How to Achieve FedRAMP Compliance?

Hari Mahesh

Cloud services have made our lives easier. Using cloud service providers, sharing files with friends or colleagues is easy. Saving photos and documents on a physical drive and worrying that they may be stored correctly has changed. You can upload everything to the cloud and retrieve or share it with anyone. However, with the rise in cloud-based service providers, the security risk also increases. Many cases of data breaches were associated with cloud data providers.

Not just citizens alone, Government officials also use cloud service providers. The US Federal Government has been using cloud services since 2018. For government agencies, data breaches can impact everything from citizen safety to national security. As cyber risks threaten governments and organizations, the US government has implemented measures to secure the federal use of cloud solutions. That’s how FedRAMP (Federal Risk and Authorization Management Program) began.

So, in this article, we will discuss FedRAMP, its principles, and how to achieve it.

What is FedRAMP?

FedRAMP is a set of regulations standardizing cloud products and services used by U.S. federal agencies. It was established in 2011 and helps the agency use modern cloud technologies with an emphasis on the security and protection of federal data. FedRAMP defines and manages a core process set to ensure adequate, repeatable cloud security for the government.

FedRAMP is controlled by the FedRAMP board, which consists of the Department of Homeland Security (DHS), the Department of Defense (DOD), and government agencies. FedRAMP has 27 applicable laws and regulations and 26 standards and guidance documents. This is one of the world’s most rigorous cloud certifications. Around 20 cloud services were initially certified, but now the current count is close to 350 cloud service providers.

Goals of FedRAMP

FedRAMP streamlines secure cloud adoption by:

• Fast Track Secure Solutions: By reusing security assessments, FedRAMP cuts red tape and speeds up the adoption of secure cloud solutions for government agencies.
• Boost Confidence in Security: FedRAMP’s rigorous standards and assessments ensure both cloud services and security evaluations are trustworthy.
• Standardize Security Approvals: Clear and consistent security benchmarks across all agencies simplify cloud product approvals within and beyond the FedRAMP program.
• Unify Security Practices: FedRAMP promotes consistent application of best practices, strengthening the overall security posture of cloud deployments.
• Real-Time Monitoring: FedRAMP encourages automation and near real-time data for continuous monitoring, ensuring ongoing security and proactively identifying potential threats.

Why FedRAMP Compliance?

FedRAMP compliance is important for two main reasons: it unlocks government business opportunities for cloud service providers(CSPs) and strengthens government agencies’ security.

Let’s go through each reason.

For Cloud Service Providers (CSPs)

CSPs require FedRAMP for the following reasons:

Access to Government Contracts

FedRAMP certification is mandatory for working with the US federal government. This compliance is an entry ticket to bid for government projects. Without this compliance, you will be missing a significant market segment.

Enhanced Credibility

Having this compliance means your cloud services provide top-notch cloud security. That builds trust and credibility with every potential client, both in the government sector and commercially. We can consider this a security seal of approval, making it attractive to all customers.

Streamlined Process

FedRAMP offers a standardized security approach across all government agencies. This eliminates the need for multiple individual security assessments, saving you considerable time and resources. It’s more like going through one security check instead of having multiple e-checks of the same type from each agency.

For Government Agencies

Government agencies require FedRAMP for the following reasons:

Ironclad Security

FedRAMP ensures that cloud services meet strict security standards. This safeguards sensitive government data from breaches, unauthorized access, and other security threats. With FedRAMP-compliant cloud services, your data is protected by Fort Knox-like security.

Efficiency and Cost Savings

FedRAMP avoids duplicating security assessments for each cloud service. This allows for faster adoption of secure cloud solutions and reduces the overall cost associated with security evaluations. No more redundant checks, just quicker implementation and lower costs.

Transparency and Visibility

The FedRAMP marketplace provides a clear list of authorized cloud services. This simplifies the selection process for government agencies. They can confidently choose trusted and secure solutions, knowing they’ve been vetted for security.

