Creating a Successful FedRAMP Continuous Monitoring Program

A Federal Risk and Authorization Management Program (FedRAMP) continuous monitoring program is designed to ensure that cloud systems and services comply with security requirements on an ongoing basis. The goal is to provide operational visibility, manage change control, and attend to incident response duties. The effectiveness of a CSP’s continuous monitoring capability supports ongoing authorization and reauthorization decisions.

Operational Visibility: As part of the continuous monitoring process, CSPs are required to provide Authorizing Officials (AO) with evidence on a specified frequency to help them evaluate the CSP’s risk posture. CSPs must also have a 3PAO perform an assessment. During this assessment all controls are tested to meet the desired level of effort.
Change Control: Systems are in constant change and FedRAMP anticipates this. CSPs must ensure that any changes made to their Cloud Service Offering (CSO) are done so through a change control process that ensures the changes are evaluated for security impact. CSPs are required to maintain a Configuration Management Plan that details how changes are controlled within the CSO.
Incident Response: CSPs must demonstrate adequate response to security incidents. CSPs are required to maintain an Incident Response Plan that defines the process for responding to incidents and the plan must meet the incident response and reporting guidance located in the FedRAMP Incident Communications Procedures.

Continuous monitoring practices are adopted by organizations or businesses to oversee and manage their IT systems' security on an ongoing basis. For FedRAMP these practices are specifically tailored to cloud service providers (CSPs) offering services to federal agencies. The program aligns with the security controls and standard set forth by the Federal Risk and Authorization Management Program (FedRAMP).

What is the Federal Risk and Authorization Management Program (FedRAMP)?

Designed to safeguard cloud solutions across the government, FedRAMP ensures that CSPs meet rigorous security standards and guidelines when offering services to government agencies.

With securities and standards based on NIST (National Institute of Standards and Technology) guidelines, cloud service providers must meet and obtain ATO (authorization to operate) status. Security requirements and controls will vary based on the sensitivity of data your organization will be handling.

Learn more about how organizations are growing their cloud business through FedRAMP authorization here.

How does continuous monitoring play a role in the FedRAMP ATO process?

To maintain an authorization that meets FedRAMP requirements, CSPs must continually demonstrate that the security posture of their service offerings is continually acceptable. Continuous monitoring in the FedRAMP ATO process involves ongoing assessment and reporting, enabling agencies to have real-time visibility into the security status of cloud systems and services handling federal data, thus mitigating risks and ensuring compliance with FedRAMP security standards.

As defined by NIST, the process of continuous monitoring includes:

Define a continuous monitoring strategy based on risk tolerance that maintains clear visibility into assets and awareness of vulnerabilities
Establish measures, metrics, and status monitoring, and control assessments that make known the status of security control effectiveness
Implement a continuous monitoring program that collects required data, measures and reports findings, and automates data collection.
Analyze the data gathered and report findings accompanied by recommendations.
Respond to assessment findings and make decisions to mitigate all vulnerabilities
Review and update the continuous monitoring program to increase visibility, enhance data driven security, and increase organizational flexibility

An important aspect of a CSPs continuous monitoring program is to provide evidence that demonstrates the efficacy of its program. CSPs and assessors must be prepared to provide this evidence at a monthly, annually or moments notice frequency.

What is FedRAMP looking for when it comes to continuous monitoring?

