A Guide to FedRAMP in 2024: FAQs & Key Takeaways

There’s a whole lot to know about FedRAMP compliance and certification, and while there are countless resources available that ensure information on the subject is in no short supply, it can be daunting to sift through, especially when what you really need are quick, straightforward answers.

That’s why our team at Anchore put together this comprehensive list of FedRAMP FAQs, complete with real-world perspectives and examples where you need them most. Simply find your question in the table of contents on the left, jump down to find the answer, and bookmark this page for when you have future FedRAMP questions and need an answer in a pinch.

Some Background on FedRAMP

What is FedRAMP? What purpose does it serve? 

FedRAMP, which stands for the Federal Risk and Authorization Management Program, is a US Federal compliance program. It provides a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services. 

Essentially, it enables federal agencies to take advantage of the latest SaaS/Cloud offerings. The last 15 years have seen the software industry transition from a perpetual license business model to a subscription business model. What this means is that the most innovative software with the highest productivity gains are only available via a SaaS/Cloud deployment model. This effectively barred federal agencies from access to an entire generation of software vendors. FedRAMP was created in order to address this gap.

The main purposes FedRAMP serves are:

• Ensuring security: It establishes a set of standardized security requirements for cloud service providers (CSPs) who want to work with federal agencies.
• Promoting efficiency: By creating a “do once, use many times” framework, FedRAMP reduces the time and cost associated with security assessments for both government agencies and CSPs.
• Enhancing consistency: It provides a uniform process for assessing and authorizing cloud services across different federal agencies.
• Increasing confidence: FedRAMP helps federal agencies feel more confident in adopting cloud technologies by ensuring that approved services meet rigorous security standards.
• Supporting modernization: By streamlining the adoption of secure cloud services, FedRAMP aids in the federal government’s IT modernization efforts.

What are the governing bodies of FedRAMP? 

FedRAMP has several key governing bodies that oversee its operations and ensure its effectiveness.

1. Joint Authorization Board (JAB): The JAB is the primary governance and decision-making body for FedRAMP. It consists of Chief Information Officers from the Department of Defense (DoD), Department of Homeland Security (DHS), and General Services Administration (GSA). The JAB is responsible for establishing the FedRAMP baseline security requirements and approving provisional authorizations.
2. Office of Management and Budget (OMB): The OMB provides the policy guidance for FedRAMP. It issued the original policy memo that created FedRAMP and continues to provide oversight.
3. FedRAMP Program Management Office (PMO): Housed within the GSA, the PMO manages the day-to-day operations of FedRAMP. It’s responsible for developing and maintaining FedRAMP processes, templates, and guidance. The PMO also coordinates between agencies, cloud service providers, and third-party assessment organizations (3PAOs).
4. National Institute of Standards and Technology (NIST): While not a direct governing body, NIST plays a crucial role by providing the risk framework and security controls that FedRAMP is based on; respectively the Risk Management Framework (RMF), NIST 800-37 and the Control Catalog, NIST 800-53.
5. FedRAMP Technical Review Board: The TRB provides technical expertise to the PMO and JAB. It reviews security authorization packages and provides recommendations.
6. Federal CIO Council: This council, consisting of CIOs from various federal agencies, provides strategic direction for FedRAMP and ensures it aligns with broader federal IT initiatives.

These bodies work together to ensure that FedRAMP remains effective, up-to-date, and aligned with federal cybersecurity needs. Their collaborative efforts help maintain the program’s integrity and its ability to serve federal agencies and cloud service providers effectively.

What’s the difference between FedRAMP & FISMA? 

The Federal Information Security Management Act of 2002 (FISMA) is a federal law that requires all federal agencies to implement an information security program to protect the agency’s data. FedRAMP is a compliance program that proves a cloud service provider complies with FISMA and can be adopted by federal agencies.