Beyond Individual Benefits

FedRAMP certification creates a secure and efficient cloud computing ecosystem. It benefits taxpayers through:

• Data security for the government
• Streamlined processes
• Cost savings due to government efficiency

The FedRAMP Marketplace

This marketplace lists authorized cloud service providers. Here’s why it’s important:

• Easier Selection for Government Agencies: They can choose pre-vetted solutions, simplifying their process.
• Increased Business for CSPs: A listing significantly improves your chances of getting government contracts.
• Enhanced Credibility for Private Sector Too: The marketplace is public, so private companies can use it to find secure cloud solutions, boosting your overall profile.

Security Credibility

FedRAMP authorization signifies an ongoing commitment to the highest security standards, making any client more confident in your service. You can leverage this by promoting your certification to build trust with all potential clients.

FedRAMP Governance Bodies

FedRAMP is a collaborative effort between several executive branch agencies, each playing a crucial role:

• Joint Authorization Board (JAB): This board, comprised of top IT leaders (CIOs) from Homeland Security (DHS), General Services Administration (GSA), and Defense (DoD), makes the key decisions and calls the shots for FedRAMP.
• Office of Management and Budget (OMB): OMB sets the program’s foundation by defining its core requirements and functionalities through policy memorandums.
• CIO Council: This group acts as the information hub. They keep federal CIOs and other representatives informed about FedRAMP through regular communication and events.
• FedRAMP Program Management Office (PMO): Housed within the GSA, the PMO is the workhorse that handles the day-to-day operations and development of the FedRAMP program.
• Department of Homeland Security (DHS): DHS keeps a watchful eye on security. They manage the continuous monitoring strategy for FedRAMP, ensuring data is appropriately collected, reports are clear, and threats and incidents are addressed effectively.
• National Institute for Standards and Technology (NIST): NIST serves as the security advisor. They provide expert guidance on FISMA compliance requirements and help develop standards for accrediting independent assessment organizations (3PAOs) that evaluate cloud security.

Getting FedRAMP Certified

There are two approaches to obtaining a FedRAMP Authorization: a provisional authorization through the Joint Authorization Board (JAB) or an authorization through an agency.

Let’s go through each approach:

JAB Authorization Process

As we know, JAB is the primary governing body for FedRAMP. The JAB selects around 12 cloud products per year to work with the JAB Provisional Authority to Operate. Also, JAB continuously monitors all JAB-authorized cloud products.

The JAB authorization process is divided into three stages:

Stage 1: Preparation

The preparation phase consists of three steps. The duration of each phase varies based on the cloud service offering’s architecture and current security posture compared to federal requirements.

FedRAMP Connect

• Register your cloud service with FedRAMP, demonstrating alignment with security controls and baselines.
• Complete a FedRAMP business case outlining your service, target government market, and how to meet FedRAMP requirements.

Readiness Assessment

• Engage a Third-Party Assessment Organization (3PAO) to conduct a Readiness Assessment (RA) of your security posture.
• Obtain a Readiness Assessment Report (RAR) summarizing your security strengths and areas for improvement (this step strengthens your application but is not mandatory).

Security Assessment

• Engage an accredited 3PAO to conduct a thorough security assessment of your cloud service against FedRAMP standards.
• The 3PAO will produce a Security Assessment Report (SAR) detailing their findings and your compliance with security controls.

Stage 2: Authorization

After the preparation phase, it is the authorization phase. In this process, the below steps are performed:

• Submit your Security Assessment Report (SAR) prepared by the 3PAO and other supporting documentation to the Joint Authorization Board (JAB) for review.
• The JAB will evaluate your submission to ensure your cloud service meets the security requirements for government use.
• If everything aligns, the JAB will grant a Provisional Authorization to Operate (P-ATO) for your cloud service. This signifies your service meets FedRAMP standards and gets listed in the FedRAMP marketplace, making it discoverable by government agencies seeking secure cloud solutions.
• The JAB review process may involve additional questions or requests for clarification from the board.
• The JAB may take 3 to 6 months to complete their review after you submit your SAR.

Stage 3: Continuous Monitoring

In this phase, the CSP must provide monthly continuous monitoring deliverables with incident reports to JAB agencies. The JAB acts as a focal point for continuous monitoring activities of systems with a P-ATO. The JAB:

• Reviews continuous monitoring and security artifacts regularly
• Monitors, suspends, and revokes a system’s P-ATO as appropriate
• Authorizes or denies significant change and deviation requests
• Ensures continuous monitoring of deliverables is provided to leveraging agencies promptly

Agency Authorization

In the agency authorization process, agencies work directly with CSPs for authorization at any time. CSPs that make a business decision to work directly with an agency to pursue an Authority to Operate (ATO) will work with the agency throughout the FedRAMP authorization process.

