If you are in the world of government cloud computing, chances are you have heard of FedRAMP - a rigorous security standard that provides a consistent approach to assessing, authorizing, and monitoring cloud services with government data in mind.
Have you ever wondered why there is no such thing as FedRAMP “Certified,” and why FedRAMP “Authorized” is the proper terminology?
In this post we will review the history of FedRAMP, explain the role of the PMO, discuss FedRAMP “authorization” versus “certification,” and define some key FedRAMP terms.
What is FedRAMP?
FedRAMP is the Federal Risk and Authorization Management Program. It is a government-wide program that provides a standardized approach to security assessment, authorization, and continuous monitoring of cloud products and services.
The goal is to ensure that sensitive government data processed, transmitted, and stored in the cloud is secure from cyber threats.
The program is managed by the FedRAMP Program Management Office (PMO), located within the General Services Administration (GSA), and collaborates with both the Department of Homeland Security (DHS) and the National Institute of Standards and Technology (NIST). The FedRAMP PMO oversees, and reviews vendor assessments conducted by third-party auditors, referred to as Third-Party Assessment Organizations (3PAOs).
In order for a cloud product or service provider to be authorized for use by federal agencies, it must undergo an extensive auditing process. This process includes rigorous testing and evaluation of security controls against established standards whereas the information system/service is granted an authorized status for use in the FedRAMP Marketplace.
The FedRAMP framework and authorization process plays a critical role in ensuring that government data remains secure when using cloud-based technologies.
The History of FedRAMP
The Federal Risk and Authorization Management Program was established in 2011 to provide a standardized approach for assessing and authorizing cloud computing services used by federal agencies. Before FedRAMP, each government agency had its own set of security guidelines which led to inconsistencies in security posture from offering to offering. FedRAMP was created in response to this issue by providing a reference framework that agencies could use to assess the security of cloud services and products.
FedRAMP was developed through collaboration between government agencies, private industry, and cybersecurity experts. The program utilizes a three-step process that includes security assessments conducted by accredited Third Party Assessment Organizations (3PAOs), authorization granted by the agency's Authorizing Official (AO), and continuous monitoring post-authorization to promote and baseline a healthy security posture.
Since its inception, FedRAMP has authorized hundreds of cloud products and services across various industries. It has become a crucial component in the government's push towards digital modernization while ensuring data protection remains a top priority.
As technology evolves, so does FedRAMP. The program continues to update its requirements based on feedback from the community and stakeholders, as well as changes in cybersecurity threats. This feedback promotes that FedRAMP remains an effective, intelligent tool for securing sensitive information in an ever-changing digital landscape.
Who is FedRAMP PMO?
The FedRAMP PMO refers to the Project Management Office of FedRAMP, which is responsible for overseeing the entire FedRAMP initiative, working closely with federal agencies, cloud service providers (CSPs), third-party assessment organizations (3PAOs), and other stakeholders to ensure that all parties understand their roles in the authorization process. The PMO also provides guidance and policy on best practices for implementing security controls and conducting risk assessments.
One of the primary responsibilities of the FedRAMP PMO is maintaining the central repository of information related to authorized CSPs. This includes details about each CSP's offerings -sometimes referred to as a CSO (Cloud Service Offering), as well as their security controls and compliance status. By providing this information in one place, federal agencies can easily find approved CSPs that meet their specific needs.
Without the work of the FedRAMP PMO team, it would be difficult for government agencies to confidently adopt cloud technologies from vendors without understanding their capabilities to meet government data requirements and regulations.
What are FedRAMP Certification Myths?
When it comes to FedRAMP, there is a common misconception that products and services can be “FedRAMP certified” -however, this is not the case. FedRAMP does not provide certifications for any cloud service providers or products/offerings.
The reason for omitting “certification” from the FedRAMP vernacular is simple - security requirements are unique to each government agency and their specific needs. Therefore, FedRAMP has established a standardized set of security controls that must be met to qualify for authorization to operate (ATO).
The reason “FedRAMP Authorized” is the right terminology instead of “Certified” is because certification implies a one-time event where a company passes a test and earns recognition for meeting certain standards. In contrast, FedRAMP authorization requires ongoing monitoring and maintenance of security controls for cloud service providers to maintain their status.
This means that the government provides an ATO for every FedRAMP package. This ATO signifies that a particular product or service meets all necessary security requirements as outlined by the program and is reassessed through continuous monitoring to prevent stagnation or falling out of compliance.
While some may use the term “certification” when referring to FedRAMP compliance, it is important to note that only “authorized” vendors have completed the necessary steps required by the program. For a vendor or product to become authorized, they must undergo extensive testing, interviews, and examination from third-party assessment organizations (3PAOs).
While there may be no such thing as a “FedRAMP certification”, obtaining an authorization remains an essential step in providing secure cloud solutions for federal agencies.
What is a FedRAMP ATO?
A FedRAMP Authorization to Operate (ATO) is a critical element in the CSP’s journey towards achieving compliance with federal security standards. Once a CSP has completed the process of obtaining a FedRAMP authorization, they are allowed to offer their service offering/product listed in the FedRAMP Marketplace to federal government agencies.
To obtain a FedRAMP ATO, a CSP must undergo a rigorous assessment process that evaluates the security controls, policies, and procedures of their cloud offering. This assessment is conducted by one of the accredited/certified FedRAMP 3PAOs that reviews the provider's compliance with the FedRAMP security requirements.
Receiving a FedRAMP ATO demonstrates that the CSP meets the stringent security standards required to manage federal data. It provides confidence to federal agencies that the cloud service is secure and can store, process, and transmit sensitive government information.
The Role of an Auditor (3PAO) in FedRAMP
FedRAMP security assessment via a 3PAO is critical for achieving authorization. The 3PAO conducts independent assessments of cloud offerings/products (to provide objective impartiality of the results) to ensure that the cloud service provider meets the rigorous security requirements set by FedRAMP.
During an audit, the 3PAO evaluates FedRAMP-defined aspects of a CSP's offering/product against a predetermined and previously agreed upon set of security controls/families contained in a Security Assessment Plan (SAP) which designates testing criteria. When the audit is over, the 3PAO-provided Security Assessment Report (SAR) provides a readout of information which identify specific areas where improvements or additional safeguards must be implemented before they can achieve authorization.
Once completed, these audits are submitted to the FedRAMP PMO for review. If the audit report is satisfactory and meets established standards outlined in Government, FedRAMP and NIST guidelines, then authorization can be granted.
Without the essential step of an impartial third party assessment in the process, there would be no way to guarantee that cloud providers meet federal cybersecurity standards providing assurance to government agencies that sensitive data will remain secure while using those services.
While many may refer to the process as FedRAMP certification, the concept conflicts with the program’s fundamental requirement of continuous monitoring and renewed authorization of the FedRAMP ATOs granted to Cloud Service Providers.
It is integral for organizations seeking success in using or advertise cloud services and products which process, store, and transmit government data to understand this terminology and process correctly to make informed decisions about which CSPs meet their specific needs. By using the correct terminology – “FedRAMP Authorized” – we can promote clarity and accuracy of discussions around cybersecurity within the federal government.
While it may seem like a small technicality, understanding the difference between certification and authorization helps maintain an elevated level of security across all federal agencies utilizing cloud services. So next time someone mentions “FedRAMP Certification,” you will know better – it is all about being authorized.