How to achieve FedRAMP Compliance?

Before the establishment of FedRAMP, the U.S. government’s approach to cloud security was inconsistent and inefficient, leading to increased risks to national information. The introduction of the FedRAMP framework in 2011 aimed to provide a standardized approach to cloud security practices and ensure secure cloud deployment by agencies, emphasizing FedRAMP compliance.

Ever since, the FedRAMP program has undergone many changes since its inception, incorporating stakeholders’ feedback and accelerating the framework’s adoption. Currently, there are 300+ FedRAMP-authorized cloud service offerings. 

Read on to learn more about FedRAMP compliance, the detailed steps to achieve authorization, and the costs involved.

What is FedRAMP compliance?

Federal Risk and Authorization Management Program or FedRAMP is a U.S. government compliance program that ensures that federal agencies adopt authorized cloud services securely by providing a consistent approach to security and risk assessments.

• FedRAMP was released in 2011 by the Office of Management and Budget (OMB) to ensure standardization of security assessments, authorization, and continuous monitoring of the security of cloud services.
• FedRAMP was a result of the collaboration of four bodies—the National Institute of Standards and Technology (NIST), the Department of Homeland Security (DHS), the Department of Defense (DoD), and the General Services Administration (GSA).
• The Chief Information Officers (CIO), DHS, DoD, and GSA are government agencies that form the Joint Authorization Board (JAB). The JAB sets FedRAMP requirements and authorizes cloud service providers (CSPs) that meet NIST standards and ensure cloud security.
• FedRAMP follows a ‘do once, use many times’ approach. FedRAMP-authorized CSPs can use the authorization to unlock better contracts from federal agencies.

Why is FedRAMP compliance important?

FedRAMP compliance is important because it ensures that sensitive government information is only stored or processed by cloud service providers that adhere to stringent security requirements. It streamlines the cloud adoption process and ensures that only FedRAMP-authorized CSPs get to work with federal governments.

The compliance framework also ensures CSPs follow uniform security practices and minimizes the chances of any threats or attacks. Additionally, CSPs do not have to undergo multiple compliance assessments to work with agencies, and they can leverage the FedRAMP assessment to demonstrate compliance repeatedly.

What are the key steps for achieving FedRAMP compliance?

The FedRAMP compliance process is executed in phases. In short, it begins with preparing documents and conducting a gap analysis, followed by assessments and authorization.

Here are the six steps to achieving FedRAMP compliance requirements:

1. Determine the authorization path

The first step is determining the authorization path based on your organization’s goals. There are two authorization approaches to consider:

• Agency Authorization (A.A.)

If you are looking to work with a single federal agency because the demand for your product is very industry-specific, you can opt for Agency Authorization. In this case, the individual agency takes the authorization responsibility and grants an ATO (Authorization to Operate) if the organization meets the FedRAMP requirements.

• Joint Authorization Board (JAB)

If you want to work with multiple federal agencies, then you must choose the JAB path. This is a more comprehensive path where a FedRAMP-accredited Third-party Assessment Organization (3PAO) conducts security assessments which the JAB then reviews. If the CSP meets the requirements, the JAB grants Provisional Authorization to Operate (P-ATO).

2. Gather initial documents 

Start compiling the preparation phase documents such as System Security Plan (SSP), Vulnerability scans, Plan of Action and Milestones (POA&M) etc. You can find these document templates on the FedRAMP official website. If required, conduct an initial gap assessment to have a fair idea of areas that need to be addressed and to prepare the action plan.

3. Determine baseline controls to be implemented

For this step, you must undergo the FIPS 199 Assessment (Federal Information Processing Standard, known as the Standards for Security Categorization of Federal Information and Information Systems). You will have to determine the information systems to be assessed along with the impact levels.

