risks.
Compliance Assurance: For government agencies, using FedRAMP-certified cloud services ensures compliance with federal regulations and standards. This is crucial in maintaining the integrity and security of government operations and sensitive data.
Continuous Improvement and Monitoring: The FedRAMP program includes ongoing assessment and monitoring, ensuring that CSPs continuously maintain and improve their security postures in response to evolving threats.
Building a Security Culture: Obtaining FedRAMP certification often requires a significant shift in how a CSP approaches security, leading to a stronger security culture within the organization.

FedRAMP certification plays a critical role in ensuring secure cloud services for federal agencies, reducing risk, and facilitating compliance with federal security standards. For cloud service providers, it opens doors to federal contracts and demonstrates a high level of commitment to security.

How do you stay FedRAMP compliant?

Continuous Monitoring: CSPs must have robust processes for continuous monitoring of their security controls to ensure ongoing compliance with FedRAMP requirements.
Regular Reporting: FedRAMP requires regular reporting to the relevant agencies and bodies, including any changes to the service or environment that might affect security.
Annual Assessments: CSPs are required to undergo annual assessments by a third-party assessment organization (3PAO) to validate their adherence to the required security controls.
Incident Management: Implementing an effective incident management and response strategy is crucial for quickly addressing any security incidents.
Training and Awareness: Regular training for staff on compliance requirements and security best practices helps maintain a culture of security and compliance.
Adhering to Updates in Standards: CSPs need to stay informed about any updates or changes in FedRAMP requirements and NIST guidelines and adjust their practices accordingly.

Maintaining FedRAMP compliance is an ongoing process that requires CSPs to continually assess and improve their security practices to keep up with evolving threats and changing standards.

Cybersecurity and compliance management tools like ZenGRC

In today’s interconnected world, especially during and after the challenges posed by the pandemic, it’s vital for businesses to secure their data and operations as they transition to cloud-based environments. Cybersecurity and compliance management tools are pivotal in this journey, and ZenGRC stands out as a leading solution.

ZenGRC offers an innovative platform for compliance, risk, and workflow management, designed to be both intuitive and user-friendly. Its software goes beyond mere workflow tracking; it proactively identifies high-risk areas before they escalate into tangible threats. This preemptive approach to risk management ensures that your business stays ahead of potential issues, safeguarding your operations and data.

One of the key features of ZenGRC is its hassle-free approach to compliance management. Recognizing the complexity and often daunting nature of compliance, ZenGRC simplifies these processes, making them more accessible and manageable. This approach allows businesses to focus on their core activities, confident in the knowledge that their compliance needs are being expertly handled.

For businesses seeking a reliable and effective tool to enable their Compliance Management Systems (CMS), ZenGRC offers a comprehensive solution. To fully appreciate the capabilities and benefits of ZenGRC, we invite you to contact us for a personalized demonstration. Discover how ZenGRC can streamline your compliance and risk management processes, ensuring a secure and efficient operational environment for your business.

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Checklist For FedRAMP Requirements

Libby Bevin · October 31, 2023 ·

When the United States government adopted a “cloud-first” initiative to ease agency data burdens, it established the Federal Risk and Authorization Management Program (FedRAMP). Although many organizations assume that FedRAMP authorization applies only to those companies seeking to work with federal agencies, FedRAMP compliance benefits private sector businesses as well.

FedRAMP Requirements Checklist

The Federal Risk and Authorization Management Program (FedRAMP) is a U.S. government-wide program that standardizes the security assessment, authorization, and continuous monitoring processes for cloud products and services used by federal agencies. It provides a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services.

