FedRAMP Guidelines

The U.S. General Services Administration (GSA) runs the Federal Risk and Authorization Management Program (FedRAMP), which standardizes the process of assessing, authorizing, and monitoring cloud computing services that federal agencies use.

The recent surge in cloud-based data breaches has made robust cybersecurity measures crucial for protecting sensitive federal data from malicious actors. FedRAMP Guidelines address this urgent need.

In this blog, you will explore FedRAMP and its benefits, identify organizations that must comply with FedRAMP standards, the three FedRAMP levels, the types of governance bodies, the FedRAMP requirements checklist, and detail the steps to obtain FedRAMP authorization.

Let’s get started!

What is FedRAMP?

The US government's Office of Management and Budget (OMB) formulated FedRAMP, which stands for Federal Risk and Authorization Management Program, in 2011. This framework standardizes the cloud security assessment, authorization, and monitoring process for US federal agencies.

FedRAMP collaborates with the Department of Homeland Security (DHS), the Department of Defense (DOD), and other government agencies. The National Institute of Standards and Technology (NIST) outlined the technical standards for cloud computing in its Special Publication 800-53, and FedRAMP aligns its guidelines with these standards.

Who Needs to Follow FedRAMP Guidelines?

Organizations offering cloud computing services or software-as-a-service (SaaS) applications must prove their system complies with FedRAMP requirements if they want to secure a U.S. government agency as a customer. The standardized language for FedRAMP requirements integrates into every federal government contract.

To sell the system to a federal government agency, organizations must obtain the appropriate authorization for the system. Organization will need to invest considerable effort to successfully navigate the FedRAMP authorization process.

Therefore, organizations should familiarize themselves with the FedRAMP authorization process as soon as they decide to pursue federal agencies as customers. However, before the organizations embark on the FedRAMP compliance journey, they ensure that they have a fully developed and functional system, and a leadership team that fully commits to and supports the FedRAMP process.

Benefits of FedRAMP Guidelines

FedRAMP offers numerous benefits for both government agencies and Cloud Service Providers (CSPs):

Benefits for Federal Agencies

• FedRAMP mitigates cybersecurity risks and enhances the security of federal data stored in cloud solutions.

• It promotes safe cloud adoption by establishing a standardized security authorization approach.

• FedRAMP minimizes costs and efforts associated with on-premises data storage, improving operational efficiency.

• It enhances transparency about cloud service provider safety, enabling agencies to make more informed decisions.

• FedRAMP helps agencies meet federal cyber compliance requirements with minimal paperwork.

Benefits for Cloud Service Providers (CSPs)

• FedRAMP fosters CSP growth by expanding horizons and allowing access to the federal market.

• It implements strong security protocols to reduce organizational data breach risks.

• FedRAMP ensures constant compliance with federal security regulations by enforcing regular innovation and enhancement.

• It offers a competitive advantage over other market players.

• FedRAMP builds public credibility and trust by showcasing the CSP as a secure, compliant organization.

Three Types of FedRAMP Levels

FedRAMP authorizes Cloud Service Providers (CSPs) at three impact levels to indicate the scope of service they can provide to federal agencies. These levels define the type of data a CSP is qualified to store and handle.

The three FedRAMP authorization levels are:

1. Low Impact Level

FedRAMP grants this authorization to CSPs when they can store federal data categorized as low impact due to minimal sensitivity and confidentiality.

This includes publicly available data such as names and email addresses. Even if compromised, this data poses little to no risk.

2. Moderate Impact Level

FedRAMP grants this authorization to CSPs when they demonstrate a certain degree of security to store moderately sensitive data not available in the public domain. This includes sensitive information like driver's license numbers and social security numbers. A breach of this data can cause some damage to individuals.

3. High Impact Level

FedRAMP grants this authorization to CSPs when they prove they are well-equipped to handle extremely sensitive and confidential public data, often categorized as high-impact data. This includes classified information that requires authorization access from several federal agents. Due to its high sensitivity, a breach of this data can lead to severe implications, including national security threats.

FedRAMP Governance Bodies

Several key governing bodies structure the program around their successful implementation and ongoing management.

