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Federal Compliance

FedRAMP Authorization Pathway

Complete guide to FedRAMP authorization for cloud service providers. Understand impact levels, authorization pathways, and achieve Authority to Operate.

325

Moderate Controls

12-24

Months to Authorize

3

Impact Levels

300+

Authorized Products

What is FedRAMP?

Federal Risk and Authorization Management Program (FedRAMP) is the U.S. government's standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services.

Mandatory for Federal

All cloud services used by federal agencies must be FedRAMP authorized. No authorization = no federal contracts.

Authorize Once, Use Many

Once authorized, any federal agency can use your service without re-authorizing, saving time and cost.

Continuous Monitoring

Authorization requires ongoing monitoring, vulnerability scanning, and annual assessments to maintain ATO.

FedRAMP Impact Levels

Choose your impact level based on the sensitivity of data your system will process

Low Impact

For systems where loss would have limited adverse effect

Controls:156 controls
Timeline:6-12 months
Est. Cost:$150K-400K

Examples:

Public websites, collaboration tools, non-sensitive data

Most Common
Moderate Impact

For systems where loss would have serious adverse effect

Controls:325 controls
Timeline:12-18 months
Est. Cost:$400K-1.5M

Examples:

Most federal data, PII, financial data, law enforcement sensitive

High Impact

For systems where loss would have severe or catastrophic effect

Controls:421 controls
Timeline:18-24+ months
Est. Cost:$1.5M-3M+

Examples:

National security, law enforcement, emergency services, healthcare

Authorization Pathways

Two paths to FedRAMP authorization-choose based on your situation

Agency Authorization

6-18 months

Partner with a specific federal agency to sponsor your authorization

Advantages:

  • Faster path for CSPs with existing agency relationships
  • Agency provides direct guidance and requirements
  • Lower initial investment than JAB
  • Can reuse authorization across other agencies

Challenges:

  • Requires finding agency sponsor
  • Agency-specific requirements may apply
  • Each additional agency requires review

Best for: CSPs with existing federal customers or agency relationships

Joint Authorization Board (JAB)

12-24 months

Authorization by DoD, DHS, and GSA for government-wide use

Advantages:

  • Highest visibility and credibility
  • Prioritized by FedRAMP PMO
  • Accepted across all federal agencies
  • FedRAMP Connect helps match CSPs with agencies

Challenges:

  • Highly competitive selection process
  • Longer timeline and higher cost
  • Strict prioritization criteria
  • Limited slots available

Best for: CSPs with broad government appeal and strong security posture

Our Recommendation

Most CSPs should pursue the Agency Authorization path first. It's faster, less expensive, and once authorized, you can reuse your authorization package for other agencies. The JAB path is best reserved for CSPs with broad government appeal and strong existing security programs.

Key Control Families

FedRAMP controls are based on NIST SP 800-53, organized into families

Access Control (AC)

Policies and procedures for system access

Account managementAccess enforcementSeparation of duties+2 more

Audit & Accountability (AU)

Logging and monitoring requirements

Audit eventsContent of audit recordsAudit storage+2 more

Security Assessment (CA)

Continuous assessment and authorization

Security assessmentsSystem interconnectionsPOA&M management+1 more

Configuration Management (CM)

System configuration and change control

Baseline configurationConfiguration change controlSecurity impact analysis+1 more

Contingency Planning (CP)

Business continuity and disaster recovery

Contingency planSystem backupSystem recovery+2 more

Identification & Authentication (IA)

User and device identification

User identificationDevice identificationAuthenticator management+1 more

Incident Response (IR)

Security incident handling

Incident handlingIncident monitoringIncident reporting+1 more

System & Communications Protection (SC)

Network and communications security

Boundary protectionTransmission confidentialityCryptographic protection+1 more

Authorization Timeline

Typical phases for achieving FedRAMP authorization (Moderate baseline)

1

Phase 1

Preparation

2-4 months

Build foundation for FedRAMP authorization

Conduct FedRAMP readiness assessment
Determine impact level
Select authorization pathway
Identify sponsoring agency (if agency path)
Engage 3PAO (Third Party Assessment Organization)
Begin documentation development
2

