Defining a FedRAMP Authorization Boundary: A Primer

What is FedRAMP?

The Federal Risk and Authorization Management Program (FedRAMP) is a government-wide program that provides a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services. FedRAMP was established to improve security of government data and systems by standardizing the way that these products and services are evaluated for security risks.

FedRAMP streamlines the security authorization process by providing a baseline set of security requirements that are tailored to the specific risk environment of each type of federal information system. This allows agencies to select Authorized Products and Services that have already been through an independent, third-party assessment against these requirements. Products and services that have not yet been assessed can still go through the FedRAMP process, but they will need to undergo an initial assessment as part of their authorization.

In order to become authorized under FedRAMP, organizations must first develop a System Security Plan (SSP) that details how their product or service will meet the FedRAMP security requirements. Once the SSP is complete, it is submitted to a Third-Party Assessment Organization (3PAO) for review. The 3PAO conducts an assessment of the organization’s security controls to verify that they are in place and operating as described in the SSP.

As part of this process, it is essential to define an authorization boundary in order to effectively secure the system. This involves taking into account all of the systems and components that make up your environment as well as any data flows within your environment. Additionally, establishing roles and responsibilities within the organization helps ensure that only authorized individuals have access to the resources they need. By following the best practices outlined in this article, organizations can create an effective authorization boundary for their FedRAMP environments.

What is an Authorization Boundary?

As defined by FedRAMP Boundary Guidance, the authorization boundary is “the system, subsystem, or component that is the subject of an authorization decision. It includes associated organizational units, individuals, data stores, systems, and networks that must be considered in making an authorization decision for a given system.” The key concept here is that the authorization boundary is where the separation of duties and responsibilities occurs with regards to security. This is important because it helps ensure that one individual or group of individuals cannot make changes to the system that would jeopardize its security posture.

In order to properly secure a system, it is important to understand its components and how they interact with each other. By identifying the authorization boundary, you can more easily understand which individuals or groups should have access to which parts of the system. This helps to prevent unauthorized changes from being made and safeguard the system against potential threats.

Defining the Boundary for Your System

One of the first steps in creating a FedRAMP authorization boundary is defining the systems that will be included in the boundary. This can be a difficult task, as there are many factors to consider. Here are some best practices for defining the boundary for your system:

1. Identify and document the system boundary: The system boundary defines the extent of the system and the data it processes, stores, and transmits. It is essential to clearly define and document the system boundary to ensure that all relevant security controls are implemented within the boundary. Consider all of the systems that make up your overall system. This includes any hardware, software, networks, and data that are part of your system.
2. Determine the impact level of the system: FedRAMP has three impact levels (low, moderate, and high) that correspond to the sensitivity and criticality of the data processed, stored, and transmitted by the system. It is important to determine the impact level of the system as it will help determine the appropriate security controls that need to be implemented. Evaluate which systems are critical to the operation of your system and which ones can be excluded from the boundary.
3. Identify system dependencies: Identify the dependencies between your systems and services. This includes both internal dependencies within your organization and external dependencies on third-party services. Understanding these dependencies will help you determine the extent to which your systems are interconnected and how they can be isolated from each other.
4. Determine the data flow between systems: Determine the data flow between your systems, including the direction of data flow and the types of data that are transmitted. This will help you determine which systems are critical for the processing, storage, and transmission of sensitive data and how they can be isolated from other systems.
5. Consider the cloud deployment model: The cloud deployment model can impact how interconnected your systems are and how they can be isolated from each other. For example, in a public cloud deployment model, multiple tenants may share resources on the same physical infrastructure, making isolation more challenging. In a private cloud deployment model, resources may be dedicated to a single tenant, making isolation easier.
6. Evaluate network segmentation options: Network segmentation options, such as VLANs, can be used to isolate systems from each other. Evaluate whether these options are feasible for your organization and how they can be implemented effectively.
7. Determine the level of isolation required: The level of isolation required will vary based on the sensitivity of the data processed, stored, and transmitted by your systems. For high-impact systems, complete isolation may be necessary, while low-impact systems may require less isolation.
8. Map FedRAMP security controls to NIST 800-53 rev 4 control families: The FedRAMP security controls are mapped to the NIST 800-53 rev 4 control families. It is important to map these controls to ensure that all relevant controls are implemented within the system boundary.
9. Implement security controls based on the impact level of the system: The security controls that need to be implemented will vary based on the impact level of the system. For example, a low-impact system may not require as many security controls as a high-impact system. Ensure that the appropriate controls are implemented for the impact level of the system.
10. Conduct a risk assessment: A risk assessment will help identify and evaluate risks to the system and the data it processes, stores, and transmits. The risk assessment should consider threats, vulnerabilities, and the likelihood and impact of potential incidents. The results of the risk assessment will inform the selection and implementation of security controls.
11. Implement continuous monitoring: Continuous monitoring is essential to ensure that the security controls are operating effectively and to detect and respond to security incidents. Ensure that continuous monitoring is implemented within the system boundary.
12. Document and maintain the FedRAMP authorization package: The FedRAMP authorization package documents the security controls implemented within the system boundary and the results of security assessments. It is important to document and maintain the authorization package to ensure that the system remains in compliance with FedRAMP requirements.

