Is FedRAMP Mandatory?

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Cybersecurity is all over the news. With the SolarWinds and Colonial Pipelines hack, we’ve learned the hard way that critical infrastructure is something we cannot take for granted. That’s why it is so important that IT providers understand why compliance frameworks like FedRAMP are necessary.

Is FedRAMP compliance mandatory? Yes. If you provide cloud services to a federal agency, you must earn your FedRAMP ATO. However, instead of seeing this as another hoop to jump through, take the time to better understand why this is so critical for national security and how it can be a huge benefit to your company overall.

What is FedRAMP?

Is FedRAMP mandatory?FedRAMP is a required cybersecurity compliance framework for Cloud Service Providers (CSPs) who want to work with federal agencies as contractors or vendors. Based on several federal security documents, most importantly documents like NIST Special Publication 800-53 and FIPS 199, FedRAMP brings high-level security to cloud providers conceived and tested by top security experts. Within these specifications, FedRAMP dictates a few critical compliance requirements:

  1. Authorization to Operate (ATO): All CSPs must earn their ATO to work with federal agencies. These can come in two forms: a more specific ATO issued by a specific agency or the more general Provisional ATO (P-ATO) issued by the Joint Authorization Board (JAB).
  2. Third-Party Assessment Organizations (3PAO): Every CSP must work with a certified 3PAO during authorization, testing and continuous monitoring.
  3. Documentation and Testing: The CSP and 3PAO must document existing security infrastructure, map out testing and remediation, and perform a battery of penetration and operations tests for ATO.
  4. Continuous Monitoring: After ATO is achieved, all CSPs must plan and undergo continuous monitoring annually to ensure compliance.
  5. Impact Levels: FedRAMP divides compliance tiers into “Impact Levels”: Low, Moderate, and High. Each level derives from FIPS 199 and applies to the kinds of data that the CSP will handle.

The specifics of compliance depend on the agency in question. Typically, the process for gaining your ATO goes as follows:

  1. A federal agency releases an RFP for cloud services specifying their FedRAMP needs, including Impact Level.
  2. A CSP applies and once accepted, can demonstrate that they are compliant or can receive compliance.
  3. The CSP partners with a 3PAO and documents existing security capabilities needed security upgrades or changes and a roadmap for testing.
  4. The 3PAO performs all necessary tests and provides a report to the agency outlining the success or failure of the CSP and any necessary remediation steps.
  5. The CSP devices (in consultation with their 3PAO) a plan for remediation and continuous monitoring, and ATO is awarded.


Is FedRAMP Mandatory?

This all sounds like a lot of work… and it is. The truth is CSPs working with the government could potentially handle critical data that could damage the wellbeing of the public or the functioning of the government. While FedRAMP does not prepare you to handle classified data (or, with the rise of CMMC in 2021, necessarily certify you to handle Controlled Unclassified Information), it does serve as a robust security framework to protect critical information for important agencies.

So, the short answer is “Yes”, FedRAMP is mandatory if you plan to offer cloud services to federal agencies. This includes any cloud service, including SaaS, PaaS or IaaS applications and services.

However, FedRAMP is also incredibly useful on its own. Consider the following:

  • FedRAMP is a strong framework. Compliance with FedRAMP shows that you have a high level of security on your cloud infrastructure. Coupled with something like SOC 2, even a non-industry-specific company can show how seriously they take their security.
  • FedRAMP prepared you to work with security experts. The 3PAO is not simply an assessor. Many 3PAOs are security experts in their own right and can help organizations better their security posture even above and beyond FedRAMP.
  • FedRAMP can help you better understand complex compliance standards. FedRAMP contains a lot of documentation, reporting and regular updates. Undergoing the process can be a huge learning process for your organization when it comes to understanding security automation, managing compliance and security personnel and integrating compliance strategy into your overall business goals.

So, if you are going into the federal space, the FedRAMP is mandatory. However, FedRAMP can also be a big step you can take towards better security and prepare you for high-level frameworks like CMMC, ISO 27001 and HIPAA.


The Continuum GRC Approach

Navigating the complexity of the program has been simplified and streamlined using the highly automated Continuum GRC ITAM. We automate your compliance experience so processes like documentation and reporting (tasks that can take weeks or months) can be completed in days or even hours. We are an experienced and certified 3PAO that has helped enterprise organizations and small businesses alike realize their federal cloud provider compliance goals.

Continuum GRC is proactive cyber security®. 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.

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