Here are the key differences:

1. Purpose
   • FISMA: Establishes a comprehensive framework to protect government information, operations, and assets against natural or man-made threats.
   • FedRAMP: Provides a standardized approach specifically for assessing, authorizing, and continuously monitoring cloud products and services.
2. Scope
   • FISMA: Applies to all federal agencies and their information systems, including both cloud and non-cloud systems.
   • FedRAMP: Focuses exclusively on cloud services used by federal agencies.
3. Implementation
   • FISMA: Requires each federal agency to develop, document, and implement an agency-wide program to secure its information systems.
   • FedRAMP: Provides a centralized certification process for cloud services that can be reused by multiple agencies.
4. Authorization
   • FISMA: Each agency is responsible for authorizing its own systems.
   • FedRAMP: Offers a “do once, use many times” approach, where a cloud service authorized for one agency can be more easily authorized for use by other agencies.
5. Standards
   • FISMA: Mandates the use of NIST standards for security categorization and controls.
   • FedRAMP: Also uses NIST standards but provides specific baseline security requirements for cloud services at low, moderate, and high impact levels.
6. Continuous Monitoring (ConMon)
   • FISMA: Requires agencies to continuously monitor their own systems.
   • FedRAMP: Includes a standardized approach to continuous monitoring specifically for cloud services.
7. Historical Context
   • FISMA: Enacted in 2002 (updated in 2014 as FISMA Reform Act) to address overall federal information security.
   • FedRAMP: Established in 2011 specifically to support the government’s cloud-first initiative.

Making the Decision to Pursue FedRAMP ATO

Who needs to be FedRAMP certified? 

FedRAMP certification is primarily required for:

Cloud Service Providers (CSPs)

Any company offering cloud-based products or services that want to do business with US federal government agencies needs to be FedRAMP certified. This includes:

• Software-as-a-Service (SaaS) providers, like Salesforce, Atlassian, Zoom, etc.
• Infrastructure-as-a-Service (IaaS) providers, like Amazon Web Services, Microsoft Azure and Google Cloud

Third-Party Assessment Organizations (3PAOs)

Organizations that perform the initial and periodic assessments of cloud systems for FedRAMP compliance must themselves be accredited by the FedRAMP Program Management Office (PMO).

Federal Agencies

While agencies don’t get “certified,” they need to use FedRAMP-authorized cloud services for their cloud deployments that involve federal data.

It’s important to note that:

• Non-cloud products and services used by federal agencies fall under different security frameworks (like FISMA) and don’t require FedRAMP certification.
• State and local governments often look for FedRAMP certification as a sign of strong security practices, even though it’s not officially required at those levels.

If a company is considering offering cloud services to any federal agency, then FedRAMP certification will be necessary.

What are the benefits? Is FedRAMP certification worth it? 

The decision to pursue FedRAMP certification can be significant for a company. Here are the key benefits and considerations to help determine if it’s worth it:

Benefits

1. Access to Federal Market: Opens up a large market of federal agencies as potential customers. The US government spends billions annually on cloud services.
2. Competitive Advantage: Differentiates your company in the marketplace; can be attractive to non-federal customers who value high security standards.
3. Improved Security Posture: The rigorous process often leads to overall improvements in a company’s security practices.
4. Reusability: Once certified, the authorization can be leveraged across multiple federal agencies.
5. Streamlined Compliance: Jump starts progress toward other compliance certifications (e.g., HIPAA, SOC 2) due to overlapping controls.

Considerations

1. Cost: The certification process can be expensive, potentially costing hundreds of thousands to millions of dollars.
2. Time Investment: The process is lengthy, often taking 12-18 months or more.
3. Ongoing Maintenance: Requires continuous monitoring and regular reassessments.
4. Resource Intensive: Demands significant staff time and may require hiring specialized personnel.
5. Complexity: The process is rigorous and complex, requiring a deep understanding of security practices.

Is it worth it?

Whether FedRAMP certification is worth it depends on:

• Your target market (how important federal customers are to your business strategy)
• Available resources (both financial and personnel)
• Long-term business goals
• Current security posture (how much work is needed to meet FedRAMP requirements)

For companies with a strong focus on serving federal agencies or those in industries where security is paramount, the benefits often outweigh the costs. However, for smaller companies or those not targeting federal customers, the investment may not be justified.

How long does it take to get FedRAMP certified?

The FedRAMP certification process can be lengthy and complex. While the duration can vary depending on several factors, here’s a general timeline:

Typical Duration

• On average, the full FedRAMP certification process takes about 12-18 months.
• Some organizations may complete it in as little as 6-9 months, while others might take 2 years or more.

