The Federal Risk and Authorization Management Program (FedRAMP) sets the standard for assessing, authorizing, and monitoring cloud products and services used by U.S. federal agencies. Understanding the FedRAMP authorization process is crucial for cloud service providers (CSPs) aiming to serve federal clients. This guide will walk you through the steps of the FedRAMP authorization process and highlight the two paths to achieving compliance: Agency Authorization and Joint Authorization Board (JAB) Authorization.
Step 1: Understand the Requirements
Before embarking on the FedRAMP journey, CSPs must thoroughly understand the security requirements set by FedRAMP. This entails familiarizing themselves with a series of standards derived from the National Institute of Standards and Technology (NIST) guidelines, FedRAMP baseline, precise control requirements, and the requisite documentation to be compiled. The goal is to determine the system impact level under which your solution will be authorized, consequently guiding the specific requirements needed.
Step 2: Select the Authorization Path
At the moment, FedRAMP offers two pathways to compliance:
- Agency Authorization: In this path, a CSP seeks authorization from a specific federal agency that intends to use the cloud service. The agency assumes responsibility for the authorization and continuous monitoring. This approach is often quicker if a CSP has an existing relationship with an agency that is ready to sponsor the authorization process. More details can be found on Agency Authorization.
- Joint Authorization Board (JAB) Authorization: This route involves obtaining a provisional authorization (P-ATO) from the JAB, which consists of representatives from the General Services Administration (GSA), Department of Defense (DoD), and Department of Homeland Security (DHS). This type of authorization can be more challenging to achieve but offers a broader acceptance as it’s recognized by all federal agencies. More on this can be explored on JAB Authorization.
Step 3: Conduct a Gap Assessment
Once the system impact level is determined, a gap assessment should be completed to uncover any showstoppers and critical controls. This entails identifying any discrepancies between current security measures and the required FedRAMP standards. By conducting a thorough gap assessment, CSPs can pinpoint areas requiring immediate attention and prioritize remediation efforts effectively. Additionally, the assessment aids in ensuring alignment with FedRAMP requirements, thereby facilitating a smoother path towards authorization.
Step 4: Prepare the Required Documentation
Both authorization paths require a comprehensive set of documents, which include the System Security Plan (SSP), policies and procedures, other supporting plans, and compliant processes. Preparation of these documents is critical as they form the basis of the FedRAMP assessment.
Step 5: Implement FedRAMP Controls
Implementing the security controls as outlined by FedRAMP is perhaps the most time-consuming phase. CSPs must ensure that their services fully comply with the required security measures. These controls cover various aspects of security management, including access control, incident response, and encryption methods.
Step 6: Undergo a Readiness Assessment
A Readiness Assessment conducted by a third-party assessment organization (3PAO) is advisable to evaluate whether the CSP is prepared for the full security assessment. While this step is optional for the agency path and mandatory for JAB, it is highly recommended as it offers an initial indication of whether the CSP’s security posture aligns with FedRAMP standards.
Step 7: Complete a Security Assessment
Once ready, the CSP undergoes a security assessment conducted by a FedRAMP-accredited 3PAO. The assessment involves rigorous testing of the implemented controls and a thorough review of the documentation provided by the CSP. The 3PAO will produce an assessment report, which is critical for obtaining authorization.
Step 8: Remediate Any Issues
It’s common for the assessment to uncover areas where security measures may fall short of FedRAMP requirements. The CSP must address these issues promptly and may need to undergo another partial assessment to verify that the remediations are effective.
Step 9: Obtain Authorization
For Agency Authorization, the sponsoring agency reviews the assessment report and other documentation to decide if they will grant an Authorization to Operate (ATO). For JAB Authorization, the provisional ATO from the JAB signifies that the CSP meets FedRAMP standards, but it will still require an agency to grant an ATO for specific use.
Step 10: Continuous Monitoring
Achieving authorization is not the end of the journey. FedRAMP requires continuous monitoring to ensure that the CSP maintains compliance with the evolving security landscape. This involves regular reporting of the security status and undergoing annual reassessments.
KyberStorm LLC specializes in assisting CSPs in obtaining and maintaining FedRAMP Authority to Operate (ATO). With our proprietary K-STORM Advisory Framework, we ensure our clients are ready within six months. We guide them through the assessment with the 3PAO and provide continuous monitoring post-ATO. Reach out today to learn more about how we can support you.