There are three information system impact levels:

• Low Impact: According to the categorization, a system is low impact when the compromise of confidentiality, integrity, and availability does not have a severe effect on the agency’s operations, assets, or individuals.
• Moderate Impact: An information system is categorized as moderately impactful when the compromise of confidentiality, integrity, and availability can have serious effects on the agency’s operations, assets, or individuals.
• High Impact: High-impact systems are those where the compromise of confidentiality, integrity, and availability can have a disastrous impact on the agency’s operations, assets, or individuals. For example, an information compromise that can hurt national security.

Based on the categorization, control implementation is decided and is the most stringent for high-impact systems. For example, high-impact systems require 400+ controls, while low-impact ones require only 100+ controls. These baseline requirements are based on NIST 800-53 and grouped under the following control domains:

SL No.	Control domain	Control implementation examples
1.	Access control	Access Policy and procedures, Account Management, Separation of duties, device lock etc.
2.	Awareness and Training	Role-based training, training records etc.
3.	Audit and Accountability	Event logging, audit record review, analysis and reporting, time stamps etc.
4.	Security Assessment and Authorization	Control assessments, Plan of Action and Milestones etc.
5.	Configuration Management	Baseline Configurations, internal system connection authorization etc.
6.	Contingency Planning	Contingency plans, Alternate storage, System backups etc.
7.	Identification and Authentication	Multi-factor authentication, identifier management, Identity proofing etc.
8.	Incident Response	Incident response policy and procedures, incident response training, incident handling etc.
9.	Maintenance	Automated maintenance activities, Nonlocal maintenance etc.
10.	Media Protection	Media access, Media storage, Media sanitization etc.
11.	Physical and Environmental protection	Physical Access Authorization, Monitoring physical access, Visitor access records etc.
12.	System Security Planning	System Security and Privacy Plans, Security and Privacy Architecture etc.
13.	Personnel Security	Personnel screening, Access agreements, position description etc.
14.	Risk Assessment	Security categorization, risk assessments, vulnerability monitoring and scanning etc.
15.	System and Service Acquisition	Allocation of resources, System development life cycle etc.
16.	System and Communications Protection	Separation of System and User functionality, security function isolation etc.
17.	System and Information Integrity	Flaw remediation, System monitoring etc.

For more details on the controls, you can visit the FedRAMP controls link.

4. Begin with assessments

For the assessment stage, in the case of Joint Authorization Board, a readiness assessment report (RAR) is issued first to provide an initial assessment of the service offerings. This is not mandatory for Agency Authorization but is usually preferred as a best practice to identify gaps early.

After the RAR, the FedRAMP-accredited 3PAO (Third-party Assessment Organization) conducts a security assessment of controls and issues a Security Assessment Report (SAR). The report contains findings and feedback on CSO’s compliance with requirements. For agency authorization, the CSP can hire an accredited independent assessor to issue the SAR.

5. Obtain authorization

After completing the remediations, it is required to submit the SAR along with other documents (SSP, POA&M, etc.) to the agency or JAB for evaluation. If everything is per the requirements, an Authority to Operate (ATO) is issued from the agency or a Provisional Authorization to Operate (P-ATO) from the JAB.

6. Continuously monitor

Once an authorization is received, it’s important to monitor controls and the risk surface to maintain compliance. Evidence will also have to be submitted for periodical continuous monitoring, vulnerability assessments, security status reports, etc.

You can employ continuous compliance tools such as Sprinto that provide you with real-time updates of the compliance status on the health dashboard. In case of any deviations, instant alerts are triggered and you receive notifications for proactive remediation.

How much does FedRAMP cost?

FedRAMP costs can range from $450000-$2million+ including pre-certification, certification, and post-certification costs.

Here is what the different cost components include:

• Pre-certification costs include expenses on gap assessments, training, documentation preparation, and consultations if required.
• Certification costs include costs of baseline control implementation and third-party assessment costs.
• Post-certification costs include ongoing monitoring costs and costs of any improvements.

Usually, the estimates are as follows:

• Gap analysis: $50k- $75k+
• Documentation (SSPs, policies, and procedures etc.): $150k-$200k
• 3PAO assessments: $150k-$250k+
• Control implementation: $25k-$150k+
• 3PAO annual assessments: $75k-$125k
• Ongoing monitoring and maintenance: $25k-$40k

Note: These costs are only estimates and can vary based on project scope.