Below is a high-level checklist of the main requirements for a cloud service provider (CSP) to become FedRAMP compliant:

System Security Plan (SSP):
- Detailed documentation describing all the security controls you’ve implemented in your environment.
- System overview, system boundaries, system environment, and system data flow diagrams.
Security Assessment Plan (SAP):
- Document detailing the planned assessment efforts.
- Identification of security controls to be tested, assessment procedures, and expected outcomes.
Security Assessment Report (SAR):
- A report that details the results of the security assessment.
- Identification of vulnerabilities, risks, and recommendations.
Plan of Action and Milestones (POA&M):
- Document identifying risks and plans for mitigation.
- Explanation of how and when vulnerabilities identified in the SAR will be addressed.
Continuous Monitoring Strategy & Plan:
- A strategy for ongoing monitoring of security controls.
- Includes the frequency and methods of testing, roles and responsibilities, and reporting requirements.
Training: Ensure all personnel have adequate security training.
Implement NIST Security Controls: Implement the security controls specified in NIST Special Publication 800-53, based on the system’s impact level (Low, Moderate, or High).
Third-Party Assessment Organization (3PAO):
- Engage a 3PAO to perform an independent assessment of your security controls and provide an objective SAR.
Authorization Package: Submit the package to the appropriate governing body (Joint Authorization Board (JAB) or an agency) for a Provisional Authorization to Operate (P-ATO) or an Authorization to Operate (ATO).
Incident Reporting: Establish a process for reporting security incidents to FedRAMP and other relevant agencies within specified timeframes.
Continuous Monitoring: Commit to ongoing monitoring and regular reporting of security control effectiveness.
FedRAMP Package Repository: Utilize the secure repository to submit documentation and updates.
Periodic Assessments: Undergo periodic reassessment (typically every three years) to ensure ongoing compliance.
Engage with FedRAMP PMO (Program Management Office): Ensure open communication with the PMO and adhere to guidance and feedback.
Policies and Procedures: Establish and maintain comprehensive security and privacy policies and procedures in line with NIST and FedRAMP requirements.
Role-based Training: Ensure training is provided to staff based on their role within the organization and relevant to the cloud service offering.

It’s worth noting that FedRAMP compliance can be complex and requires significant commitment. This checklist is a high-level overview, and each item involves numerous sub-tasks and detailed requirements. Depending on the cloud offering and its impact level, certain controls or requirements might differ.

Always refer to official FedRAMP documentation and resources or consult with experts when working towards compliance.

Who should be FedRAMP compliant?

Currently, any cloud service provider (CSP) working with the federal government needs to meet the security assessment, authorization, and continuous monitoring requirements to obtain a Joint Authorization Board Provisional Authority to Operate (JABP-ATO). In July 2018, a bipartisan bill known as the FedRAMP Reform Act of 2018 seeks to increase efficiency for CSPs adopting FedRAMP assessment processes.

However, whether your CSP works with government agencies or not, you may want to adopt the security controls as part of a business plan that helps provide insight and transparency to your customers.

Why do non-CSPs care about FedRAMP?

Cloud computing is the wave of the future. As evidenced by IBM’s purchase of Red Hat for $34 billion, hybrid cloud services are the current long game for managing, analyzing, and leveraging data. These services remain a primary target for hackers. Supply chain attacks increased by 200% in 2017 and will likely continue to grow. Your CSP may be the weakest link in your supply chain. FedRAMP compliance can enable you to control your business information system solutions better.

Why FedRAMP is more secure than FISMA

The Federal Information Security Management Act (FISMA) guidelines can be used to review cloud services’ security controls. The Federal Information Procession Standard (FIPS) 199 ranks information based on the impact a vulnerability or breach has on your information system infrastructure. The FIPS 200 used by FISMA outlines minimum security control requirements. Finally, FISMA applies baseline security controls described in that National Institute of Standards and Technology (NIST) publication 800-53.

These controls sound great but come with a few problems FedRAMP solves.

FedRAMP focuses specifically on security elements unique to CSPs.
FedRAMP security controls go beyond the NIST baseline requirements.
FedRAMP requires a third-party assessment organization (3PAO) to certify the security controls.

If you’re a cloud services provider or someone seeking to engage a CSP in enabling business operations, these additional information security protections focus on threats specific to Infrastructure-as-a-Service (IaaS) providers.

