On May 30, 2023, FedRAMP released the NIST SP 800-53 Revision (Rev) 5 security baselines. This release brings forth fresh security controls that cater to the growing necessity of assessing a Cloud Service Provider's (CSP) risk maturity and their ability to effectively mitigate risks amidst the constantly evolving threat landscape.
With Revision 5 being released, Quzara recognize that CSPs are now seeking answers to crucial questions such as:
Rest assured; we are here to guide you through this transition period whether you are just starting out or are currently authorized.
In this blog post, we will delve into the latest FedRAMP release, break down the notable changes within Revision 5, discuss the transition timeline for CSPs currently in any phase within their FedRAMP Authorization Journey, offer expert insights and invaluable guidance, and equip you with the essential knowledge to flourish in the dynamic cloud security landscape.
Since its inception in 2011, the Federal Risk and Authorization Management Program (FedRAMP) has played a vital role in the U.S. government's cloud security strategy, providing a standardized risk-based approach for assessing, authorizing, and continuously monitoring cloud products and services used by federal agencies.
At the core of FedRAMP's security framework are the National Institute of Standards and Technology's (NIST) Special Publication (SP) 800-53 guidelines with emphasis on security and protection of federal information.
FedRAMP uses a core set of processes to set the seal on effective, repeatable cloud security for the government. It also utilizes a mature marketplace to increase utilization and familiarity with cloud services while facilitating collaboration across government through open exchanges of lessons learned, use cases, and tactical solutions.
The FedRAMP baseline comparison was authored based on the MITRE NIST 800-53 Revision 4 to Revision 5 Change analysis.
Baseline | # of Controls | Control Changes | Parameter Changes |
Tailored / Low Impact SaaS (LI-SaaS) | 156 | Added 31 additional controls to the baseline. | 58 |
Low | 156 | Added 31 additional controls to the baseline. | 58 |
Moderate | 323 | 2 controls have been removed from the baseline total and 21 net new controls. | 100 |
High | 410 | 11 controls have been removed from the baseline total and 76 net new controls. | 33 |
The transition plan released by FedRAMP on May 30, 2023, provides guidance that will assist CSPs in various stages of FedRAMP in identifying the requirements and actions needed to move forward from Revision 4 to Revision 5:
1. Planning Phase - CSPs are in the “Planning” phase and will implement and have an assessor test the new Rev. 5 baseline and use the updated FedRAMP templates prior to submitting a package for authorization if any of the following criteria is met:
2. Initiation Phase – CSPs are in the “Initiation” phase if any of the following criteria is met:
The FedRAMP PMO has stated that CSPs with a current authorization will need to work closely with their AOs to coordinate the development and timeline delivery of their Rev. 5 transition plan prior to their assessment schedule.
Notably, CSPs will rest assured that their current state Rev. 4 FedRAMP documentation package can remain for their next assessment if it is scheduled for 2023, but will need to deliver their completed transition plan.
3. Continuous Monitoring Phase - CSPs are in the Continuous Monitoring Phase if the CSP has achieved an ATO and are currently in ConMon of their authorization cycle.
The points below detail the actions a CSP will need to take so that the CSP is prepared for the assessment following all Revision 5 implementations and requirements.
Here are some ways that Quzara can assist organizations in their transition to FedRAMP Revision 5:
Gap Assessment Service: Quzara can conduct a comprehensive Gap Assessment that compares your current compliance with the Revision 4 requirements to the new requirements of Revision 5. This service provides an understanding of the differences (the "gap") and what steps need to be taken to comply with Revision 5. The intended outcome is a clear roadmap detailing the actions required for compliance.
Documentation Revision and Preparation: In line with the new requirements, Quzara can aid in the revision of your System Security Plan (SSP), Policies & Procedures, and other ancillary documents. The intended outcome here is to have updated documentation that aligns with the Revision 5 requirements and is ready for submission to the relevant authorities.
Technical Implementation Consultation: Quzara can provide consultation and guidance on necessary technological updates and system hardening to meet new controls, parameters, and enhancements brought about by Revision 5. Our experts can also provide advice on the management of supply chain risk and the integration of third-party solutions. The intended outcome is a system that meets the technical requirements of Revision 5.
Privacy Consultation: Given the heightened emphasis on privacy in Revision 5, Quzara can provide a thorough review of your existing privacy practices and offer suggestions for improvement. This includes the development of privacy training, Privacy Impact Analysis, and more. The intended outcome is an improved privacy posture that aligns with the new FedRAMP guidelines.
Training and Workshops: Quzara can provide training sessions and workshops on Revision 5 for your teams. These would cover the new controls, requirements, and other changes to ensure your team is equipped to handle the transition and maintain compliance thereafter. The intended outcome is a well-informed and competent team ready to tackle the new challenges.
Continuous Monitoring Service: Post-authorization, Quzara can assist in maintaining your compliance with the ongoing monitoring requirements under Revision 5. This includes periodic assessments to ensure compliance is maintained and assisting in the implementation of new controls as they are introduced. The intended outcome is the preservation of your authorization status and a reduced burden on your internal teams.
The transition to Revision 5 of the FedRAMP program is a critical milestone for organizations that provide services and products to the federal government. With its new, comprehensive approach, this revision promises to ensure compliance with security standards in an increasingly complex cyber landscape. By following the guidelines outlined in this article, business owners can successfully navigate their way through the transition period while ensuring that their customers’ data remains secure and compliant with all applicable regulations. As soon as additional information becomes available from FedRAMP, we'll be delving into more intricate details in our upcoming blog posts.
For additional information on this topic, or to learn how Quzara can further help you understand the NIST 800-53 Revision 5 or conduct a Rev. 4 to Rev. 5 gap assessment, contact our team.