Learn the almighty FedRAMP

Chue Moua

Jun 16, 2020

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What is FedRamp?

FedRAMP (Federal Risk and Authorization Management Program) is a US government-wide program that provides a standardized approach to security assessment, authorization, and continuous monitoring for cloud services. The goal of FedRAMP is to provide a common security framework to reduce duplication of effort, increase efficiency, and increase the speed of securing cloud-based IT services for federal agencies.

What is the requirement for FedRamp?

To meet FedRAMP requirements, cloud service providers (CSPs) must demonstrate that their services meet specific security controls and standards, as outlined in the Federal Risk and Authorization Management Program (FedRAMP) security control standards. These controls address areas such as access control, incident management, and risk management.

In addition, CSPs must undergo a security assessment by a third-party assessment organization (3PAO) and receive an authorization from a Joint Authorization Board (JAB). The JAB is responsible for granting provisional authorizations for cloud services to be used by federal agencies.

To maintain FedRAMP authorization, CSPs must also conduct continuous monitoring and provide regular reports to ensure that their services continue to meet the security requirements of the program.

In summary, FedRAMP requirements include:

  • Adherence to security controls and standards
  • Third-party security assessment
  • Joint Authorization Board (JAB) authorization
  • Continuous monitoring and reporting.

What types of business needs FedRAMP and why?

You may need FedRAMP if you are a cloud service provider offering services to the federal government, or if you are a federal agency looking to adopt cloud services for processing and storing sensitive government data.

For cloud service providers, FedRAMP provides a standardized approach to security assessment, authorization, and continuous monitoring, making it easier to sell your services to the federal government. By demonstrating that you have met a rigorous set of security standards, you can increase your visibility and competitiveness in the federal marketplace.

For federal agencies, FedRAMP provides assurance that a cloud service provider has met a set of security standards and has been thoroughly evaluated for handling sensitive government data. By relying on FedRAMP authorization, you can save time and resources compared to conducting individual security evaluations for each cloud service you use. This can help you adopt cloud services more quickly and securely, and support your mission by enabling you to leverage the benefits of cloud computing.

Overall, FedRAMP helps to improve the security and compliance of cloud services used by the federal government, and provides a common understanding of security requirements and expectations among cloud service providers, federal agencies, and other stakeholders.

Controls Li-SaaS Low Moderate High
Rev 4 29 125 325 421
Rev 5 66 156 323 410
Net Change in Controls +127% +25% -1% -3%

How do you determine your impact level and security objective?

The FedRAMP security impact level and security objectives for an application are determined by a thorough evaluation of the risks associated with the application and the data it processes. This involves assessing the confidentiality, integrity, and availability of the data, as well as the impact of a potential security breach.

The FedRAMP security impact levels range from low to high, and determine the minimum set of security controls required for a cloud service provider to achieve FedRAMP authorization. The security impact level is a critical factor in determining the overall scope and rigor of the security assessment and authorization process.

The FedRAMP security objectives provide a set of high-level security requirements that must be met by a cloud service provider in order to achieve FedRAMP authorization. These objectives are organized into security domains, including access control, incident management, and data protection, and are designed to ensure that cloud service providers implement robust and effective security controls.

To determine the FedRAMP security impact level and security objectives for your application, you would need to engage in a risk assessment process, typically with the assistance of a FedRAMP-accredited third-party assessment organization. This process would involve evaluating the application, its architecture, and the data it processes, and determining the security controls needed to meet the required level of security. The outcome of this process would be a detailed security assessment report, which would form the basis for the application’s FedRAMP authorization.

The 3 Impact Level

FedRAMP impact levels are a way to categorize the level of security required for a cloud service provider to achieve FedRAMP authorization. The impact levels range from low to high, and determine the minimum set of security controls that must be in place for a cloud service provider to handle sensitive government data.

The three FedRAMP impact levels are:

  1. Low Impact Level: This level is for cloud services that process and store information that is considered low risk to national security, such as public information.
  2. Moderate Impact Level: This level is for cloud services that process and store information that is considered moderate risk to national security, such as information that is sensitive but not classified.
  3. High Impact Level: This level is for cloud services that process and store information that is considered high risk to national security, such as classified information.

The security controls required for each impact level are specified in the FedRAMP security control baseline, which is based on the NIST SP 800-53 security controls. The security controls required for each impact level are designed to ensure that cloud service providers implement a robust and effective security program that protects sensitive government data.