Vulnerability scanning results:
- Authenticated vulnerability scans using system credentials. These should include any applicable operating system, infrastructure, database, and web application scans.
- Enable all non-destructive plugins for scans, ensuring all vulnerabilities are discovered.
- Full system boundary scanning to include all components within the systems boundary.
Annual 3PAO assessments based on agreed upon controls that must be documented in a Security Assessment Plan (SAP) and approved by the AO.
In depth Plan of Actions and Milestones (POA&Ms) that addresses all scan findings as well as assessment findings which are updated until all findings have been remediated or validated.
Effective change control processes that require security impact assessments. If the assessment determined the change will have an adverse affect on the integrity of the authorization, the CSP must complete a FedRAMP Significant Change Request Form and provide it to the AO for review. If it is deemed to be a significant change, the CSP must coordinate with the 3PAO to perform an assessment based on a SAP developed by the 3PAO. The CSP will also be required to submit updated documentation based on the newly implemented changes.
Effective incident response processes that show that the CSP has the capability to respond to incidents. The CSP must submit to the AO and maintain an Incident Response Plan. The CSP is expected to follow the reporting guidance located in the FedRAMP incident Communications Procedure. In addition, FedRAMP or AOs may require CSPs to treat vulnerabilities deemed as critical as incidents and require the CSPs to remediate the vulnerabilities if possible or implement mitigating factors. There may be reporting requirements to the PMO concerning the status of the vulnerabilities.

What is the first step to a successful FedRAMP continuous monitoring program?

The first step towards establishing a successful FedRAMP continuous monitoring program involves understanding and thoroughly comprehending the specific requirements, guidelines, and expectations outlined by FedRAMP for continuous monitoring.

It's essential for CSPs aiming for FedRAMP authorization to thoroughly review and understand the Continuous Monitoring Strategy Guide to ensure their continuous monitoring practices align with FedRAMP requirements. This guide serves as a valuable resource for implementing robust and compliant continuous monitoring programs for cloud services intended for use by federal agencies.

Here are key aspects covered in the FedRAMP Continuous Monitoring Strategy Guide:

Continuous Monitoring Overview: The guide offers an overview of continuous monitoring, ongoing authorization, and how a successful continuous monitoring program will help an organization maintain security authorization that meets FedRAMP requirements.
FedRAMP Continuous Monitoring Requirements: It details the specific requirements, controls, and standards mandated by FedRAMP for CSPs to follow in their continuous monitoring programs. This includes NIST-based security controls, assessment frequencies, incident response, configuration management, vulnerability scanning, and reporting.
Continuous Monitoring Plan Development: The guide outlines the necessary steps to create a comprehensive continuous monitoring plan tailored to the unique needs of CSPs seeking FedRAMP authorization. This includes developing strategies for security control assessment, vulnerability management, incident response, and compliance reporting.
Tools and Technologies: Guidance is provided on selecting and implementing appropriate automated tools and technologies to support continuous monitoring activities. This may encompass security information and event management (SIEM) systems, intrusion detection systems (IDS), vulnerability scanners, and other relevant solutions.
Incident Response and Reporting Procedures: The guide covers protocols and procedures for detecting, responding to, and reporting security incidents promptly. It outlines the necessary steps CSPs should take in case of a security breach or incident involving federal data.
Documentation and Reporting Standards: Details are provided on maintaining accurate documentation and reporting on continuous monitoring activities, security control assessments, compliance status, identified vulnerabilities, and remediation efforts. This includes the format and frequency of reporting required by FedRAMP.
Adaptation and Improvement Strategies: The guide may also include recommendations for adapting and enhancing the continuous monitoring program over time. This involves learning from incidents, reassessing risks, updating security controls, and aligning with evolving security threats and regulatory changes.
Roles and Responsibilities: Clear delineation of roles and responsibilities within the CSP organization for executing continuous monitoring activities, ensuring accountability and efficient execution of the monitoring plan.

The #1 thing you can do to create a successful FedRAMP continuous monitoring program

Creating a successful FedRAMP continuous monitoring program requires expertise in cloud security, compliance, risk management, and a comprehensive understanding of FedRAMP requirements. Selecting the right partner can help you achieve authorization on an accelerated timeline.

Whether you need short-term assistance or a full FedRAMP partner, the team at DataLock Consulting Group has the expertise in cybersecurity, compliance, and FedRAMP to help CSPs develop and implement a robust continuous monitoring program. We can provide guidance on strategy, risk assessment, policy development, and implementation of necessary controls. Additionally, as a certified 3PAO, our experts can evaluate and assess a CSPs security posture against FedRAMP requirements.

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