Navigate FedRAMP: A step-by-step checklist

TLDR: The Federal Risk and Authorization Management Program (FedRAMP) provides a framework that allows cloud computing service organizations to demonstrate security performance over their cloud for an Authorization to Operate (ATO) with a federal agency. This process is designed to enable federal agencies to adopt secure solutions. Implementing a FedRAMP Checklist streamlines efficiency and effectiveness for cloud service providers (CSPs) to manage their security assessments, documentation, and FedRAMP compliance program. This guide will assist with obtaining an Agency ATO or a Joint Authorization Board (JAB) Provisional-ATO (P-ATO). It includes key starting steps, best practices, and essential documents needed for a successful FedRAMP authorization journey.

FedRAMP checklist: Steps to achieve authorization

Step 1: Pre-authorization readiness assessment

Building a robust FedRAMP Checklist helps any cloud service offering (CSO) align with federal government expectations for cybersecurity. Before seeking FedRAMP authorization, conduct a thorough readiness assessment to identify potential gaps and ensure you meet baseline FedRAMP requirements. This initial evaluation involves:

1. Evaluating Impact Level: Based on FIPS 199 guidelines, determine whether your system data is categorized as Low, Moderate, or High Impact.
2. Reviewing Existing Security Controls: Compare your current security policies and configurations against FedRAMP compliance standards and mark down any gaps or improvements.
3. Initial Document Collection: Gather initial required documentation on your information system, including configuration management procedures, system boundaries, and data flow diagrams.

Step 2: Building a system security plan

The System Security Plan (SSP) is central to FedRAMP compliance and your FedRAMP authorization journey. The SSP outlines how your organization addresses relevant security controls and manages configuration management processes across your cloud services. Key components include:

• System overview: Architecture diagrams and data flow.
• Security requirements mapping: Demonstrating alignment with NIST SP 800-53 controls.
• Configuration management processes: Steps to manage changes without introducing new security risks.

Step 3: Engaging a third-party assessment organization

A qualified third-party assessment organization (3PAO) plays an essential role in verifying FedRAMP compliance. 3PAOs conduct independent security assessments to ensure your organization follows FedRAMP requirements and meets federal security standards.

Choosing the right 3PAO is a vital step. A well-trained assessor can guide you through the complexities and help you correct issues before final submission.

Step 4: Conducting a security assessment

During the security assessment, the 3PAO validates the effectiveness of your CSP environment’s security controls. This stage often involves:

• Configuration Management Review: Ensuring changes to the information system adhere to approved processes.
• Security Controls Evaluation: Verifying each implemented control meets FedRAMP baseline requirements.
• Penetration Testing: Assessing your environment for exploitable vulnerabilities. The penetration test includes:
• External Testing (Internet-facing assets)
• Internal Testing (Authenticated access within the system)
• Web Application Testing
• Database Testing
• Network Segmentation Testing
• Privilege Escalation Testing

The security assessment is your proof of due diligence, confirming that implemented controls effectively protect federal data. Working through the above steps in order will ensure a successful outcome, as will incrementally working through your gaps with an experienced 3PAO.

Key documentation for FedRAMP authorization

Essential templates and documents

Your authorization package generally includes at least three core documents:

1. System security plan (SSP): The foundational document for system description, responsibilities, and security measures.
2. Security assessment report (SAR): Generated by the 3PAO post-assessment, detailing vulnerabilities, threats, and any residual risk.
3. Plan of action and milestones (POA&M): Outlines remediation steps for identified weaknesses, including timelines and responsible personnel. For some regulatory requirements, having PO&AM documentation for several lower-impact controls may be enough to show agencies you have a roadmap for becoming compliant.

You can find official FedRAMP.gov documents and templates to ensure consistent formatting and compliance.

