Since July 2024, the Federal Risk and Authorization Management Program, or FedRAMP, has undergone significant changes that will greatly impact the way cloud service providers (CSPs) are able to obtain authorization to work alongside the federal government and its agencies. 

Prior to the recent revision, the authorization process was conducted via one of two methods: Authorize to Operate (ATO) by way of agency authorization, and Provisional Authority to Operate (P-ATO) via the Joint Authorization Board (JAB). Both methods included a three-step process: Preparation, Authorization, and Continuous Monitoring. 

Now, there is a singular authorization process, ATO, making P-ATO no longer an option for CSPs. 

Recent Changes to Authorization Process

As part of the revision, FedRAMP has introduced several measures that are aimed at speeding up the authorization process without sacrificing the necessary level of scrutiny.

Streamlined Authorization Process 

One of the notable changes involves the modernization of the process for achieving ATO. Previously, obtaining FedRAMP authorization was a complex and time-consuming process, involving multiple steps and significant investment from CSPs. However, with these new changes, FedRAMP is moving towards streamlining the authorization process while maintaining the integrity of security standards, meaning there will be only one authorization method for CSPs — ATO.

With FedRAMP’s new streamlined process, comes the dismantling of the JAB and the P-ATO process, and the implementation of the new governing body, the FedRAMP Board. The board will, “approve and help guide FedRAMP policies, bring[ing] together the federal community to create a robust authorization ecosystem,” said Eric Mill, the executive director for cloud strategy at the U.S. General Services Administration (GSA).

Due to the single authorization method, communication will become more fluid, ensuring that CSPs can address agency concerns in real time, which is expected to expedite approvals. The program has also emphasized more transparent guidelines, clarifying the steps needed to achieve compliance. This reduces the guesswork for cloud service providers and enables them to better align their security practices with federal requirements from the onset, rather than having to backtrack and make corrections during the authorization process. 

The goal of this new streamlined process is to get more CSPs through the authorization pipeline faster while still maintaining robust security standards, which is a stark difference from the P-ATO process that was only conducted during specific times of the year. This effort was created based on the feedback within the cloud service industry where companies voiced concerns about the length of time it takes to gain authorization, especially given the rapid pace at which technology changes.

Emphasis on Automations

Among the most impactful changes is the increased emphasis on continuous monitoring and automation. The use of automated tools that can assess security controls in real-time allows cloud service providers to detect vulnerabilities swiftly and efficiently throughout the entire FedRAMP process. This shift towards automation aims to minimize human error, improve response times to threats, and ensure that cloud environments remain secure as they continue to grow and change. Continuous monitoring will now play a more central role in FedRAMP, allowing agencies and cloud providers alike to be better equipped to respond to cybersecurity threats.

This emphasis on automation is supported by a new technical documentation hub that was specifically designed to support CSPs during the authorization process. The automate.fedramp.gov website offers CSPs with all the necessary documentation to support them during the authorization process. This documentation includes detailed technical specifications, best practices, and guidance on managing their authorization packages. 

The intention of this new hub is to provide CSPs with quicker and more frequent documentation updates, improve the user experience for those implementing FedRAMP packages and tools, and to provide a collaborative workflow.

There are plans in place to expand the capabilities of the hub, with the intention to also integrate FedRAMP authorization submissions.

Implementation of Red Teaming 

Previous authorization methods included a three-step process: preparation, authorization, and continuous monitoring. In previous iterations, part of the preparation process for both methods was an initial assessment of the CSOs done by an independent third-party assessment organization (3PAO).

The appointed 3PAOs would conduct a thorough evaluation of the CSP’s security package, which included both a documentation review and testing of the cloud service’s implementation of their security controls. Additionally, CSPs were required to provide monthly and annual security assessments, vulnerability scans, and other documentation to prove their ability to protect federal data as part of their continuous monitoring.

With this new revision, FedRAMP has also introduced a new mandate surrounding red teaming, adding an additional layer of scrutiny for cloud security. Red teaming is an advanced form of ethical hacking where security experts simulate real-world attacks on cloud environments to uncover vulnerabilities that traditional testing methods might miss. This new mandate requires CSPs to undergo periodic red teaming assessments, ensuring that their systems can withstand sophisticated threats that are constantly evolving in the cybersecurity landscape.

By simulating these real-world attacks, red teaming identifies weaknesses before they can be exploited, giving CSPs the chance to proactively address potential threats. It’s a vital step in recognizing the importance of not just meeting baseline security standards but continuously improving security postures to keep pace with emerging threats. 

While this new requirement adds an additional layer to the authorization process, it also provides peace of mind for both the CSPs and government agencies, reinforcing the trust necessary for working with sensitive government data. 

Conclusion

At its core, FedRAMP allows federal agencies to leverage modern cloud technologies while maintaining the necessary security protocols. However, as technology evolves and cybersecurity threats become more sophisticated, FedRAMP has had to adapt to ensure CSPs can remain flexible while still adhering to the government’s stringent security requirements. 

These significant changes reflect not only the evolving world of cybersecurity threats, but also the increasing complexity of cloud environments. This revision highlights the program’s adaptability and commitment to maintaining a high level of security across all federal cloud environments. The foundation laid by these updates will help streamline the authorization process, enhance monitoring capabilities, and ultimately provide greater assurance that government data remains protected in an ever-changing threat landscape.

As these recent changes continue to take effect, they are set to shape the future of cloud security for federal agencies, creating a more secure and efficient path forward for cloud adoption across the U.S. government. SEM will be closely following the ongoing evolution of the FedRAMP process and will continue to provide you with the latest updates and guidance to help you navigate the authorization process effectively.