Here also we have three stages:

Stage 1: Preparation

For agency authorization, in the preparation part, we have two steps:

Readiness Assessment

• Initiate contact with your target agency and formalize a partnership agreement. This agreement outlines your intent to pursue agency authorization for your CSO.
• Discuss the agency’s specific security needs and how your service can address them.
• Negotiate the terms of the authorization, including the scope of use and any ongoing monitoring requirements.

Pre-Authorization

• Work with the agency to clearly understand their security needs and compliance requirements. This will ensure that your CSO aligns with their priorities before investing significant resources in a full security assessment.
• Develop a Security Assessment Plan (SAP) in collaboration with the agency. This plan will outline the scope and methodology for the upcoming security assessment, specifically considering the agency’s unique requirements.
• By collaborating on the SAP upfront, you can avoid potential delays or rework during the actual assessment.

Stage 2: Authorization

In the authorization phase, we have two steps: Full Security Assessment and Agency Authorization Process.

Authorization: Full Security Assessment

The agency will thoroughly assess (CSO) to ensure it meets its security requirements. This assessment may involve:

• Internal Assessment: The agency’s security team may conduct the assessment themselves, leveraging their expertise and understanding of security posture.
• Third-Party Assessment: Alternatively, they may engage an accredited Third-Party Assessment Organization (3PAO) to perform the assessment. This can objectively evaluate and leverage the 3PAO’s expertise in FedRAMP standards.

Authorization: Agency Authorization Process

• Upon completing the security assessment, you’ll submit a comprehensive Security Authorization Package (SAAP) to the agency.
• This SAAP document details your security controls, policies, and procedures, demonstrating how your CSO meets the security requirements defined during pre-authorization and the security assessment.
• The agency will thoroughly review your SAAP, the security assessment report, and other relevant documentation. This review may involve additional questions or requests for clarification from the agency’s security team.
• Based on their review, the agency will make a final decision on whether to grant authorization.

Stage 3: Continuous Monitoring

The continuous monitoring phase consists of post-authorization activities to maintain a security authorization that meets the FedRAMP requirements.

• Once authorized, you’re responsible for continuously monitoring your cloud service to ensure your security posture aligns with the agency’s security requirements and FedRAMP baselines. This involves ongoing activities like vulnerability patching, security threat monitoring, and regular security assessments.
• Continuously demonstrating a solid security posture fosters trust with the authorizing agency and strengthens your relationship. This can pave the way for future collaborations or expanding your services within the agency.

Impact Levels for FedRAMP Authorizations

FedRAMP categorizes Cloud Service Offerings (CSOs) into three impact levels based on a security incident’s potential impact on the federal government’s data and operations. These impact levels determine the security controls required for authorization. Here’s a breakdown:

Low Impact Level

Security incidents involving low-impact CSOs are unlikely to seriously impact the confidentiality, integrity, or availability of government data, operations, or assets. These CSOs typically process unclassified data with minimal to no risk of exposure.

Moderate Impact Level

Security incidents involving moderate-impact CSOs could potentially negatively impact the confidentiality, integrity, or availability of government data, operations, or assets. These CSOs may process sensitive data but are unlikely to contain highly sensitive information.

High Impact Level

Security incidents involving high-impact CSOs are highly likely to severely impact the confidentiality, integrity, or availability of government data, operations, or assets. These CSOs typically process highly sensitive data, and a security breach could have significant consequences.

Role of Testing in FedRAMP Compliance

FedRAMP relies heavily on testing to ensure the security of cloud services utilized by the U.S. federal government. This includes penetration testing, mimicking real-world attacks to expose vulnerabilities, and vulnerability scanning to identify weaknesses in a cloud service’s defenses. Security assessments, mandatory for both JAB and agency authorization paths, often incorporate these tests to evaluate a service’s overall security posture. Even after authorization, ongoing testing remains crucial to maintain a secure environment.

