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Perspectives

Decoding the FedRamp authorization process for cloud providers

Answers and assistance to accelerate the authorization timeline

The Federal Risk and Authorization Management Program (FedRAMP) authorization is a recognized security milestone. But reaching the destination demands awareness and preparation. The FedRAMP cloud service providers have many questions regarding the process. We are here to answer those queries and assist them to strategize better.

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What is FedRAMP?

Spurred by the U.S. Government’s Cloud First policy, the FedRAMP is a security assessment and authorization process created to provide a consistent and efficient mechanism for applying security and measuring risk in cloud resources used by federal agencies. FedRAMP authorizations are required for multi-tenant clouds that store federal agency data or metadata; they are needed for many U.S. Government cloud contracts.

How does it work?

Despite recently becoming a law, FedRAMP does not operate on its own. It is a program that layers on top of the Risk Management Framework (RMF) and Authorization to Operate (ATO) processes employed by U.S. Government agencies when evaluating whether to use software and services. By issuing cloud-specific guidance and acting as a middleman, FedRAMP makes ATOs more consistent, trustworthy, and reusable across each agency. This means that when your organization is providing a multi-tenant cloud service to the U.S. Federal Government, you will be seeking two authorizations:

  • An agency ATO, coming from your sponsoring agency (or a provisional ATO), will allow you to do business with your contracting agency
  • A FedRAMP authorization, coming from the FedRAMP Program Management Office (PMO), will publicly acknowledge your service as a FedRAMP-authorized cloud service offering (CSO) and allow prospective U.S. Government clients to perform a security review of your system.

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What are the different options?

The FedRAMP process is tailored to your offering as a Cloud Service Provider (CSP). Specific requirements vary based on the type of data stored in your system and how many agencies want to use it. For instance, three different FedRAMP impact levels are available to CSPs, depending on the sensitivity of the data they store. Also, CSPs may move through the FedRAMP process via agency sponsorship or the Joint Authorization Board (JAB).

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  • Develop business case (JAB only)
  • Get prioritized by the JAB or establish agency sponsorship
  • Define authorization boundary
  • Create FedRAMP environment
  • Create SSP and supporting documentationReadiness Assessment Report (JAB requirement, optional for Agency)
  • Full security assessment
  • Review and authorization by JAB or Agency sponsor
  • Continuous monitoring

During and after your authorized Third-Party Assessment Organization (3PAO) assessment, you will be responsible for “Continuous Monitoring” or “ConMon” requirements for the duration of your security authorization. ConMon requirements are both operational and reporting-focused, and they help your sponsoring agency understand the ongoing security health of your organization.

How can Deloitte help?

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3PAO Assessment and advisory

  • Perform complete security assessments or Readiness Assessment Report (RAR) (Requires independence)
  • Perform gap assessments against FedRAMP standards
  • Direct assistance in the design and implementation of security controls, including documentation support
  • Assist in navigating through the authorization process

Security, architecture, and engineering

  • Architecture guidance and hands-on-keyboard support
  • Infrastructure as code development
  • Automation implementation
  • Project management oversight of architecture builds

Vulnerability management

  • Establishing a sustainable, consistent vulnerability management process
  • Establishing effective patching plans and development processes to remediate vulnerabilities

Platform hosting services

  • Hosting services on Deloitte’s PaaS
  • Accelerate your path to authorization by inheriting Deloitte’s controls at the platform and infrastructure layers

Get in touch

Matt Bogusch
Managing Director
Deloitte & Touche LLP
mbogusch@deloitte.com

Scott Maker
Managing Director
Deloitte & Touche LLP
smaker@deloitte.com

Joe Bartos
Senior Manager
Deloitte & Touche LLP
jobartos@deloitte.com

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