The authorization boundary diagram and description must encompass any external system or service that houses federal or sensitive data related to the CSO. Additionally, any tool, service, or component listed in the system security plan, but excluded from testing, should be assessed as an external service. For instance, even if an external ticketing system utilized to document and trace system vulnerabilities is not directly linked to the CSO, it still contains sensitive data that could affect the CIA of the CSO. These kinds of external systems and services must be disclosed to the Authorizing Official, and they should be represented on the authorization boundary diagram and elaborated in the authorization package deliverables (SSP, SAP, SAR) or Readiness Assessment Report (for CSPs pursuing a FedRAMP Ready designation). 

Determining Federal Data within the Boundary

Based on FedRAMP Guidance, Federal metadata refers to data that, if compromised, could affect the confidentiality, availability, or integrity of federal data processing, storage, or transmission systems. This includes configuration data such as hostnames, IPs, and system running configurations, as well as security documentation, incident response data, and ticketing information with system-specific details. The impact level of such metadata can vary, and the categorization of metadata in a CSO should be validated by the CSP with the AO.

There are two subcategories of metadata.

Federal Metadata:

The first includes metadata that has a direct potential impact on mission, organizations, or individuals if confidentiality, integrity, or availability is lost. Examples include security metadata, vulnerability information, active incident response and communication data, and active threat assessment, penetration test, or security investigation data. This metadata must reside within the authorization boundary or within the boundary of another federal information system authorized at the same or greater FIPS-199 impact level, as determined by the AO in consultation with the CSP. JAB systems using external systems for processing, storage, or transmission of this metadata must use a system with JAB authorization at the same or greater FIPS-199 impact level.

The second subcategory of federal metadata includes metadata that has an indirect potential impact on mission, organizations, or individuals if confidentiality, integrity, or availability is lost. Examples include data revealing system infrastructure, facilities, and design, as well as application, system, and network configuration information. This metadata may be authorized to reside in a system fully owned, maintained, and operated by the CSP if contractual vehicles or other agreements provide for and if the CSP can demonstrate or attest to meeting and maintaining satisfactory security requirements in accordance with NIST SP 800-171. Additionally, this subcategory includes information that could be sold for profit and historical federal metadata previously considered to have a direct potential impact.

Corporate Metadata:

Corporate metadata refers to data that pertains to processes within the authorization boundary or federal customers but does not contain sensitive security information or information that could pose a threat to federal data processing, storage, or personnel data. Examples include sales data, IT utilization and performance data, project planning information, marketing materials, and pricing data.

CSPs are responsible for accounting for, protecting, and documenting corporate metadata within applicable FedRAMP deliverables. External systems processing or storing corporate metadata may maintain an active connection with the authorization boundary, but all connections must be examined, and the type of information transmitted in the connection must be validated by the 3PAO during initial authorization and annual assessment.

Interconnections:

According to the federal definition in NIST SP 800-47, an interconnection refers to the direct connection of two or more IT systems for the purpose of sharing data and other information resources. In the context of FedRAMP, Authorizing Officials (AOs) must review interconnections to ensure that all federal data and metadata that is transmitted within or outside the system is adequately protected.

Cloud technologies that utilize interconnections, APIs, and other synchronous/asynchronous connections which may transmit federal data or metadata, are required to document, test, and monitor these connections in compliance with FedRAMP and federal guidelines.