Penetration Testing

This simulates real-world cyberattacks, attempting to exploit vulnerabilities in a cloud service’s security posture. It evaluates the effectiveness of security controls against unauthorized access and identifies areas where attackers might gain a foothold. Commonly used tools are Metasploit, Burp Suite, Nessus, etc.

Vulnerability Scanning

Regular scans are performed to detect known vulnerabilities in software and hardware components of the cloud service. Vulnerability scanning tools like Nessus, OpenVAS, Rapid7Nexpose, Qualys etc, are used to identify security weaknesses that need to be addressed automatically.

Configuration Management Testing

This type of testing checks that systems are configured properly and in compliance with FedRAMP requirements. It includes ensuring security settings are correctly applied and maintained across the cloud service. Commonly used tools include Ansible, Puppet, SaltStack, Terraform, etc.

Web Application Testing

Web application testing ensures that a cloud service’s web applications operate as intended while meeting strict security standards. This form of testing checks for the correct functionality of web applications to prevent errors that could expose sensitive government data to security threats. By validating user interactions, data processing, and business logic, functional testing helps identify and mitigate risks in web applications before malicious actors can exploit them.

Commonly used tools involve Selenium and testRigor. Read: Learning Software Application Testing: A Guide.

testRigor is an excellent choice for end-to-end testing. You can execute test cases that help verify that changes in web applications function as expected across different platforms and devices. The best part is that you can test complex scenarios through plain English test cases. Read: How to do End-to-end Testing with testRigor.

Using testRigor, you can perform cross-browser and cross-platform testing singlehandedly. Execute test cases on the web, mobile (native, hybrid), desktop, and API using plain English commands.

login as customer
click "Verify Your KYC"
enter stored value "FirstName" into "First Name"
enter stored value "LastName" into "Last Name"
enter stored value "DOB" into "Date Of Birth"
enter stored value "address" into "Address"
enter stored value "email" into "Email ID"
enter stored value "phone" into "Mobile"
click "Save" roughly to the left of "Submit"
Check the page contains "KYC Application Pending"

This sample test script demonstrates that it contains simple English steps. Additionally, with testRigor, we can create reusable functions and save them for future use. This eliminates the need to write all steps repeatedly; instead, we can simply invoke the function, such as “login as customer.” Read: How to use reusable rules or subroutines in testRigor?

Furthermore, we can store values with identifiers and easily reference them in the script, as seen in the command “enter stored value ‘FirstName’ into ‘First Name‘.” Read: How to use variables in testRigor?

testRigor helps you validate files, audio, 2FA, video, email, SMS, phone calls, mathematical validations/calculations of formulas, APIs, Chrome extensions, and many more complex scenarios. Access testRigor documentation and top testRigor’s features to learn about more valuable capabilities.

Conclusion

Achieving FedRAMP compliance is a rigorous but vital process for cloud service providers looking to serve U.S. federal agencies. It begins with understanding and aligning with the comprehensive security requirements FedRAMP sets forth. This alignment involves preparing thorough documentation, implementing robust security controls, and engaging with accredited third-party assessors for initial and ongoing evaluations.

Successful compliance also requires a commitment to continuously monitoring and improving security practices to respond effectively to new vulnerabilities and threats. By systematically addressing these aspects, CSPs can achieve FedRAMP compliance and enhance their overall security posture, making their services more reliable and trustworthy for government and other sensitive environments.

Use supportive and intelligent tools such as testRigor that make this process easier, effortless, and efficient. testRigor’s powerful capabilities, combined with the guidance provided in this article, enable organizations to effortlessly navigate the complex requirements of FedRAMP and maintain long-term compliance.

Frequently Asked Questions (FAQ’s)

Benefits include enhanced security that helps to mitigate weakness, compliance to ensure adherence to FedRAMP security controls, and increased trust with government agencies.

The time required to achieve FedRAMP authorization can vary significantly depending on the complexity of the cloud service, the maturity of its existing security practices, and the specific requirements of the authorizing agency. Generally, the process can take from 6 months to 2 years.

testRigor is SOC2 and HIPAA compliant and supports FDA 21 CFR Part 11 reporting. You can efficiently perform accessibility testing through testRigor. Read here how to build an ADA-compliant app.