How to Manage FedRAMP Requirements

Since FedRAMP was initially intended to govern CSPs working with federal information, much of which may be classified, the requirements may feel burdensome. However, with CSPs increasingly targeted by hackers, these requirements protect anyone using a FedRAMP certified CSP. Although FedRAMP released a “Tips and Cues Compilation,” below is an easy to review the summary of the most critical steps to compliance.

Continuous Monitoring

Address every vulnerability found in your continuous monitoring program

Remediate the vulnerability. Establish a Deviation Request Process. Justify findings as “Vendor Dependency” and establish 30-day vendor contact timetable.

Align monthly monitoring scans and Plan of Action & Milestones (POA&M) to sync with your patch management program to report only real vulnerabilities not ones already scheduled for remediation.

Security Controls

Review for commonly overlooked or insufficiently answered controls.

When reviewing the “Implementing Configuration Settings (CM-6)” make sure to identify all system components requiring configuration management, individuals responsible for configuration, how responsible part configures, any additional FedRAMP requirements included, and where you saved the documentation.

Review for common missed or neglected FedRAMP or NIST requirements

Not identifying portals, lacking multi-factor authentication, non-segregation of customers, high vulnerabilities detected during testing, unclear authorization boundaries, incomplete or poorly defined policies and procedures are all examples of common documentation problems.

General Program

Communicate with your FedRAMP Information System Security Officer (ISSO) or government liaison.
A Cloud Service Offering (CSO) must be approved and granted FedRAMP Provisional Authorization to Operate (P-ATO) or Agency ATO before leveraging security controls.
Use NIST SP 800-53 Revision 1 Contingency Planning Guide for Federal Information System Appendix B to create a Business Impact Analysis
If you are a moderate impact CSP and want to want to move into Law Enforcement, Emergency Services, Financial Systems, Health Systems, or any other high impact category, you should review the Categorization Change Form Template first.

Readiness Assessment Report (RAR)

Always send an email notification to info@fedramp.gov when submitting a RAR or RAR update or authorization package to ensure review.

Security Assessment Plan (SAP) & Security Assessment Report (SAR)

If 3PAO validates/determines a finding a “False Positive” ensure that the JAB also approves those findings otherwise, they must be added to the Continuous Monitoring (ConMon) POA&M.
3PAO vulnerability scanning includes reviewing tools for configurations, ensuring scans meeting FedRAMP requirements, overseeing and monitoring scans, describing and executing procedures.
Penetration testing tools must be in the SAP and match the Penetration Test Plan document.
Document False Positives or corrected findings with specific items of evidence such as screenshots or scan files, list by file name, and include with the SAR.
Assign unique Vulnerability Identifiers and ensure previously documented vulnerabilities are not assigned new identifiers.

System Security Plan (SSP)

Security requirements for each control include a description of the solution, how it meets security control requirement, responsible parties, how often reviewed, who reviews, what triggers reviews, documentation of reviews, proof of review, any policies referenced as implementation reasons.
Review “Security Procedures” to include all steps for users, system operations personnel, or others. FedRAMP notes the following examples of procedures:

How ZenGRC Enables FedRAMP Documentation

FedRAMP compliance requires more than a single security policy. The detailed control narratives and the wide array of 3PAO documentation necessary for establishing certification often hinder the process. Organization can streamline your process. Moreover, communication within your organization can help develop efficient reporting lines when multiple parties are responsible for different contingencies and controls.

Our compliance dashboards act as a “single source of truth” showing data and metrics that allow you to determine whether your controls align with regulatory requirements or whether you have compliance gaps.

With task prioritization, you can assign, audit, and track issues to stay on top of vulnerability management.

Using the SaaS platform, you can gather evidence more rapidly to streamline the audit process.

For more information about ZenGRC’s ability to ease your compliance stress, contact us for a demo today.