When defining FedRAMP authorization boundaries, it is important to consider whether interconnected systems have existing FedRAMP authorization. If they do not have authorization, they will be considered unauthorized services, and the entire system boundary may be at risk of non-compliance with FedRAMP requirements.

Organizations need to be aware of the potential risks associated with unauthorized services, including security risks, data breaches, and non-compliance with regulatory requirements. Unauthorized services can also impact the overall security posture of the organization, making it more vulnerable to cyber attacks and other security incidents.

To prevent unauthorized services from posing a risk to the organization, it is essential to conduct a thorough review of all interconnected systems to determine if they have existing FedRAMP authorization. This review should include the following steps:

1. Identify all interconnected systems: Identify all systems that are interconnected with the system boundary. This includes cloud services, network devices, servers, and other components that work together to provide a service or support business operations.
2. Determine if the interconnected systems have FedRAMP authorization: Determine if each interconnected system has existing FedRAMP authorization. This can be done by reviewing the FedRAMP Marketplace, which lists all cloud service providers that have been authorized by FedRAMP.
3. If an interconnected system does not have FedRAMP authorization, determine if it needs to be authorized: This will depend on the impact level of the system and the sensitivity of the data it processes, stores, and transmits.
4. Complement appropriate security controls to isolate unauthorized services: If an interconnected system cannot be authorized, or if it is determined that it poses a security risk to the system boundary, appropriate security controls must be implemented to isolate the unauthorized service. This may involve network segmentation, access controls, and other measures to limit the potential for a security incident to spread.

Best Practices for Defining Your Authorization Boundary

When it comes to defining your authorization boundary for FedRAMP, there are a few best practices to keep in mind. First and foremost, your boundary should be defined at the system level. This means that you need to identify which systems or components make up your environment and which ones are outside of your control. You also need to take into account how your systems interact with each other and with external systems.

Another important consideration is what data is passing through your systems and where it is coming from or going to. You need to think about how data flows within your environment and identify any potential risks associated with that data. Additionally, you should consider what happens if there is a breach of one of your systems. What would be the impact on the rest of your environment?

Finally, when defining your authorization boundary, you need to establish who has access to which systems and data. This includes defining roles and responsibilities within your organization as well as determining which individuals or groups have access to specific resources. By taking all of these factors into account, you can create a comprehensive and secure authorization boundary for your FedRAMP environment.

Conclusion

In conclusion, defining a FedRAMP authorization boundary requires careful consideration of various factors, including system components, data flows, and access controls. Adhering to best practices such as defining the boundary at the system level, identifying potential risks, and establishing roles and responsibilities can help organizations create a secure and compliant FedRAMP environment. It is also important to stay up to date with guidance and regulations from the FedRAMP program office, such as the FedRAMP Authorization Boundary Guidance, to ensure that the authorization boundary remains effective and relevant. By following these best practices, organizations can better protect their cloud-based services and maintain the trust of their stakeholders.

Defining a FedRAMP authorization boundary is an essential step to ensure the security of cloud-based services. By understanding the best practices for defining a FedRAMP authorization boundary, organizations can make sure that their systems are well protected from external threats and comply with all applicable regulations. Implementing these best practices will also help organizations reduce operational costs by streamlining processes and establish better control over the management of their Cloud environments. Additional details can be found here at the FedRAMP PMO Draft Guidance: FedRAMP Authorization Boundary Guidance

How can we assist you?

Quzara LLC can assist organizations in their FedRAMP authorization journey by providing expertise in cloud-based security architectures for platforms such as Azure, AWS, and Google. With our knowledge and experience, we can help organizations define their FedRAMP authorization boundary and ensure compliance with federal cybersecurity requirements. Our team of experts can guide organizations through the authorization process and ensure that their systems and networks are secure from malicious actors.

By partnering with Quzara LLC, organizations can have peace of mind knowing that their cloud-based systems and services are secure and compliant with FedRAMP requirements. We offer a range of services, from developing a System Security Plan to conducting security assessments and audits, to help organizations meet FedRAMP standards. Our goal is to provide organizations with the tools and knowledge they need to protect their networks and data from cyber-attacks and ensure that they meet federal cybersecurity requirements.