Factors Affecting Timeline

• Readiness of the Cloud Service Provider (CSP)
• Complexity of the system
• Level of security authorization required (Low, Moderate, or High)
• Chosen authorization path (Agency Authorization or JAB Provisional Authorization)
• Responsiveness of the CSP to assessment findings
• Current workload of the reviewing bodies

Key Phases and Approximate Durations

• Preparation and Readiness Assessment: 1-3 months
• Documentation Development: 3-6 months
• Third-Party Assessment: 2-4 months
• Agency Review and Authorization: 3-6 months

Continuous Monitoring (ConMon)

• After initial authorization, continuous monitoring is ongoing

Considerations

It’s important to note that this timeline assumes a relatively smooth process. Delays can occur if:

• The system has significant security gaps that need addressing
• Documentation is incomplete or inadequate
• There are delays in remediation of identified issues
• The reviewing agency has a backlog

To expedite the process, CSPs are advised to:

• Thoroughly prepare before starting the formal process
• Engage with a FedRAMP consultant or experienced advisor
• Ensure all documentation is complete and accurate from the start
• Be responsive to inquiries and quick to address any identified issues

Remember, while the initial certification is a significant milestone, FedRAMP compliance is an ongoing process requiring continuous monitoring and periodic reassessments.

What is the cost of achieving FedRAMP ATO? 

The cost of achieving FedRAMP Authorization to Operate (ATO) can vary significantly depending on several factors. Here’s a breakdown of the typical costs and considerations:

Overall Cost Range

• Generally, costs can range from $500,000 to $2 million or more.
• Some organizations report spending up to $5 million for complex systems or high-impact level authorizations.

Key Cost Factors

•    Size and complexity of the cloud system
•    Current security posture and how much work is needed to meet FedRAMP requirements
•    Level of authorization sought (Low, Moderate, or High impact)
•    Whether using internal resources or external consultants

Specific Cost Areas

• Internal Labor Costs:
  • Often the largest expense, typically ranging from $400,000 to $1 million+
  • Includes time for security team, developers, management, etc.
• Third-Party Assessment Organization (3PAO) Fees:
  • Usually between $150,000 to $300,000 for initial assessment
  • Ongoing annual assessments can cost $50,000 to $150,000
• Consulting Fees (if used):
  • Can range from $100,000 to $500,000 or more
  • Helps with readiness, documentation, and guidance through the process
• Technology and Tools:
  • $50,000 to $200,000 for security tools, monitoring systems, etc.
• Documentation and Preparation:
  • Can cost $100,000 to $300,000 if outsourced

Ongoing Costs

• Annual continuous monitoring and maintenance can cost 30-50% of the initial authorization cost

Hidden Costs

• Potential system upgrades or redesigns to meet security requirements
• Opportunity costs of dedicating resources to FedRAMP instead of other projects

Cost-Saving Strategies

• Thorough preparation before starting the formal process
• Leveraging existing security controls and documentation
• Using FedRAMP-compliant cloud infrastructure providers, like AWS GovCloud

It’s important to note that while these costs are significant, they should be weighed against the potential return on investment from accessing the federal market and the overall improvement in security posture.

Companies considering FedRAMP authorization should conduct a thorough cost-benefit analysis and potentially consult with FedRAMP advisors to get a more accurate estimate based on their specific situation.

The FedRAMP Certification Process 

What are the FedRAMP impact levels? 

FedRAMP categorizes cloud systems into three impact levels based on the potential impact of a security breach. These levels are directly aligned with the Federal Information Processing Standard (FIPS) 199. Here are the three FedRAMP impact levels:

Low Impact

• For systems where the loss of confidentiality, integrity, and availability would have a limited adverse effect on an agency’s operations, assets, or individuals.
• Typically involves publicly available information or non-sensitive data.
• Requires implementation of the FedRAMP Low baseline security controls.

Moderate Impact

• For systems where a loss would have a serious adverse effect on an agency’s operations, assets, or individuals.
• This is the most common level for federal systems.
• Covers a wide range of sensitive but unclassified data.
• Requires implementation of the FedRAMP Moderate baseline security controls.