FedRAMP requires you to have an agency sponsor to get through the authorization process, and the sponsorship can cover a major chunk of these costs. The CSP, however, has the ultimate responsibility of funding the process.

It is important to note that the costs of Fedramp compliance can vary depending on several factors, such as:

• Nature and size of the CSP
• Authorization path chosen
• Impact level of information systems
• Current security maturity of the organization and security enhancements required
• Resources and expertise available
• Choice of consultant or automation tool etc.

How does FedRAMP compliance differ from other security certifications?

FedRAMP is often compared to NIST, ISO 27001, SOC 2, and FISMA because all these frameworks aim to protect sensitive information or ensure information security. However, there are differences in scope, audience, and other aspects.

Let’s look at the key differences among these compliance standards:

• FedRAMP vs NIST: The FedRAMP standards focus more on CSPs working with federal agencies and include controls based on NIST 800-53 that revolve around secure cloud services. NIST, on the other hand, is a broader framework with guidance applicable to CSPs and other businesses of various sizes and industries.
• FedRAMP vs ISO 27001: ISO 27001 is an international Information Security Management System (ISMS) standard that provides broader information security guidance for all organizations. FedRAMP focuses on information system security only for CSPs offering services to federal agencies. Also, ISO 27001 is a voluntary standard, but FedRAMP is not.
• FedRAMP vs SOC 2: The SOC 2 standard is voluntary and applies to service organizations, including cloud providers. It does not prescribe specific controls to maintain customer data’s security, availability, confidentiality, privacy, and processing integrity. FedRAMP is mandatory for cloud computing services used by the U.S. government and requires CSPs to implement controls based on NIST 800-53.
• FedRAMP vs FISMA: FISMA applies to all federal agencies and requires security for all of their information systems. FedRAMP, on the other hand, is more focused on the security of federal agencies’ cloud environments and has specific control implementation requirements.

What are the challenges associated with achieving and maintaining FedRAMP compliance?

The FedRAMP guidelines are comprehensive, the documentation is intensive, and there are stringent continuous monitoring requirements. The assessments are meticulous, making implementation complex.

The challenges associated with achieving and maintaining FedRAMP compliance include:

Complex requirements

The FedRAMP requirements are stringent and complex to understand, with hundreds of security controls to be implemented and detailed documents to be maintained. Third-party assessment organizations and other stakeholders are involved, and requirements are continuously updated, making things challenging.

Resource constraints

Achieving FedRAMP compliance is the initial step, but maintaining it is a long-term project that requires dedicated resources. Compliance efforts require technical experts, a budget for new tools and initiatives, the setting up of continuous monitoring mechanisms, and much more. Such a scenario can be particularly demanding, especially for small businesses with limited financial means.

Team collaboration and culture

FedRAMP compliance requires cross-functional collaboration and many cultural changes to add new layers of security and ensure robust defenses. If the organization is used to working in silos, this can create resistance from employees and make it hard to communicate and implement policy changes or new initiatives.

Ongoing monitoring requirements

The FedRAMP ConMon (Continuous Monitoring) requirements are equally demanding. CSPs must submit regular vulnerability scan reports, maintain baseline controls, remediate vulnerabilities within a specific timeframe and more. This requires dedicated resources and the right selection of tools. 

Third-party dependencies

CSPs that depend on vendors or third parties for any of their offerings are required to ensure that they are FedRAMP compliant. If the dependency is on too many vendors, it can be hard to ensure and manage that every vendor is meeting the requirements.

What are the benefits of FedRAMP compliance for Cloud Service Providers?

FedRAMP compliance enables CSPs to build market credibility, enhance their security posture and win government clients. Here are the benefits of FedRAMP compliance for CSPs:

Risk minimization

FedRAMP compliance ensures standardized security requirements are implemented, there is continuous monitoring of services for any threats, and robust defenses to manage any incidents. All these measures ensure that CSPs uphold the highest standards of security and minimize any risks to government information.