Security assessment report

The Security Assessment Report (SAR) consolidates the results of the security assessment process performed by the 3PAO. It includes:

• Identified vulnerabilities and their potential impact.
• Detailed methodology on how testing was conducted.
• A thorough risk analysis explaining how each finding affects your system’s security posture.

An accurate, transparent SAR instills confidence in both the FedRAMP PMO and federal agencies reviewing your request.

Developing a contingency plan

An Information System Contingency Plan details how your services will maintain or quickly restore operations in the event of a security breach, natural disaster, or any other serious incident. Steps include:

• Incident response plan: Step-by-step procedures to handle security incidents.
• Backup and recovery procedures: Methods and timelines for data restoration and system recovery.
• Testing frequency: Regular plan reviews and mock scenarios, also known as table-top exercises, with cross-department personnel.

The most effective way to obtain FedRAMP authorization is to leverage their document templates and then meet with key stakeholders to gather information. Having an expert on staff or as a consultant to fill out the documents is also a plus, as they will be able to decipher information from stakeholders and integrate it into the system plans.

Navigating the FedRAMP authorization process

The role of the FedRAMP PMO and JAB

The FedRAMP PMO (Program Management Office) supports cloud service providers by providing guidance, policies, and resources throughout the FedRAMP requirements cycle. It coordinates with CSOs, reviews documentation, and ensures consistent standards.

The Joint Authorization Board (JAB) is composed of representatives from key federal agencies, such as DHS, GSA, and DOD, and is responsible for granting Provisional Authority to Operate (P-ATO).

What are the different types of FedRAMP authorization?

1. Agency ATO: Granted by a specific federal agency to a CSP for its cloud environment. The agency then sponsors the cloud service and assumes risk responsibility.
2. JAB P-ATO: Provisional authority allows government-wide reuse of a cloud service provider. A JAB P-ATO generally holds more weight, as multiple agencies can leverage the CSP solution with minimal rework.

Submitting the authorization package

After completing your security assessment and finalizing all necessary FedRAMP documentation, leverage the FedRAMP Initial Authorization Package Checklist to determine what files to upload and which require FedRAMP templates.

1. Finalize the SSP, SAR, and POA&M: Ensure each document is accurate, consistent, and free of major gaps. Work with your 3PAO to submit the System Assessment Plan documents, including Security Controls Selection Worksheet.
2. Submit the Package: Working with you 3PAO, Send these materials to either the FedRAMP PMO or your sponsoring federal agency.
3. Undergo the Review Process: The PMO or agency will evaluate your package for completeness and compliance.

Submitting a well-organized authorization package significantly reduces review times and potential rework.

Continuous monitoring and maintaining FedRAMP compliance

Continuous monitoring activities

Earning an ATO or P-ATO is a milestone, but maintaining FedRAMP compliance requires ongoing diligence through continuous monitoring. This involves regular security assessments, updates to your incident response plan, and annual reviews of security controls. These tasks help you stay aligned with evolving threats and federal agencies’ expectations. Common activities include:

• Ongoing vulnerability management: Conducting regular vulnerability scans and promptly addressing findings. Adding unaddressed findings to the PO&AM documentation.
• Annual security control review: Ensuring security controls remain effective and up-to-date. This includes policies, procedures, and the scope of your information system.
• Incident response updates: Refining and testing your response plans to keep pace with new risks.

Monthly reporting requirements

FedRAMP reporting involves updating POA&M, maintaining an accurate system inventory, and conducting various scans (OS, network, container, DB, web) to identify and address security vulnerabilities, ensuring comprehensive monitoring and remediation. Specific requirements include:

1. Vulnerability scan reports: Summaries of newly identified system vulnerabilities and applied patches. These scans typically include Operating System (OS) and network scans to detect infrastructure-level threats, container scans to identify issues within containerized workloads, database (DB) scans to safeguard stored data, and web scans to mitigate application-layer risks. In addition, remediation scans are performed to confirm that previously identified vulnerabilities have been successfully resolved.
2. POA&M updates: Detailed progress on remediation items, including timelines and statuses.
3. Configuration management reports: Documentation of any system changes and how they align with FedRAMP requirements.

