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

  • 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!