High Impact

• For systems where a loss could have a severe or catastrophic adverse effect on organizational operations, assets, or individuals.
• Involves highly sensitive information, including certain types of law enforcement and emergency services data, financial data, health records, and other critical assets.
• Requires implementation of the FedRAMP High baseline security controls, which are the most rigorous.

Key points

• The impact levels are a pyramid, each higher level incorporates all the controls from the lower levels—plus additional ones.
• The number of security controls increases significantly with each level (Low: 125, Moderate: 325, High: 421 controls).
• Agencies determine the appropriate impact level based on the type of data they plan to store or process in the cloud system.
• Cloud Service Providers (CSPs) can choose which impact level(s) to pursue certification for, based on their target market and capabilities.

The impact level determines the depth and breadth of the security assessment, influencing both the cost and time required for FedRAMP authorization. Higher impact levels generally require more extensive security measures and more rigorous assessments.

What are the FedRAMP requirements for each impact level? 

The FedRAMP requirements for each impact level are inherited from NIST 800-53, which serves as the authoritative reference for security controls for many federal compliance programs (e.g., SSDF, ATO/cATO, CMMC, etc).

Here’s an overview of the requirements for each impact level:

Low Impact

Total Controls: 125

Key Requirements:

• Basic access control (AC)
• Simple audit (AU) capabilities
• Basic incident response (IR) plan
• Minimal personnel security (PS)
• Basic system and information integrity (SI) measures

Moderate Impact

Total Controls: 325

Key Additional Requirements:

• More robust access control (AC), including multi-factor authentication (MFA)
• Enhanced audit and accountability (AU) measures
• Comprehensive incident response (IR) and handling
• Contingency planning (CP) and disaster recovery
• Enhanced personnel security (PS) measures
• More rigorous system and information integrity (SI) controls
• Configuration management (MC)
• Media protection (MP)

High Impact

Total Controls: 421

Key Additional Requirements:

• Advanced access control (AC) mechanisms
• Stringent audit and accountability (AU) measures
• Sophisticated incident response (IR) and handling procedures
• Comprehensive business continuity (CP) and disaster recovery planning
• Rigorous personnel security (PS) vetting
• Advanced system and information integrity (SI) controls
• Strict configuration and change management (CM)
• Enhanced media protection (MP) and data encryption
• Supply chain risk management (SR)

Common themes

• Access Control (AC)
• Awareness and Training (AT)
• Audit and Accountability (AU)
• Security Assessment and Authorization (CA)
• Configuration Management (CM) 
• Contingency Planning (CP)
• Identification and Authentication (IA)
• Incident Response (IR) 
• Maintenance (MA)
• Media Protection (MP)
• Physical and Environmental Protection (PE)
• Planning (PL) 
• Personnel Security (PS)
• Risk Assessment (RA)
• System and Services Acquisition (SA)
• System and Communications Protection (SC)
• System and Information Integrity (SI)

The specific requirements within each of these areas become more stringent as the impact level increases. Cloud Service Providers must implement and document all required controls for their target impact level(s) and undergo a third-party assessment to verify compliance.

It’s important to note that these requirements are regularly updated to address evolving security threats and technologies. CSPs must stay current with the latest FedRAMP requirements and continuously monitor and maintain their systems to ensure ongoing compliance.

What are the steps to getting FedRAMP certified? 

The process of obtaining FedRAMP certification involves several key steps. Here’s a high-level overview of the typical path to FedRAMP authorization:

1. Preparation and Readiness Assessment
   • Determine the impact level you’re targeting (Low, Moderate, High)
   • Conduct a gap analysis between your current security posture and FedRAMP requirements
   • Develop a plan to address any identified gaps