The FedRAMP impact level assigned to a cloud service provider is determined through a risk assessment process and is a critical factor in determining the scope and rigor of the security assessment and authorization process.

o learn more about FedRAMP SP 800-53 controls, click here…

FedRAMP also categorizes covered entities across three security objectives following the Federal Information Processing Standard (FIPS) 199 standards:

  • Confidentiality – Protect personal privacy and proprietary information
  • Integrity – Stored information is guarded against tampering
  • Availability – Reliable access to information at all times.

Understanding the FedRAMP Security Controls

FedRAMP requires cloud service providers to implement a set of security controls that are designed to protect sensitive government data and meet the security requirements of the federal government. These security controls are based on the NIST SP 800-53 security controls and are organized into security domains, such as access control, incident management, and data protection.

Some examples of the types of security controls required by FedRAMP include:

  1. Access Control: Includes controls for managing user authentication, authorization, and access to sensitive data.
  2. Incident Management: Includes controls for detecting, reporting, and responding to security incidents.
  3. Data Protection: Includes controls for encrypting sensitive data in transit and at rest, and protecting against unauthorized access and theft.
  4. Risk Management: Includes controls for conducting risk assessments, managing vulnerabilities, and ensuring that security risks are continuously monitored and addressed.
  5. Continuous Monitoring: Includes controls for ongoing assessment and reporting of the security state of a cloud service, including security incidents and security control effectiveness.
  6. Configuration Management: Includes controls for managing the configuration of systems and applications, and ensuring that security configurations are maintained over time.

These security controls are designed to ensure that cloud service providers implement a robust and effective security program that protects sensitive government data and meets the security requirements of the federal government. The specific set of security controls required for each FedRAMP impact level is specified in the FedRAMP security control baseline.

The 17 families of security controls in NIST SP 800-53 are as follows:

  1. Access Control
  2. Awareness and Training
  3. Audit and Accountability
  4. Configuration Management
  5. Identification and Authentication
  6. Incident Response
  7. Maintenance
  8. Media Protection
  9. Physical and Environmental Protection
  10. Planning
  11. Personnel Security
  12. Risk Assessment
  13. Security Assessment and Authorization
  14. System and Services Acquisition
  15. System and Communications Protection
  16. System and Information Integrity
  17. Telework

Each of these 17 families contains a set of security controls and guidelines that organizations can use to implement and maintain a secure information technology system. The specific set of security controls required for each FedRAMP impact level is specified in the FedRAMP security control baseline, which is based on the NIST SP 800-53 security controls.

Why use a GRC System for your FedRAMP initiative?

A Governance, Risk, and Compliance (GRC) system can be useful for organizations pursuing FedRAMP certification for several reasons:

  1. Automation: GRC systems can automate many of the manual processes involved in the FedRAMP certification process, such as risk assessments, security control implementation and monitoring, and documentation. This can help organizations save time and resources, and ensure that all required activities are completed accurately and in a timely manner.
  2. Centralized Management: A GRC system provides a centralized platform for managing all aspects of the FedRAMP certification process, including documentation, security control implementation, and risk assessments. This can help organizations maintain a clear and consistent view of their compliance posture, and make it easier to identify and address any issues that may arise.
  3. Improved Compliance: A GRC system can help organizations stay in compliance with FedRAMP and other relevant regulations by providing real-time monitoring and reporting capabilities, and ensuring that security controls are implemented and monitored consistently.
  4. Efficient Reporting: A GRC system can automate the generation of reports required for FedRAMP certification, such as security assessment reports, incident reports, and continuous monitoring reports. This can help organizations save time and resources, and ensure that reports are accurate and up-to-date.

In summary, using a GRC system for your FedRAMP initiative can help organizations streamline and automate many of the manual processes involved in the certification process, improve compliance, and provide real-time monitoring and reporting capabilities.

Why is FedRAMP certification Important?

FedRAMP certification is important because it provides assurance to federal agencies that a cloud service provider has met a set of security standards for handling sensitive government data. The certification process involves a thorough security assessment of the provider’s systems, facilities, and processes, and ongoing monitoring to ensure that security controls remain effective over time. By relying on FedRAMP certification, federal agencies can save time and resources compared to conducting individual security evaluations for each cloud service they use. Additionally, FedRAMP certification provides a level of trust and confidence to federal agencies and their stakeholders, helping to facilitate the adoption and integration of cloud services into federal IT environments.

What is the FedRAMP certification process?

  1. Preparation: The cloud service provider must gather required documentation, such as security plans and network diagrams, and prepare for a security assessment.
  2. Assessment: An independent third-party assessment organization (3PAO) performs a security assessment of the cloud service provider’s systems, facilities, and processes. The assessment covers a range of security controls, such as access control, incident management, and data protection.
  3. Authorization: If the assessment is successful, the 3PAO provides a security assessment report to the Joint Authorization Board (JAB), which includes representatives from various federal agencies. The JAB reviews the report and decides whether to grant authorization for the cloud service to be used by federal agencies.
  4. Continuous Monitoring: After authorization, the cloud service provider must continuously monitor its systems and security controls to ensure that they remain effective. The 3PAO also performs periodic re-assessments to validate the continued effectiveness of the security controls.

