Achieving FedRAMP authorization is a monumental task, and one that should be celebrated, but it is also just the first step in working with the U.S. Government. Many Cloud Service Providers (CSPs) lose sight of this fact and risk maintaining their authorization. In this blog we introduce some of the key considerations and highlight a new pitfall each month to help CSP protect their investment.
Maintaining FedRAMP authorization is crucial for CSPs serving federal agencies. The Federal Risk and Authorization Management Program (FedRAMP) sets stringent security standards to ensure the safety and reliability of cloud services used by the federal government and as of 2023 on-going authorization is required by law for continued use of the Cloud Service Offering (CSO). Let's explore the considerations for maintaining FedRAMP authorization.
Maintaining FedRAMP authorization is vital for CSPs to continue offering their services to federal agencies. It involves ongoing compliance with security requirements and regular assessments to ensure that the cloud environment remains secure. Without continuous monitoring and the updating of the system to new FedRAMP requirements, like the Revision 5 updates, can mean the possibility of losing your authorization and having to repeat the authorization process to regain a lost authorization.
Regularly monitoring security incidents and events is crucial for identifying potential threats and vulnerabilities. And allows for effectively triaging and responding to security incidents within FedRAMP time constraints.
Conducting regular vulnerability scans helps identify and address security weaknesses in the cloud environment. Don't forget to prioritize vulnerabilities based on severity and impact and create effective and timely remediation plans to address identified issues.
Effective patch management is essential for mitigating known vulnerabilities. It's imperative that you keep all systems and applications up to date with the latest patches.
Maintaining secure configurations helps prevent security misconfigurations that could be exploited by attackers. Don't forget to make document configuration changes and ensure they comply with security policies.
Conducting regular security control assessments ensures that all security controls are functioning as intended. Make sure your annual assessments and Significant Change Requests are submitted with enough time for your agency partner to review to meet expected timelines.
All these tasks should be covered in the CSP's Continuous Monitoring (ConMon) Plan. CSPs also need to understand that they must maintain comprehensive documentation and regular reporting to your agency partners to demonstrate maintenance of system security and compliance with FedRAMP requirements.
A major part of your ConMon plan is managing the POA&M. This is crucial for tracking the remediation of identified security issues. Make sure you document security findings and remediation actions in the POA&M and track progress with regular POA&M updates.
A nuance within the Revision 5 FedRAMP Baseline (Moderate and above) is the change in hardening requirements under CM-6. Where revision 4 of the FedRAMP Baseline required CIS Level 1 Benchmarks, Revision 5 requires DISA STIGs or in certain cases CIS Level 2.
Given that Revision 5 was released last year, it is assumed that as part of your on-going maintenance of a FedRAMP Authorized CSO, you will have migrated your hardening standards from using CIS Level 1 to STIG or CIS2. If you have not done this, you are at risk in maintaining your FedRAMP Authorization, or at a minimum receiving a High finding as part of your annual assessment. You can partially mitigate this risk by having a plan to transition to CIS Level 2 or DISA STIGS when asked by your assessing 3PAO (and if you're not asked this, you should be re-evaluating your assessing partner, as FedRAMP has been clear in their guidance on this topic) or FedRAMP. This plan must include a realistic timeline, well-defined milestones, and an end date for the transition. We recommend that the end date of the transition be before the CSP's next annual assessment. And don't forget to document and track the transition in the Plan of Action and Milestones (POA&M).
Maintaining FedRAMP authorization is an ongoing process that requires diligent adherence to security standards and continuous improvement of security practices. By following the guidelines provided by FedRAMP and ensuring effective management of the CSP's FedRAMP program, CSPs can achieve and maintain the necessary authorization to serve federal agencies securely.
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