1. Choose an Authorization Path
   • Agency Authorization: Work directly with a specific federal agency
   • Joint Authorization Board (JAB) Provisional Authorization: A centralized authorization process
2. Engage a Third-Party Assessment Organization (3PAO)
   • Select an accredited 3PAO to perform your assessment
3. Complete FedRAMP Documentation
   • Develop the System Security Plan (SSP)
   • Create other required documents (e.g., Incident Response Plan, Contingency Plan)
4. Implement Security Controls
   • Put in place all required security measures based on your impact level
5. Conduct the Readiness Assessment
   • 3PAO performs an initial assessment to ensure you’re ready for the full audit
6. Remediate Any Issues
   • Address any gaps or vulnerabilities identified in the readiness assessment
7. Full Security Assessment
   • 3PAO conducts a comprehensive assessment of your system and documentation
8. Develop the Security Assessment Report (SAR) and Plan of Action & Milestones (POA&M)
   • 3PAO creates the SAR
   • You develop the POA&M to address any remaining issues
9. Submit Package for Review
   • Submit your full authorization package to the FedRAMP PMO or your sponsoring agency
10. Obtain Authorization
    • The reviewing body assesses your package and grants authorization if all requirements are met
11. Continuous Monitoring (ConMon)
    • Implement ongoing monitoring and reporting to maintain your authorization

Stakeholders

Throughout this process, you’ll likely interact with:

• Your internal team
• The 3PAO
• FedRAMP PMO (Program Management Office)
• Sponsoring agency (if pursuing Agency Authorization)
• Potentially, FedRAMP consultants or advisors

Remember, this is a complex and time-consuming process that typically takes 12-18 months or more. Each step may involve multiple sub-steps and iterations. Many organizations find it beneficial to work with experienced FedRAMP consultants to navigate this process effectively.

What tools or solutions can help me achieve FedRAMP compliance? 

Several tools and solutions can assist in achieving and maintaining FedRAMP compliance. Here’s an overview of key categories and some examples:

Compliance Management Platforms

• Automated tools to track controls, manage documentation, and monitor compliance
• Examples: Coalfire FedRAMP Assurance, A-LIGN’s A-SCEND, Schellman Comply

Security Information and Event Management (SIEM)

• Centralized logging and security event monitoring
• Examples: Splunk, Panther, RunReveal

Vulnerability Scanning and Management

• Identify and track vulnerabilities in your systems
• Examples: Anchore Enterprise

Configuration Management

• Ensure systems are configured according to FedRAMP requirements
• Examples: Chef, Puppet, Ansible

Identity and Access Management (IAM)

• Manage user access and implement multi-factor authentication
• Examples: Okta, Microsoft Azure Active Directory, AWS IAM

Encryption Tools

• Protect data at rest and in transit
• Examples: Hashicorp Vault, AWS Key Management Service

Continuous Monitoring (ConMon) Solutions

• Automate ongoing security assessments
• Examples: Anchore Enterprise

Document Management Systems

• Organize and maintain required documentation
• Examples: Drata, AuditBoard, Archer Insight

Incident Response and Management

• Tools to help detect, respond to, and manage security incidents
• Examples: PagerDuty, ServiceNow Security Operations

Cloud Access Security Brokers (CASBs)

• Visibility and control over cloud service usage
• Examples: Microsoft Defender for Cloud Apps, Cloudflare CASB

Network Security Tools

• Firewalls, intrusion detection/prevention systems
• Examples: Cloudflare, Palo Alto Networks, F5

Data Loss Prevention (DLP)

• Prevent unauthorized data exfiltration
• Examples: Zscaler, Cloudflare DLP

When selecting tools:

• Ensure they meet FedRAMP requirements for their respective functions
• Consider solutions that integrate well with your existing infrastructure
• Look for tools that can generate reports in FedRAMP-required formats
• Prioritize solutions that can help automate compliance processes

Remember, while these tools can significantly aid in achieving and maintaining FedRAMP compliance, they’re not a substitute for a comprehensive security program and expert guidance. Many organizations use a combination of these tools along with consulting services to navigate the FedRAMP process effectively.

Other FedRAMP FAQs

What’s the difference between ATO and P-ATO? 