NIST and FedRAMP: A Brief Overview

Libby Bevin · June 8, 2023 ·

If you are new to the U.S. government’s rules for federal government contractors, there can be a host of tricky compliance terms to navigate. So here is a quick primer on two of the most important terms a CISO is likely to encounter: NIST and FedRAMP.

NIST Background

The National Institute of Standards and Technology (NIST) produces standards and risk assessment frameworks for a wide range of subjects, including cybersecurity. These documents typically take the form of Special Publications (SP).

For example, the NIST SP 800 series deals with computer security. Specifically, NIST 800-53 Revision 4, Security and Privacy Controls for Federal Information Systems and Organizations, details the security and privacy controls that must be in place for information systems in the U.S. government.

Other publications in the SP 800 series cover issues such as including risk management (SP 800-37 and SP 800-30,) and business continuity planning (SP 800-34).

Why Is NIST Important?

The Federal Information Security Management Act of 2002 (FISMA) and Federal Information Security Modernization Act of 2014 (also called FISMA, and which updates the original law) require U.S. government agencies to implement information security controls using a risk-based approach to information security and cybersecurity assessment. Each agency must report its compliance annually to the Office of Management and Budget (OMB) — and the primary framework used for FISMA compliance is detailed in NIST SP 800-53.

In other words, to be a government contractor, your business must comply with NIST standards to meet annual FISMA compliance requirements. In addition, contractors managing IT systems on behalf of government agencies may also be required to report their compliance with FISMA and other security standards, such as the PCI-DSS standard for protecting credit card data.

How FedRAMP Enters the Compliance Picture

The Federal Risk and Authorization Management Program (FedRAMP) helps U.S. government agencies to reap the benefits of cloud services while minimizing duplicative information security work. It essentially serves as a seal of approval for cloud service providers (CSPs); when a CSP meets FedRAMP standards, federal agencies can use that CSP without the exhaustive due diligence and testing that might typically happen.

CSPs offer cloud products, such as IaaS, PaaS, and SaaS, for sale to the government. These systems must meet the requirements of FISMA; FedRAMP provides a way to streamline the security and risk assessment process for maximum efficiency, so organizations can engage in a cloud-first strategy.

FedRAMP relies on several of the NIST SP documents, including 800-53 as a library of system controls and 800-37 for risk management. The streamlining occurs with a focus on which controls the CSP manages and which are managed by the agency purchasing the cloud services.

For example, a SaaS provider will offer the same shared physical security protections to all users due to the use of a single data center or hosting facility, leading to a low risk for these users. Conversely, each acquiring agency is responsible for implementing appropriate password controls which are sufficiently secure.

A CSP that wants to sell services to the U.S. government must identify which controls are relevant to the services the CSP is selling, and then engage a qualified third-party assessment organization (3PAO) to conduct a risk assessment. Once this assessment has been conducted on behalf of one government agency, other agencies may rely on the report of that assessment without having to conduct their own — saving time and money.

How Are NIST and FedRAMP Connected?

NIST provides standards and guidelines around risk management, information security, and privacy controls for information systems used by the U.S. government. FedRAMP employs the NIST guidelines to enable U.S. government agencies to use cloud services securely and efficiently.

In other words, if you’re a cloud service provider and want to bid on government contracts, you must comply with NIST standards so that you can be part of the FedRAMP program and have a much easier time offering your services to U.S. government customers.

While NIST and FedRAMP compliance are not required for private organizations that don’t bid on federal government contracts, following those standards is still a wise idea for any organization that wants to take a smart approach to cloud-based services and cybersecurity.

Manage NIST and FedRAMP Compliance with RiskOptics

RiskOptics makes managing both NIST and FedRAMP compliance pain-free. The RiskOptics ROAR Platform has FedRAMP and NIST SP 800-53 controls pre-loaded, so you can leverage existing work from compliance with other regulations to get FedRAMP compliant. You can also prepare evidence for your 3PAO quickly and more easily with the audit module.

To learn more about managing NIST and FedRAMP controls in our comprehensive risk management platform, schedule a demo today.