75% of businesses say that cloud security is one of their top concerns. It makes sense: cloud protections may not seem as strong as old-fashioned ones, such as paper filing or on-site data storage. However, new regulations have made cloud systems and storage stronger than ever, particularly in the public sector. In this article, we'll discuss FedRAMP (the Federal Risk and Authorization Management Program) and how its robust requirements help government entities and non-profits maintain data security.
What Is FedRAMP?
FedRAMP is a government-wide initiative to provide a regimented approach to security assessment, authorization, and continuous monitoring for cloud systems used by federal agencies. It was founded in 2011 and signed as part of the FY23 National Defense Authorization Act (NDAA) in December of 2022. FedRAMP is codified as the authoritative regularized approach for security in cloud computing products that handle unclassified federal information.
Before FedRAMP was enacted, each federal agency had different requirements for cloud service providers. This caused providers to have to secure multiple authorizations, which wasted time and money. Now, with FedRAMP, one authorization creates a cloud security package that can be utilized across agencies.
Who Needs FedRAMP?
FedRAMP compliance is required for cloud service providers that work with U.S. federal agencies. This includes:
- Any CSP (cloud service provider) that offers services to federal agencies. This includes third-party vendors that store, process, or transmit federal data.
- Any U.S. federal government agency that requires a cloud solution. FedRAMP-authorized cloud services must be implemented for cloud-based IT at low-impact levels or higher.
- Any organization handling federal data. This includes government contractors, companies supporting government programs, and government staffing firms, among others.
- Any software vendor offering solutions to the government. This includes SaaS (software as a service), IaaS (infrastructure as a service), or PaaS (platform as a service) solutions.
There is a difference between mandatory and voluntary FedRAMP adoption. Mandatory FedRAMP adoption is for executive agency cloud deployments and service models at the Low, Moderate, and High-risk impact levels and the cloud service providers that deliver them. Voluntary FedRAMP adoption is for private sector organizations, state and local governments, non-executive agencies, and commercial off-the-shelf (COTS) providers who want to align their security practices with the federal government as a best practice.
What Is FedRAMP Compliance?
FedRAMP Compliance is the list of requirements that the federal government demands of cloud products and services used by federal agencies. These requirements prove that cloud service providers are committed to utilizing the highest security standards when handling federal data.
The key components of FedRAMP compliance are:
- Standardized Security Controls: FedRAMP security requirements are based on controls and processes gleaned from NIST SP 800-53 guidelines.
- Impact Levels: Cloud services are sorted into Low, Moderate, or High impact levels based on data sensitivity.
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Authorization Process: Cloud Service Providers (CSPs) must undergo a rigorous authorization process gained from:
- Agency Authorization: Resulting in an Authorization to Operate (ATO) (specific to one agency)
- Joint Authorization Board (JAB): Resulting in a Provisional Authorization to Operate (P-ATO)13 (government-wide applicability)
- Continuous Monitoring: Once authorized, CSPs must maintain ongoing security assessments, such as vulnerability scanning, security control assessments, and change management.
- Documentation: CSPs must compile and maintain comprehensive documentation, including a System Security Plan (SSP) and other required FedRAMP documents.
- Third-Party FedRAMP Assessment: An accredited Third-Party Assessment Organization (3PAO) conducts independent security assessments. This is sometimes referred to as a FedRAMP audit.
What Is FedRAMP Certification?
FedRAMP certification is a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services used by U.S. federal agencies. FedRAMP certification is more accurately referred to as FedRAMP Authorization, and it's the formal approval granted to a CSP after completing all the necessary steps to prove compliance with FedRAMP requirements.
Organizations that need to be FedRAMP certified include:
- Cloud Service Providers offering cloud products or services to U.S. agencies.
- Federal agencies that operate at low, moderate, and high-risk impact levels.
- Companies that handle federal data (not all; this varies depending on the data).
- Contractors and subcontractors that use cloud services to process, store, or share federal information (not all; this varies depending on the data).
- Third-party service providers that offer services built on FedRAMP-authorized infrastructure (this depends on their service model).
Why Is FedRAMP Required?
FedRAMP is required because the federal government needs to protect sensitive data across agencies, and this is the streamlined way to do so. FedRAMP provides a standardized approach to government cloud security, assessment, authorization, and continuous monitoring, ensuring that all federal agencies remain secure.
Risk management is necessary for any cloud service, and FedRAMP reduces the risk of data breaches and cyber threats for federal information. And it's working: 85% of FedRAMP participants say the program encourages the use of secure cloud services across the government.
Additionally, FedRAMP is required because it modernizes cloud systems in the federal government and saves taxpayers money. It's estimated that the framework saves 30-40% in costs.
What Are the Benefits of FedRAMP?
The benefits of FedRAMP are standardization, providing a uniform approach to security assessment and risk management at federal agencies. It reduces effort on behalf of federal employees, cutting inconsistencies across departments. Additionally, the market access to FedRAMP certification grows the market opportunities for cloud service providers. They can elevate their system and increase appeal by obtaining a FedRAMP certification.
