FedRAMP implementation

Federal Risk and Authorization Management Program (FedRAMP) is a US government initiative that provides a standardized process for evaluating, authorizing, and continuously monitoring the security of cloud products and services used by federal agencies. Its goal is to ensure that cloud solutions used by the US federal agencies meet consistent, rigorous security standards, helping safeguard sensitive government data stored in the cloud.

Challenges in implementing FedRAMP SSP, POAM, and OSCAL requirements

Cloud service providers (CSPs) aiming to serve US federal agencies through FedRAMP authorization encounter several significant hurdles. These challenges arise due to the program’s stringent security standards, complex authorization process, and requirement for continuous compliance.

  • High documentation burden

    • System Security Plan (SSP) and Plan of Action and Milestones (POAM) reports are extensive and detailed, requiring hundreds of data points across multiple sections and controls.

    • Manual updates to these documents are time-consuming and prone to errors, especially during monthly (POAM) or during authorization cycles (SSP).

  • Data fragmentation across tools and teams

    • Vulnerability data is sourced from security scans, Security Assessment Reports (SARs), manual findings, and questionnaires.

    • Each source uses different formats, terminology, and structure, making it difficult to consolidate and normalize data for reporting.

  • Lack of standardization in security scans

    • CSPs must run at least three types of security scans, often with tools from different vendors such as Tenable, Rapid7, and Qualys.

    • These scans generate CSV files with inconsistent column names and structures, requiring custom mapping for each provider.

  • Manual data entry and duplication risks

    Without automation, teams manually copy and paste data into FedRAMP templates, increasing the risk of human error, duplicate vulnerabilities, and incomplete records.

  • Complex control implementation tracking

    • Each FedRAMP control requires detailed implementation evidence, walkthroughs, and metadata.

    • Tracking hundreds of controls and ensuring completeness is a significant operational challenge.

  • Continuous compliance and monthly reporting

    • The POAM report must be submitted monthly, requiring accurate tracking of vulnerabilities and remediation status.

    • CSPs must maintain a live inventory of vulnerabilities and ensure timely updates and exports.

  • OSCAL format requirements

    • FedRAMP increasingly mandates machine-readable formats like Open Security Control Assessment Language (OSCAL), adding complexity to the export process.

    • CSPs must ensure their data is structured correctly to meet OSCAL schema requirements.

  • Coordination across security and compliance teams

    • Completing FedRAMP documentation requires input from multiple stakeholders: security teams for scan data, compliance teams for remediation plans, and project owners for control walkthroughs.

    • Ensuring collaboration and accountability across teams is essential but challenging.

People involved in FedRAMP implementation

The people involved in FedRAMP implementation include:

  • CSP and FedRAMP advisory firm

  • Third-party assessment organization (3PAO)

  • Security and compliance professionals

  • Federal and sponsoring agencies

  • Joint Authorization Board (JAB)

  • Third-party assessment organizations (3PAO)

FedRAMP solution guides

Implementing FedRAMP, SSP, POAM, and OSCAL reporting toolkit

Set up the FedRAMP toolkit to automate SSP, POAM, and OSCAL reports.

Implementing SSP workflow

Use the SSP Automation Robot to create and export your System Security Plan.

Implementing POAM workflow

Run the POAM robots to collect, review, and export vulnerability data.