The Federal Risk and Authorization Management Program (FedRAMP) provides standardized security requirements for cloud services utilization across federal agencies. As cloud adoption accelerates, ensuring services meet FedRAMP standards is crucial for managing risk. Rigorous evaluation of compliance underpins secure cloud migration. The core artifact demonstrating FedRAMP compliance is a completed System Security Plan (SSP) documenting all security controls, testing evidence, and implementation details. Reviewing SSPs and authorization packages should be the basis for any FedRAMP evaluation. Look for Authorization to Operate (ATO) letters from FedRAMP and a documented history of clean audits. Independent assessors help analyze authorization packages to catch any gaps.
Validating continuous monitoring
FedRAMP obligates services to continuous monitoring and maintenance of compliance post-authorization. Agencies must regularly review updated SSPs, scan reports, and monthly deliverables to confirm ongoing conformance. Alarming trends, unaddressed vulnerabilities, or inconsistencies in reports may indicate monitoring issues. Validate services are fulfilling Continuous Monitoring requirements without fail.
Third-party assessment organizations (3PAOs) conduct in-depth FedRAMP audits and issue authorization recommendations. Not all 3PAOs exhibit equal rigor. Verify which accredited 3PAO performed the assessment. Analyze how deeply and extensively they evaluated controls, evidence, and infrastructure security. Rigorous 3PAO audits ensure genuine FedRAMP adherence versus just “checkbox” compliance.
Examining remediation cadence
FedRAMP requires immediate remediation when new system vulnerabilities are uncovered. Review documentation to confirm how rapidly services address critical issues reported in scans and audits. Slow remediation increases the risk of compromise. Only services demonstrating urgency and discipline in remediation merit trust. Beyond documentation, it is instructive to interview engineering teams managing FedRAMP-authorized services. Quiz them on security protocols, compliance processes, remediation response, and training. Teams displaying fluency in FedRAMP principles likely operate services with diligence. Audit documentation tells part of the story teams’ command of compliance tells the rest.
Sampling policies and training
FedRAMP requires extensive policies and rigorous workforce training. Sample training completion records to confirm all personnel have completed the required courses. Spot-check policy documents like Incident Response Plans, Configuration Management Plans, and Contingency Plans for FedRAMP alignment. Gauging actual staff preparedness and plan quality provides insights documentation alone does not offer.
Compliant configuration of cloud assets and software is foundational to managing risk. FedRAMP dictates several configuration mandates like encryption, access controls, logging, and firewalls. Performing selective first-hand configuration review identifies potential unseen gaps in meeting standards like CIS benchmarks. Hands-on inspection complements trusting documentation assertions.
Testing incident response
The real test of compliance comes when incidents strike. Confirm that services maintain updated Incident Response plans encompassing fedramp certifications requirements. Schedule controlled “intrusion testing” via sanctioned red teams. Gauge detection, response, reporting, and remediation timelines. Robust incident response proves services operate securely even under attack versus simply documenting compliance.
Technical controls are just part of FedRAMP. Equally important is whether services demonstrate a cultural commitment to compliance not just checking boxes. Evidence like leadership emphasizing security, investing in automation, hiring pedigree personnel, or exceeding “minimum required” controls indicate genuine commitment versus apathy towards compliance. Given FedRAMP’s rigor and complexity, many agencies enlist experienced third-party advisers to assist in evaluations. Independent experts augment the internal analysis of security controls, documentation, infrastructure configurations, and more. Their insights bolster evaluation thoroughness and objectivity. Advisory also educates agency teams on compliance nuances strengthening future evaluations.