Competitive advantage

FedRAMP authorization enhances trust in the Cloud Service Offerings (CSO) by CSPs and builds positive public perception. This is because it uses the NIST and FISMA standards to implement controls. The compliance status serves as a reputation builder and enables them to confidently scale their federal business footprint.

No repetitive assessments

FedRAMP compliance is a one-time effort that CSPs can repeatedly leverage. They do not have to undergo multiple assessments each time they want to work with a new federal agency, and this saves time, costs, and room for strategic activities.

Smooth collaborations

FedRAMP compliance paves the way for smooth collaborations across multiple agencies wanting to work with secure CSPs. More access to the federal market also brings more integration across other federal programs, enhancing opportunities and business growth.

What are the consequences of non-compliance with FedRAMP requirements?

Non-compliance with FedRAMP requirements can cause business disruptions. But there are other repercussions of FedRAMP non-compliance such as:  

Loss of federal contracts

Federal agencies are required only to use cloud services that meet FedRAMP requirements. Non-compliance can trigger serious investigations for the CSPs and the loss of current and future agency contracts.

Fines and penalties

Non-compliance can also attract legal fines and penalties for CSPs. However, no fixed percentage or amount of penalties can be charged, depending on the severity of the compliance violation.

Risks of security incidents

FedRAMP security requirements are as comprehensive as possible, enabling CSPs to build airtight controls. Non-compliance can mean loose ends in the security fabric and expose information systems to security breaches, threats, and attacks.

Negative public perception

One of the biggest long-term consequences of non-compliance is a bad reputation. Losing trust among clients and partners can lead to loss of opportunities, business disruptions, and slow sales cycles.

Expedite FedRAMP compliance with automation

FedRAMP can be a great one-time investment that can be leveraged multiple times to bag federal contracts. However, the stringency of requirements and rigorous assessments make it a challenging and long-drawn process. Forward-thinking CSPs have therefore started turning towards automated tools like Sprinto to expedite the process and minimize redundant tasks.

Sprinto lets you Bring Your Own Framework (BYOF) to the platform and enable seamless implementation with adaptive automation capabilities. It integrates with your tech stack, enables you to map the right controls to the framework, and runs automated checks to ensure you are always on track. The platform comes with integrated risk management, policy templates, and advanced training modules to help you expand the scope of compliance programs.

Talk to an expert today and kickstart your compliance journey.

FAQs

What are FedRAMP security levels?

FedRAMP security levels are also known as impact levels and are categorized as:

• Low impact
• Medium impact
• High impact 

The categorization is based on the severity of the impact that compromised confidentiality, integrity and availability would have on the organization’s operations, assets and people. Systems with more adverse effects are classified as high-impact systems, while those with less effect fall under low-impact security level.

How much time does it take to achieve FedRAMP certification?

The FedRAMP certification can take anywhere from 9-18 months, depending upon your preparation and the scope of the project. Usually, the timeline is as follows:

• Preparation (gap analysis, documentation): 1-3 months but can extend to 6 months
• Security Assessment: 4-6 months usually but can extend to 9 months
• Remediation: 1-2 months
• Review: 2-3 months
• FedRAMP Authorization process: 1-2 months

What are the different FedRAMP marketplace designations?

There are 3 different FedRAMP marketplace designations:

• FedRAMP Ready: FedRAMP Ready indicates that the CSP has undergone a readiness assessment which has been approved and reviewed by FedRAMP PMO (Program Management Office and the CSP is ready to begin the full assessment process by 3PAO.
• FedRAMP in process: FedRAMP in process indicates that CSP is undergoing the authorization process and is working with JAB or an agency for the same. The CSP might be undergoing a full security assessment or under the review stage in this case.
• FedRAMP Authorized: FedRAMP Authorized indicates that the CSP has completed the FedRAMP requirements and has successfully gone through the authorization phase. Once authorized, it can start offering services to the federal agencies.