Quzara, with nearly a decade of active involvement in federal cloud security compliance, is closely monitoring potential developments within the Federal Risk and Authorization Management Program (FedRAMP).
Given recent administrative restructuring at GSA, coupled with increasing Congressional interest and industry feedback, we believe it is timely to share insights and proactive recommendations designed to shape FedRAMP’s future direction.
These recommendations aim to guide FedRAMP toward greater agility, simplified compliance processes, and stronger overall security outcomes.
Context: Potential Administrative Changes
Recent industry signals and administrative communications suggest significant potential restructuring of FedRAMP operations, notably reductions in contractor staffing balanced by stable or slightly increased federal employee counts.
This restructuring, if realized, would align with broader efficiency initiatives within the General Services Administration (GSA). Despite these possible adjustments, FedRAMP maintains an active authorization pipeline, currently authorizing over 370 cloud services.
Emerging policies, including RFC-0004 on Boundary Policy and revised Cryptographic Module Selection and Use guidance, highlight FedRAMP's likely ongoing alignment with current cybersecurity best practices.
Anticipated Changes in FedRAMP
Based on current trends and industry insights, Quzara anticipates the following potential changes within FedRAMP:
- Potential Elimination of Agency Sponsorship:
It appears increasingly possible that the existing agency sponsorship requirement may be phased out. Such a move would enable agencies to independently evaluate CSPs during procurement, potentially reducing authorization times.
- Move Toward Increased Automation:
FedRAMP is anticipated to significantly increase reliance on automated technical validation processes, aiming to decrease manual review times. However, comprehensive, universally accepted automation platforms remain undeveloped, highlighting an important area for CSP-led innovation.
- Reduced direct role of FedRAMP PMO and elimination of JAB related responsibilities:
There are indicators suggesting the Joint Authorization Board (JAB) and the FedRAMP PMO could transition to governance and oversight roles rather than direct operational review responsibilities, potentially giving individual agencies greater discretion and responsibility.
- Shift of Continuous Monitoring to Agencies:
We anticipate continuous monitoring responsibilities, previously managed centrally by the FedRAMP PMO, could shift to individual federal agencies. Agencies may face significant challenges managing these increased responsibilities due to existing resource constraints.
- Marketplace Evolution to a Maturity-Based Model:
The FedRAMP Marketplace as we currently know it could potentially evolve into a maturity-based marketplace, helping agencies match CSPs' security maturity levels to their specific risk profiles.
- The Scope and Role of 3PAOs:
Third-party assessment organizations (3PAOs) will likely remain integral due to their legal requirement under the FedRAMP Authorization Act, although their role may adapt to accommodate greater automation.
Key Challenges to Address
- Alignment on the Future Framework for FedRAMP Compliance:
The path forward involves adopting an enhanced set of controls derived from NIST SP 800-53 and other NIST guidelines. These controls should focus mainly on the Technical control family to facilitate automation. Other control families may be deprioritized or integrated from existing frameworks. This step is essential!
- Absence of a Mature Automation Platform:
A robust automation platform capable of comprehensive compliance validation does not yet exist, creating a gap that CSPs will need to rapidly address through standardized automated solutions.
- Agency Resource Constraints:
If continuous monitoring responsibilities shift fully to agencies, current resource limitations could severely impact their ability to maintain compliance unless mitigated by effective automation.
- Alignment with DoD Standards:
Potential FedRAMP modernization efforts currently lack alignment with Department of Defense (DoD) frameworks like CMMC and SRG, potentially complicating compliance for CSPs operating across federal sectors.
Quzara’s Strategic Recommendations
- Remove the Agency Sponsorship Requirement:
Facilitate direct procurement-based risk assessments by agencies, streamlining the authorization process.
- Transition Towards Automation-Friendly Security Controls:
FedRAMP should consider partially or entirely transitioning away from traditional NIST SP 800-53 controls to a carefully selected, automation-friendly control set emphasizing real-time security posture. CSPs would be expected to enable these automated controls to be listed on the marketplace.
- Clearly Define FedRAMP PMO’s Governance Role:
Redefine the PMO’s responsibilities to emphasize strategic policy-making, governance, and oversight, rather than detailed operational reviews, to eliminate current bottlenecks.
- Prioritize Operational Security Controls:
Focus evaluations on operational security measures such as continuous vulnerability assessments, regular penetration testing, and active security monitoring, providing immediate visibility into CSP security status.
- Streamline Vulnerability Reporting:
Implement automated, agile reporting processes to quickly identify, disclose, and address vulnerabilities, improving responsiveness and transparency.
- Support Transition for Program Authorization Backlog:
Critically, it is important to clear the existing backlog of CSPs previously engaged with the JAB process, supporting their transition toward agency-managed Program Authorization pathways and expediting their operational readiness.