Consistent reporting keeps your environment transparent and fosters trust with federal stakeholders. Oversight of these activities should coincide with operations and security teams rather than become an administrative burden. Creating automated reports by using IT service management processes and agile digital tools will reduce overhead.

Common challenges in achieving FedRAMP authorization

Understanding complex security requirements

The wide range of FedRAMP security requirements, which are aligned with NIST controls, can overwhelm newcomers. Many organizations underestimate the scale of required evidence for security controls and the depth of documentation needed.

Navigating the documentation process

Compiling the System Security Plan (SSP), Security Assessment Report (SAR), and Plan of Action and Milestones (POA&M) can be complex, particularly for first-time applicants. Common pitfalls include:

• Overlooking security control requirements and improper categorization.
• Inconsistent or incomplete data in the SSP; inaccurate system scope.
• Delayed updates to reflect system changes.

Engaging with the right third-party assessors

Selecting a qualified 3PAO can make or break your timeline for FedRAMP authorization. Inexperienced assessors may miss critical findings or fail to guide you adequately through remediation.

Partnering with experienced 3PAOs who are well-versed in FedRAMP’s rigorous standards and can provide actionable guidance. Leveraging the experience of an expert can help you set up systems for updating requirements more efficiently and effectively.

Best practices for a successful FedRAMP authorization

Early preparation and planning

Building a robust approach from the start can streamline the authorization process and minimize rework. Organizations that begin FedRAMP efforts well in advance of formal submission often find they can more easily identify and resolve security control gaps. Early planning also:

• Simplifies documentation updates.
• Reduces resource bottlenecks. Assigning ownership and setting expectations from the top of the organization are critical.
• Ensures alignment with 3PAO, federal agency or JAB feedback.

Leveraging automation tools

Automation solutions help track security assessments, manage POA&M items, and produce compliance evidence with less manual effort. For instance, some providers automate vulnerability scans or facilitate continuous updates to the SSP.

Maintaining open communication with federal agencies

Ongoing dialogue with the sponsoring federal agency or the FedRAMP PMO helps clarify requirements and expedite authorization processes. Offer regular status updates and promptly address any concerns about your cloud services security posture.

Build and scale an effective FedRAMP program

Implementing a scalable FedRAMP solution across your organization ensures a sustainable, high-confidence posture. By bringing together risks, controls, policies, and frameworks into one system, AuditBoard’s platform empowers you to meet rising compliance needs and continuously improve cybersecurity.

A well-structured FedRAMP program is a long-term investment in cybersecurity, helping your organization remain compliant and resilient amid evolving threats.

Ready to level up your compliance efforts? Build an effective FedRAMP program with AuditBoard's FedRAMP solution is designed to help organizations develop and scale. Key features include:

• Stakeholder collaboration: Facilitates communication by deploying surveys and automating evidence collection, maintaining an audit trail in a centralized location.
• Efficient evidence management: Allows organizations to collect evidence once and utilize it across multiple audits and assessments, reducing redundancy and stakeholder fatigue.
• Framework control mapping: Provides visibility into controls applicable to specific frameworks, enabling users to view overlaps and focus on testing relevant controls.
• Compliance issue management: Automates issue identification during testing, assigns action plan owners, and tracks progress, streamlining the creation of management-ready audit reports.

These features aim to empower organizations to meet increasing compliance needs by integrating risks, controls, policies, frameworks, and issues into a cohesive system.

About the authors

Cindy Kuan is a Manager of Product Solutions at AuditBoard. Prior to joining AuditBoard, Cindy spent 5 years with EY Los Angeles and 1 year with The Walt Disney Company specializing in technology audits, SOX/ICFR, and SOC Reporting across Biotechnology, Technology, and Real Estate industries.