FedRAMP and Evolving Requirements for MSPs and SaaS Providers

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The FedRAMP OMB has recently released a memorandum on modernizing the standard to address new realities in digital technology.  This shift reflects the increasing reliance on Software-as-a-Service (SaaS) and the strategic roles of Managed Service Providers (MSPs) in the federal, as well as the impact of new technologies like artificial intelligence.

This article aims to summarize some of these pivotal updates to FedRAMP, unraveling their implications for service providers navigating the nuanced federal marketplace. 


The Shift Towards SaaS in Federal IT

The federal government’s shift toward Software-as-a-Service is more than a trend—it’s a paradigm shift. Agencies are increasingly turning away from traditional on-premises software solutions in favor of the versatility, scalability, and cost-effectiveness that SaaS offers. This pivot is not without its complexities, however. It demands a new approach to security, one that can navigate the cloud’s nebulous borders without compromising security or performance.

With that goal in mind, the new draft memorandum refers to the need for government agencies to utilize a more comprehensive collection of SaaS products rather than relying on larger PaaS or IaaS solutions to host customer software. 

Fortunately, this means that the OMB is also moving to streamline authorization for cloud providers. 


AI and Cloud Security in the New FedRAMP Era


The White House’s recent Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence has significant implications for FedRAMP and, by extension, for MSPs and SaaS providers. 

This order underscores the government’s commitment to harnessing the benefits of AI while mitigating the risks associated with its deployment in federal operations. 

Here’s how the order impacts the FedRAMP mandate:

  • Enhanced AI Security Controls: FedRAMP is expected to integrate AI-specific security controls (specifically through its increased expectation of security automation) to safeguard against unique vulnerabilities and threats AI technologies pose.
  • AI Risk Assessment: Providers must conduct comprehensive risk assessments for AI applications, demonstrating their preparedness to tackle potential AI-related security challenges.
  • AI Governance Frameworks: A requirement for transparent governance and accountability mechanisms for AI use within cloud services could become part of FedRAMP’s authorization process.
  • AI Transparency and Compliance: There may be an emphasis on transparency in AI algorithms and data usage, necessitating providers to document and justify AI decision-making processes. Furthermore, these providers will most likely have a limited number of trustworthy AI firms to work with (specifically, those that meet minimum requirements, according to the EO).
  • AI Training and Awareness: FedRAMP might incorporate standards for training federal employees on the safe use of AI, affecting how providers structure their service offerings.


Modernization and Compliance for MSPs and SaaS Providers

The OMB draft memo proposes new guidance for modernizing the GSA’s FedRAMP program, marking a transformative phase for cloud security and compliance. 

This modernization drive aims to streamline processes and bolster the security of cloud services, affecting MSPs and SaaS providers in several ways:

  • Streamlined Authorization Process: The new OMB guidance will likely refine the FedRAMP authorization process, potentially reducing the time and cost associated with obtaining and maintaining FedRAMP compliance while opening the potential avenues for authorization.
  • Emphasis on Continuous Monitoring: There may be an increased focus on continuous monitoring requirements, ensuring that MSPs and SaaS providers consistently maintain the security standards required by FedRAMP.
  • Alignment with Private Sector Practices: The guidance could bring FedRAMP more in line with private-sector security practices, providing a more familiar framework for MSPs and SaaS providers and facilitating more straightforward adaptation.
  • Greater Accountability and Transparency: With the modernization efforts, providers might face stricter requirements for accountability and transparency in their security practices and data governance.
  • Increased Collaboration: The OMB’s proposed guidance could encourage greater collaboration between cloud service providers, third-party assessors, and government entities, fostering a more cohesive compliance environment.

For MSPs and SaaS providers, staying abreast of these changes is crucial. The new guidance not only impacts their operational and compliance strategies but also affects how they position themselves in the federal marketplace. 


Implications for MSPs and SaaS Providers

The evolution of FedRAMP carries many implications for MSPs and SaaS providers that are crucial for their operational strategy and competitive positioning. Some of the critical implications include:

  • Need for Enhanced Security Measures: With the new security baselines, providers must enhance their security measures to meet the updated controls, especially AI and cloud services.
  • Adaptation to Regulatory Changes: The shifting regulatory environment necessitates a flexible adaptation strategy to keep up with new requirements and guidance.
  • Strategic Investment in Compliance Infrastructure: Providers must invest strategically in their compliance infrastructure to meet the rigorous demands of FedRAMP authorization.
  • Demonstration of Compliance and Transparency: Transparency in security practices and AI algorithms will become more critical than ever, requiring detailed documentation and justification of processes.
  • Continuous Monitoring and Reporting: The focus on continuous monitoring and reporting will require providers to maintain an ongoing compliance and risk management process.
  • Opportunities for Market Differentiation: Providers who can quickly adapt to and comply with the new requirements may differentiate themselves in the marketplace and leverage this as a competitive advantage.

For MSPs and SaaS providers, understanding and integrating these implications into their strategic planning is essential for success in the federal marketplace. By doing so, they can maintain compliance and set themselves apart as leaders in cloud security and innovation.


Maintain Modernized Security with Continuum GRC

The updates to the FedRAMP represent a pivotal moment for MSPs and SaaS providers operating in the federal sphere. The shift toward SaaS, the integration of artificial intelligence, and the modernization of compliance processes underscore a broader transformation within federal IT procurement and cybersecurity standards.

Continuum GRC is a cloud platform that can take something as routine and necessary as regular vulnerability scanning and reporting under FedRAMP and make it an easy and timely part of business in the public sector. We provide risk management and compliance support for every major regulation and compliance framework on the market, including:

  • FedRAMP
  • StateRAMP
  • GDPR
  • NIST 800-53
  • FARS NIST 800-171
  • CMMC
  • SOC 1, SOC 2
  • PCI DSS 4.0
  • IRS 1075
  • ISO 27000 Series
  • ISO 9000 Series
  • ISO Assessment and Audit Standards

And more. We are the only FedRAMP and StateRAMP-authorized compliance and risk management solution worldwide.

Continuum GRC is a proactive cyber security® and the only FedRAMP and StateRAMP-authorized cybersecurity audit platform worldwide. Call 1-888-896-6207 to discuss your organization’s cybersecurity needs and find out how we can help your organization protect its systems and ensure compliance.

Continuum GRC



Authorization Paths in the New FedRAMP OMB Memorandum - Lazarus Alliance, Inc.

[…] a more flexible authorization framework, the OMB and others seek to provide more providers, specifically providers of standalone SaaS applications, a way to work with the program […]

Authorization Paths in the New FedRAMP OMB Memorandum -

[…] a more flexible authorization framework, the OMB and others seek to provide more providers, specifically providers of standalone SaaS applications, a way to work with the program […]