Joint Authorization Board (JAB)

The cornerstone of FedRAMP's decision-making process is the Joint Authorization Board (JAB). This board serves as the primary authority for the program and is composed of the Chief Information Officers (CIOs) from three critical federal agencies: the Department of Homeland Security (DHS), the General Services Administration (GSA), and the Department of Defense (DOD).

The JAB reviews and grants authorizations to cloud service providers, ensuring that they meet the stringent security requirements necessary for government use.

Office of Management and Budget (OMB)

The Office of Management and Budget (OMB) plays a pivotal role in FedRAMP's governance by issuing the FedRAMP policy memorandum. This document outlines the core requirements, capabilities, and expectations for the program, ensuring consistency across federal agencies and establishing the standards that cloud services must meet to achieve compliance.

CIO Council

The CIO Council, representing federal Chief Information Officers, ensures effective dissemination of FedRAMP information across agencies. Through cross-agency communications, events, and collaborations, the CIO Council maintains alignment and understanding of FedRAMP’s objectives and processes among federal stakeholders.

FedRAMP Program Management Office (PMO)

The GSA houses the FedRAMP Program Management Office (PMO), which is responsible for developing and managing the program’s day-to-day operations. The PMO authorizes cloud services, manages the processes involved, and provides ongoing support to both agencies and cloud service providers in navigating the FedRAMP requirements.

Department of Homeland Security (DHS)

The Department of Homeland Security (DHS) oversees FedRAMP’s continuous monitoring strategy. This includes setting criteria for data feeds, managing the reporting structure, coordinating threat notifications, and leading incident response activities. DHS’s involvement ensures that the program maintains security as a dynamic and integral component.

National Institute of Standards and Technology (NIST)

The National Institute of Standards and Technology (NIST) provides essential guidance to FedRAMP, particularly concerning compliance with the Federal Information Security Modernization Act (FISMA).

NIST also contributes to developing accreditation standards for independent third-party assessment organizations (3PAOs), which are critical for maintaining the integrity and reliability of the FedRAMP authorization process.

FedRAMP Requirements Checklist

To achieve FedRAMP (Federal Risk and Authorization Management Program) compliance, cloud service providers (CSPs) must meet several rigorous requirements that ensure the highest level of security for federal information. This includes:

1. System Security Plan (SSP): CSPs must create a comprehensive document detailing the security controls implemented within the cloud service, including policies, procedures, and system boundaries. The SSP must address all relevant control families and include necessary attachments, such as a privacy threshold analysis, incident response plan, and configuration management plan.

2. Security Assessment Plan (SAP): CSPs must outline the approach for testing and assessing the security controls in place. This plan should include procedures for penetration testing, security test cases, and other assessment methodologies. The SAP also needs to detail the scope, timeline, and resources that the assessment process requires.

3. Security Assessment Report (SAR): CSPs summarize the findings from the security assessment, including risk exposure, test case results, and identified vulnerabilities. They use the SAR to inform the Plan of Action and Milestones (POA&M). Additionally, CSPs provide recommendations in the SAR for addressing identified security weaknesses or non-compliance issues.

4. Plan of Action and Milestones (POA&M): CSPs create a roadmap that tracks vulnerabilities, outlines remediation tasks, assigns responsibilities, and sets deadlines for addressing identified risks or gaps. They implement continuous monitoring as a key aspect of the POA&M to ensure security controls remain effective over time.

5. Third-Party Assessment Organization (3PAO) Involvement: A FedRAMP-accredited 3PAO validates and verifies the security controls through independent testing and assessments. This process ensures that the CSP meets all FedRAMP standards before authorization. The independent verification adds an extra layer of credibility and assurance to the compliance process.

Steps to Get FedRAMP Authorized

To achieve FedRAMP compliance, a cloud service provider (CSP) must assess, obtain authorization, and continuously monitor their cybersecurity measures. Understanding FedRAMP compliance and the authorization process is crucial. Here are the fundamental steps to attain FedRAMP compliance:

1. Assemble Initial FedRAMP Documents

Organizations should use available resources, including documents and templates from the FedRAMP site, to initiate the authorization process. After completing the FIPS 199 assessment, organizations will better understand the relevant documents. They should gather initial documents and templates and familiarize themselves with the likely authorization path based on the data.