ATO (Authority to Operate) and P-ATO (Provisional Authority to Operate) are both important designations in the FedRAMP certification process, but they have distinct differences:

ATO (Authority to Operate)

• Issued by: A specific federal agency
• Scope: Authorizes a Cloud Service Provider (CSP) to operate for that specific agency
• Process: The agency reviews the CSP’s security package and grants authorization based on their risk tolerance and specific needs
• Usage: Allows the CSP to provide services to that particular agency
• Validity: Generally valid for 3 years, subject to continuous monitoring

P-ATO (Provisional Authority to Operate)

• Issued by: The Joint Authorization Board (JAB)
• Scope: A provisional authorization that can be leveraged by any federal agency
• Process: The JAB reviews the CSP’s security package and grants a provisional authorization based on a rigorous baseline assessment
• Usage: Serves as a starting point for agencies to grant their own ATOs, potentially speeding up the process
• Validity: Generally valid for 3 years, subject to continuous monitoring

Key Differences

Issuing Authority

• ATO: Individual agency
• P-ATO: Joint Authorization Board (DoD, DHS, and GSA)

Reusability

• ATO: Specific to the issuing agency
• P-ATO: Can be leveraged by multiple agencies

Process Complexity

• ATO: Can be less complex, depending on the agency’s requirements
• P-ATO: Generally more rigorous due to the need to meet a baseline acceptable to multiple agencies

Time and Resource Investment

• ATO: Can be faster if working with a single agency
• P-ATO: Often more time-consuming and resource-intensive

Market Access

• ATO: Limited to the issuing agency
• P-ATO: Provides a pathway to serve multiple agencies more easily

It’s important to note that a P-ATO is not a final authorization to operate. Each agency must still review the security package and issue its own ATO, but the P-ATO can significantly streamline this process.

CSPs often pursue a P-ATO if they plan to serve multiple agencies, as it can provide broader market access. However, if a CSP is focused on serving a specific agency, pursuing an ATO directly with that agency might be more efficient.

Have there been any changes to FedRAMP?

Yes, FedRAMP has undergone several changes and updates since its inception in 2011. Here are some of the most significant recent changes and ongoing initiatives:

FedRAMP Authorization Act (December 2022)

• Codified FedRAMP into law, cementing its role in federal cloud security
• Aimed to streamline the authorization process and promote reuse of authorizations across agencies
• Established the Federal Secure Cloud Advisory Committee to provide guidance on FedRAMP

FedRAMP Modernization — Transition to Revision 5 (Ongoing)

• Aligns FedRAMP with NIST SP 800-53 Revision 5
• Introduces new security controls and enhances existing ones
• Expected to be fully implemented by the end of 2024 -> follow updates on FedRAMP modernization efforts

Automation Initiatives

• Development of the Open Security Controls Assessment Language (OSCAL) to automate security documentation
• Efforts to streamline the authorization process through increased automation

Threat-Based Methodology (2021)

• Introduction of a threat-based approach to assess and authorize cloud products and services
• Focuses on addressing specific threat scenarios relevant to federal agencies

FedRAMP Tailored for Low-Impact Software-as-a-Service (LI-SaaS)

• Streamlined process for authorizing low-risk cloud applications
• Reduced the number of controls required for certain low-impact systems

Continuous Monitoring (ConMon) Strategy Updates

• Enhanced requirements for ongoing security monitoring and reporting
• Introduction of more frequent vulnerability scans and penetration testing

Enhanced Reuse Capabilities

• Improved processes for agencies to reuse existing ATOs, reducing duplication of effort

Agency Liaison Program (2020)

• Established to improve communication and collaboration between FedRAMP and federal agencies

Marketplace Updates

• Ongoing improvements to the FedRAMP Marketplace to provide more detailed and user-friendly information about authorized cloud services

These changes reflect FedRAMP’s ongoing efforts to improve efficiency, enhance security, and adapt to evolving technology and threat landscapes. As FedRAMP continues to evolve, cloud service providers and federal agencies should stay informed about the latest updates and requirements.

Next Steps

FedRAMP is an exhaustive topic as evidenced by the length of this article. The important thing to remember when beginning this journey to achieving FedRAMP compliance is that it is a journey. This is a process that takes time. If you’re looking for shortcuts to get to the punchline as quick as possible, be sure to read our case study on how Cisco Umbrella utilized Anchore Enterprise to achieve FedRAMP compliance in weeks versus months or reach out to our team directly and we can walk you through how we can help your organization achieve similar results.