Cloud service providers (CSPs) that want to work in the federal government sector must obtain FedRAMP certification. FedRAMP certification benefits small and large CSPs because it boosts security, increases efficiency, and offers the opportunity to do business with U.S. government agencies.
The Federal Risk and Authorization Management Program (FedRAMP) is a government-wide program in the United States that acts as a seal of approval for CSPs’ cloud products and services. FedRAMP certification deems if services are secure enough to be used by federal agencies, rather than each agency performing its own assessments.
The FedRAMP program was established in 2011 to provide a standardized approach to security assessments, authorization, and continuous monitoring for cloud products and services. CSPs that offer software-as-a-service (SaaS) solutions are reviewed by third-party assessment organizations (3PAOs) to certify if the vendor meets the program’s security requirements.
To maintain FedRAMP compliance, a CSP must monitor and assess its security controls regularly and demonstrate that the security of its cloud service offering continues to meet FedRAMP standards.
What Is FedRAMP?
The Federal Risk and Authorization Management Program, or FedRAMP, harmonizes the security evaluation and authorization processes for cloud services used by federal agencies in the United States.
The goal of FedRAMP is to assure 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 need to follow. Needless to say, understanding FedRAMP is no easy task.
Why Is FedRAMP Certification Important?
Being FedRAMP compliant is required for any cloud services that store federal data. This means that FedRAMP authorization is vital for your security plan if you wish to engage with the federal government. FedRAMP compliance requirements are outlined in the NIST 800-53 security framework, the gold standard in security.
FedRAMP is essential because it assures that the government’s cloud services are safe and that security is continuously examined and maintained. It also creates a uniform set of criteria for all government agencies and cloud service providers to follow.
The FedRAMP Marketplace lists FedRAMP-approved cloud service providers. When federal government agencies want a new cloud solution, they first look to this marketplace. Consequently, using a product that has already been authorized is substantially more accessible and faster for an agency than starting the approval process with a new cloud provider.
You’re far more likely to do more business with government agencies if you’re listed in the FedRAMP Marketplace. Moreover, FedRAMP certification can also help you advance your business in the private sector because the FedRAMP Marketplace is open to the public. So many private companies searching for a trusted CSP start by checking which vendors are on the FedRAMP Marketplace.
Yes, many potential clients might be unaware of FedRAMP, but many larger businesses know about FedRAMP, especially if they do business with the federal government themselves. Lacking FedRAMP certification could become a deal-breaker as you try to close business with more mature companies.
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 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, 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 suitable 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, granting 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 small number of federal agencies.
To decide which type of security authorization is suitable for a particular cloud service offering, the CSP should 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 different impact levels: low, moderate, and high. These levels refer to the severity of a potential impact if an information system is jeopardized. 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 that the U.S. government has carefully vetted.
FedRAMP Certification Best Practices
There are a series of recommended practices for demonstrating maturity and increasing the chances that an Authorizing Official (AO) will approve your development security strategy.
Select and Implement Technical Security Controls
The Authorizing Official (AO) will review your offering closely, seeking grounds 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.
Even if you’re attempting to keep development outside the FedRAMP permission boundary, you should implement as many technical FedRAMP restrictions as possible to demonstrate maturity. For example, consider scanning your entire infrastructure, implementing tight access control and multi-factor authentication, logging, and security monitoring.
Pipeline Security for CI/CD
Demonstrating maturity is crucial for firms using a modern continuous integration continuous deployment (CI/CD) software development method.
In theory, CI/CD systems should improve and simplify security by incorporating automated testing early in the development process. 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 the utility of CI/CD methodologies. Development teams may help AOs be more comfortable with this software development and deployment approach by demonstrating increased security maturity across the entire 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 even 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 both your infrastructure and your code.
Postponing Development Deployments to Federal Clients
Many CSPs feel 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. Code is run and scanned at least once a month before deployment to the government 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, be sure to apply security patches to both environments as soon as they become available.
Manage FedRAMP Compliance With Reciprocity ZenComply
Officials from the Defense Department have stated that the objective of FedRAMP certification is to keep compliance costs low. ZenComply software can help ensure compliance with many complicated cloud security standards and frameworks cost-effectively and smoothly.
ZenComply 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.
ZenComply organizes and archives all relevant documentation, making it simple to locate when it is time for internal and external audits.
Schedule a demo today to see how ZenComply can help you achieve “Zen-mode” compliance!