Other benefits of FedRAMP include:
- Increased efficiency
- Cost savings
- Faster cloud adoption
- More transparency between the government and cloud providers
- Better collaboration across the federal government.
What Is FedRAMP Equivalent to?
FedRAMP is equivalent to other security frameworks, such as ISO 27001, HITRUST CSF, and DoD Provisional Authorization. ISO 27001 is the most-known global standard for security management systems, providing companies of any size with a guide to establish, utilize, regularly use, and update cloud security.
HITRUST CSF is the standard from the Health Information Trust Alliance for managing data securely for healthcare systems. It leverages over 50 data and security privacy regulations, such as HIPAA compliance and NIST, for high-level security.
The DoD Provisional Authorization is a specific requirement for cloud security for the Department of Defense. It's similar to FedRAMP but has additional security requirements based on the needs of the Department of Defense.
FedRAMP vs. SOC 2
While people often compare FedRAMP and SOC 2, they have different security standards. They are both compliance frameworks for security, but they have different target markets. FedRAMP is for cloud service providers working with federal agencies, while SOC 2 is applicable to a wide range of organizations. FedRAMP is more extensive, with 325 security controls for moderate impact and 421 for high impact systems. SOC 2 is based upon the five trust services criteria, with only security required.
What Is FedRAMP Ready?
FedRAMP Ready is granted to cloud service providers after successfully completing a Readiness Assessment with an accredited Third-Party Assessment Organization (3PAO). This status indicates that a CSP's cloud service offering (CSO) has been assessed for its capability to meet federal security requirements as outlined by FedRAMP.
CSPs can achieve FedRAMP Ready designation by undergoing the assessment process and submitting the Readiness Assessment Report. Once that's done, the FedRAMP program management office (PMO) reviews the report and either grants the company or doesn't. If approved, they will be deemed as "FedRAMP Ready" for a full calendar year. After that, they need to resubmit documentation to be reviewed again.
Some of the benefits of being FedRAMP-ready are:
- Gains a listing in the FedRAMP marketplace, increasing visibility.
- Creates a competitive advantage when a CSP responds to a government RFP.
- Helps companies better understand full authorization for FedRAMP.
What Is FedRAMP Authorized?
FedRAMP authorization is granted to cloud service providers that have completed all security assessments and have been granted either an Authority to Operate by a federal agency or a Provisional Authority to Operate by the Joint Authorization Board. FedRAMP authorization is important because it proves that a CSP has completed all the security assessments and is safe to use within a federal agency.
FedRAMP Ready only covers one-third of the control required for a FedRAMP moderate impact assessment. It's natural for a company to first be FedRAMP Ready and then work toward full FedRAMP authorization. To move from FedRAMP Ready to FedRAMP Authorized, the company must undergo the security authorization process, which includes the full security assessment and agency authorization process.
How to Get FedRAMP Certified?
Cloud Services Providers can get FedRAMP certified in 12-18 months by completing the following five steps:
- Pre-Assessment and Planning (3-6 months): The CSP must study FedRAMP standards and conduct a gap analysis, prepare necessary documentation (including system security plan), and then select an accredited Third-Party Assessment Organization (3PAO) from the FedRAMP marketplace.
- Security Assessment (6-9 months): The 3PAO must review and test security controls, conduct a penetration test and red team exercise (for Rev 5 assessments), and then the CSP must address any security gaps or shortcomings identified.
- Authorization Package Submission: Finalize the Security Assessment Report (SAR) and then submit the authorization package to the sponsoring agency and FedRAMP PMO.
- Agency Review and PMO Review (2-6 months): The sponsoring agency reviews the SAR package, and the FedRAMP PMO conducts a detailed technical review. The CSP must revise the SAR based on feedback and resubmit if necessary
- Continuous Monitoring: The CSP must complete ongoing security assessments and monitoring practices and then address any new security requirements or vulnerabilities that pop up.
What Are Common Challenges to FedRAMP Certification?
Common challenges to FedRAMP certification are a lack of understanding of how the process works, underestimating the dedication required to complete the certification, lack of staff familiar with FedRAMP and secure cloud architecture, and inadequate funding and staffing to handle the certification process.
To overcome issues like this, bring on FedRAMP experienced personnel who have gone through the process before. Additionally, your organization may need to reallocate some budget to ensure there is enough money to handle the certification process. Additionally, your team can focus on looking for an agency sponsor that's likely to benefit from your services, which will keep them more engaged throughout the process.
How Long Does It Take To Get FedRAMP Certified?
It takes 12-18 months for a CSP to get FedRAMP certified. Factors affecting the certification duration include the complexity of the cloud service offerings, the maturity of the documentation of existing security practices, and the experience level of the Third-Party Assessment Organization. Additionally, every CSP should do a pre-planning stage of 3-6 months to gain a deeper understanding of standards, conduct a gap analysis, and prepare the documentation.
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