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.
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