2. Conduct FIPS 199 Assessment

The National Institute of Standards and Technology (NIST) developed the Federal Information Processing Standard (FIPS 199) to categorize data that cloud computing services store and transmit as low, moderate, or high-impact. This impact level classification determines the controls a CSP must implement.

Most organizations collaborating with federal agencies fall within the "moderate" category. Higher impact levels require more stringent controls.

3. Conduct 3PAO Readiness Assessment

A third-party assessment organization (3PAO) performs a cybersecurity attestation and creates the Readiness Assessment Report (RAR). This step is mandatory for the JAB authorization path and highly recommended for the Agency Authorization path.

Even without a formal 3PAO readiness assessment, conduct some form of readiness and preparation before seeking FedRAMP certification. Identify gaps and prepare action plans in advance to streamline the subsequent steps. Establishing a clear baseline of the CSP's security and risk posture benefits the authorization process.

4. Develop and Implement a Plan of Action and Milestones (POA&M)

NIST SP 800-53 requires agencies and/or CSPs seeking authorization to implement controls addressing known gaps between FedRAMP requirements and the information systems and related controls in scope. Remediate these gaps on a systematic schedule and document all activities.

Document an action plan and timeline for revisiting any identified gaps that organizations cannot address immediately. This demonstrates the organization's dedication to mitigating risks and maintaining compliance.

5. Follow the Agency or JAB Process for Authorization

The FedRAMP authorization process splits into the "Agency Process" or the "JAB Process". The Agency Process leads to an Authorization to Operate (ATO), while the JAB Process results in a Provisional Authorization to Operate (P-ATO).

Under the JAB Process, cloud providers must:

1. Undergo evaluation as part of the FedRAMP Connect process.

2. Be chosen as one of twelve CSOs annually.

3. Conduct a formal Readiness Assessment with an authorized 3PAO.

4. Finalize the System Security Plan (SSP).

5. Undertake a Full Security Assessment with an authorized 3PAO.

6. Address findings from the Security Assessment Report (SAR) issued by the 3PAO.

7. Complete JAB evaluation.

8. Obtain Provisional Authorization to Operate (P-ATO) if accepted.

9. Prepare for continuous monitoring.

In the Agency Process, CSPs collaborate directly with a federal agency to obtain an Authority to Operate (ATO) by:

1. (Optional) Conducting a formal Readiness Assessment with an authorized 3PAO (highly recommended).

2. Fulfilling Pre-Authorization requirements and conducting a Kickoff with the Agency.

3. Undergoing a Full Security Assessment with an authorized 3PAO to assess compliance with FedRAMP's security requirements.

4. Addressing findings from the Security Assessment Report (SAR) issued by the 3PAO.

5. Uploading materials, including the security package to FedRAMP's repository and receiving an Authorization to Operate (ATO) letter.

6. Having FedRAMP PMO review the security package for inclusion in the FedRAMP Marketplace.

7. Preparing for continuous monitoring.

6. Maintain Continuous Monitoring

After obtaining formal authorization (ATO or P-ATO), organizations undergo continuous monitoring, both internally and by the federal agencies they engage with. To maintain FedRAMP compliance, provide evidence that certain key controls are operational on a monthly and/or annual basis, such as through vulnerability scanning and penetration testing.

Leverage automated controls or automate controls where feasible to streamline the continuous monitoring phase. Use the right compliance and risk management technology. For example, schedule vulnerability scans to run at set intervals to eliminate manual initiation or execution.

Final Thoughts

FedRAMP authorization offers CSPs a fantastic opportunity to expand their market and build credibility.

So, if you’re an application security engineer providing cloud solutions, get FedRAMP authorization to strengthen your organization's security against SQL injection and XSS vulnerabilities.

You can also check out Akto, a proactive API security platform with robust features designed to fortify your cybersecurity posture. With Akto's support, you can easily navigate the complexities of achieving and maintaining FedRAMP compliance, helping your organization stand out in an increasingly competitive environment.

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