The FedRAMP certification process is designed to be repeatable and scalable, and provides a level of transparency and accountability to federal agencies and their stakeholders. The goal is to make it easier and more secure for federal agencies to adopt cloud services while ensuring that sensitive government data is protected.

What is Joint Authorization Board Provisional Authorization?

Joint Authorization Board (JAB) Provisional Authorization is a type of authorization granted by the JAB, which is a group of senior-level representatives from federal agencies responsible for overseeing the FedRAMP certification process. JAB Provisional Authorization indicates that a cloud service provider has been deemed secure enough to be used by federal agencies, but with conditions or limitations specified by the JAB.

A JAB Provisional Authorization may be granted when a cloud service provider has demonstrated sufficient security controls, but further work is needed to fully meet FedRAMP requirements. This can include additional security measures, documentation, or other requirements. In this case, the JAB may grant a Provisional Authorization for a specified period of time, during which the cloud service provider must complete the additional work required to achieve full FedRAMP authorization.

JAB Provisional Authorization provides federal agencies with a level of assurance that a cloud service provider is working towards meeting FedRAMP requirements and that appropriate security controls are in place to protect sensitive government data. It can also help cloud service providers that are just starting the FedRAMP certification process to move quickly to market and begin serving federal agencies.

What is Agency Authority to Operate?

An Agency Authority to Operate (ATO) is an authorization granted by a federal agency to a cloud service provider, allowing the provider to process and store sensitive government data on behalf of that agency. An ATO is based on a review of the provider’s security controls, and indicates that the agency has determined that the security of the provider’s systems and data meets its requirements.

An ATO is a key component of the Federal Risk and Authorization Management Program (FedRAMP), which provides a standardized approach to security assessment, authorization, and continuous monitoring for cloud services used by federal agencies. A cloud service provider that has received an ATO from one federal agency can use that authorization to help demonstrate its security posture to other agencies, making it easier to sell its services to the federal government.

The process for obtaining an ATO depends on the specific agency and its requirements, but it generally involves submitting a security assessment report and other documentation, as well as undergoing an on-site review of the provider’s systems and processes. Once an ATO is granted, the agency is responsible for ongoing monitoring of the provider’s security controls to ensure they remain effective.

FedRAMP Best Practices

FedRAMP Best Practices are guidelines and recommendations developed by the Federal Risk and Authorization Management Program (FedRAMP) to help cloud service providers achieve a high level of security and compliance with government standards. These best practices cover a range of security domains, including access control, incident management, and data protection, and are designed to help cloud service providers implement robust and effective security controls.

FedRAMP Best Practices are not mandatory requirements, but following them can help cloud service providers achieve FedRAMP authorization more quickly and efficiently, and provide additional assurance to federal agencies and their stakeholders. Additionally, FedRAMP Best Practices can help cloud service providers differentiate themselves from their competitors and increase their visibility in the federal marketplace.

By adhering to FedRAMP Best Practices, cloud service providers can demonstrate their commitment to security and compliance, and help ensure the protection of sensitive government data. They also provide a common understanding of security requirements and expectations among cloud service providers, federal agencies, and other stakeholders, which can help to streamline the authorization process and facilitate the adoption of cloud services by the federal government.

  • Although automation is the future, our suggestion is to avoid IaC approaches. There’s just too many open holes, documentation requirements, staging requirements, vulnerabilities management within the codes and how many times are you really going to deploy a FedRAMP Infrastructure.
  • DevSecOps requirements is a very crucial part of FedRAMP.  The entire CI/CD pipeline needs a shift left security model from code to running application.  Keep the boundary separate, it’ll help you in the long run with ConMon.
  • Our highest recommendation is to utilize a GRC system.  Doesn’t matter which one you use but make sure it’s a mature products.

Published On: February 6th, 2023 / Categories: Blogs, compliance /

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With over 2+ decades of experience in the field of IT and compliance, I have successfully overseen multiple FedRAMP certifications and a dozen ATOs within the realms of the DOJ and DOD.

“Chue is a brilliant technologist who is a SME for everything with InfoSec and Federal Government Compliance. He is incredibly diligent, hard-working and is able to easily discuss complicated technical matters with both experts and beginners. His can-do, humble attitude made it a distinct pleasure to work with and learn from him.”

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