Phase 2

Documentation

3-6 months

Develop required security documentation

Complete System Security Plan (SSP)
Document all control implementations
Develop policies and procedures
Create contingency and incident response plans
Prepare POA&M for any gaps
Complete SAR readiness activities
3

Phase 3

Assessment

2-4 months

3PAO conducts independent security assessment

3PAO reviews documentation
Penetration testing conducted
Vulnerability scanning performed
Control testing and interviews
Security Assessment Report (SAR) developed
Remediate findings and update POA&M
4

Phase 4

Authorization

1-3 months

Agency or JAB reviews and grants authorization

Submit authorization package
PMO/Agency review of documentation
Address reviewer questions
Receive Authority to Operate (ATO)
List on FedRAMP Marketplace
5

Phase 5

Continuous Monitoring

Ongoing

Maintain authorization through continuous monitoring

Monthly vulnerability scans
Annual penetration testing
Ongoing POA&M management
Significant change requests
Annual security assessment
ConMon deliverables to FedRAMP

Required Documentation

FedRAMP requires extensive security documentation

System Security Plan (SSP)

Critical

Comprehensive document describing system architecture and security controls

Typical size: 300-800+ pages

Security Assessment Report (SAR)

Critical

3PAO assessment findings and recommendations

Typical size: 100-300 pages

Plan of Action & Milestones (POA&M)

Critical

Remediation plan for identified vulnerabilities

Typical size: Living document

Contingency Plan

Critical

Business continuity and disaster recovery procedures

Typical size: 50-100 pages

Incident Response Plan

Critical

Procedures for handling security incidents

Typical size: 30-60 pages

Configuration Management Plan

System configuration and change control procedures

Typical size: 30-50 pages

FedRAMP vs. Other Frameworks

How FedRAMP compares to SOC 2 and ISO 27001

AspectFedRAMPSOC 2ISO 27001
BasisNIST SP 800-53AICPA Trust Services CriteriaISO/IEC 27001 Annex A
Controls156-421 (by impact level)~60-80 criteria93 controls
Assessment3PAO + Government reviewCPA firm auditAccredited registrar
Timeline12-24 months3-6 months6-12 months
Cost$500K-3M+$30K-100K$50K-200K
Validity3 years (with ConMon)12 months3 years (annual surveillance)

Building on Existing Compliance

If you already have SOC 2 or ISO 27001, you've done 30-50% of the work for FedRAMP. Many controls overlap, and your existing documentation can be adapted for FedRAMP requirements.

Common Pitfalls to Avoid

Learn from others' mistakes on the FedRAMP journey

Underestimating Scope

FedRAMP authorization is a major undertaking. Companies often underestimate the time, resources, and documentation required.

Solution: Plan for 12-24 months and $500K-2M+ depending on impact level. Engage experienced FedRAMP consultants early.

Inadequate Documentation

Generic policies and incomplete SSP are common causes for delays. Every control must be specifically addressed.

Solution: Use FedRAMP templates, document control implementations in detail, and engage technical writers.

Weak Continuous Monitoring

Achieving authorization is only the beginning. Many CSPs struggle with ongoing ConMon requirements.

Solution: Build ConMon processes from day one. Automate vulnerability scanning, log collection, and reporting.

No Agency Sponsor

Starting FedRAMP without an agency sponsor or realistic path to JAB leads to stalled authorization.

Solution: Secure agency commitment before investing heavily. Consider agency path before JAB.

Insufficient Boundary Definition

Unclear or overly broad system boundaries increase scope, cost, and complexity significantly.

Solution: Clearly define authorization boundary. Use inherited controls from FedRAMP-authorized IaaS where possible.

Underestimating 3PAO Role

Choosing inexperienced 3PAO or not engaging them early enough leads to assessment delays and findings.

Solution: Select experienced FedRAMP 3PAO, engage them during documentation phase, conduct readiness assessment.

Ready to Pursue FedRAMP Authorization?

Our compliance experts have helped cloud service providers achieve FedRAMP authorization. From readiness assessment to continuous monitoring, we guide you through the entire process.

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