The Federal Risk and Authorization Management Program (FedRAMP) is the U.S. government’s standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services used by federal agencies. If you are a cloud service provider (CSP) that wants to sell to the federal government, FedRAMP authorization is the gatekeeper.

FedRAMP was established in 2011 to solve a practical problem: every federal agency was independently evaluating the security of cloud services, resulting in duplicated effort, inconsistent standards, and a slow procurement process. FedRAMP created a “do once, use many” framework — a CSP achieves authorization once, and that authorization can be leveraged by any federal agency.

The program is built entirely on NIST SP 800-53 security controls, tailored into baselines appropriate for different levels of data sensitivity. Understanding this relationship is essential for any CSP navigating the authorization process. Defense contractors pursuing both FedRAMP and CMMC 2.0 certification face significant control overlap, making a unified approach essential.

Impact Levels and Control Baselines

FedRAMP defines three impact levels based on the potential consequences if the confidentiality, integrity, or availability of the information in the cloud system were compromised. These levels are derived from FIPS 199 categorization. All FedRAMP baselines are currently aligned with NIST 800-53 Revision 5, which was adopted by FedRAMP to ensure consistency with the latest federal security standards.

FedRAMP Low

FedRAMP Low applies to cloud systems where the loss of confidentiality, integrity, or availability would have a limited adverse effect on organizational operations, organizational assets, or individuals.

  • Typical use cases: Public-facing websites, collaboration tools handling non-sensitive data, development and test environments with no production data.
  • Control baseline: Approximately 156 controls drawn from NIST 800-53 Low baseline, plus FedRAMP-specific requirements.
  • Assessment rigor: Lower than Moderate and High, but still requires a Third-Party Assessment Organization (3PAO) evaluation.

FedRAMP also offers a Low Impact SaaS (Li-SaaS) path for low-risk SaaS applications, which uses a streamlined baseline and simplified authorization process.

FedRAMP Moderate

FedRAMP Moderate applies to systems where compromise would have a serious adverse effect. This is the most common impact level for FedRAMP authorizations and covers the majority of federal cloud deployments.

  • Typical use cases: Email systems, case management applications, financial management tools, HR systems, and most business applications that handle controlled but unclassified federal data.
  • Control baseline: Approximately 325 controls drawn from NIST 800-53 Moderate baseline, plus FedRAMP-specific parameters and enhancements.
  • Assessment rigor: Full 3PAO assessment with detailed testing of every control. Moderate represents the bulk of FedRAMP authorizations in the marketplace.

FedRAMP High

FedRAMP High applies to systems where compromise would have a severe or catastrophic adverse effect, potentially involving loss of life, major financial loss, or significant harm to national interests.

  • Typical use cases: Law enforcement systems, emergency services, financial systems, health systems with sensitive patient data, and any system processing highly sensitive government data.
  • Control baseline: Approximately 421 controls drawn from NIST 800-53 High baseline, with the most stringent parameter settings and additional FedRAMP enhancements.
  • Assessment rigor: The most thorough assessment level, with heightened requirements for encryption, access control, incident response, and continuous monitoring.

Each step up in impact level adds controls and increases the specificity of control parameters (e.g., session timeout values, encryption standards, audit log retention periods). The incremental effort from Low to Moderate is substantial, and from Moderate to High is significant again.

Authorization Paths

Historically, CSPs could pursue authorization through two paths: a Joint Authorization Board (JAB) Provisional Authority to Operate (P-ATO) or an Agency Authority to Operate (ATO). In 2023, the JAB was sunsetted as part of FedRAMP program reforms. Authorization now flows through agency sponsors, though the FedRAMP Program Management Office (PMO) continues to play a central coordination and oversight role.

Agency Authorization

This is now the primary authorization path. A CSP works with a specific federal agency that agrees to sponsor the authorization. The process works as follows:

  1. Agency partnership. The CSP identifies a federal agency that wants to use its cloud service and is willing to sponsor the authorization. The sponsoring agency has a direct operational interest in the service, which motivates engagement throughout the process.

  2. Readiness Assessment (optional but recommended). The CSP engages a 3PAO to conduct a Readiness Assessment, producing a Readiness Assessment Report (RAR). This pre-assessment identifies gaps before the full assessment begins, reducing the risk of costly rework.

  3. Full Security Assessment. The 3PAO conducts a comprehensive assessment of the CSP’s cloud system against the applicable FedRAMP baseline. The assessment covers every control in the baseline and produces a Security Assessment Report (SAR).

  4. Authorization package submission. The CSP submits the complete authorization package to the sponsoring agency and the FedRAMP PMO. The package includes:

    • System Security Plan (SSP) — Detailed documentation of the system architecture, boundaries, data flows, and how each control is implemented.
    • Security Assessment Report (SAR) — The 3PAO’s findings from the full assessment.
    • Plan of Action and Milestones (POA&M) — A remediation plan for any findings identified during the assessment.
    • Continuous Monitoring artifacts — Evidence of ongoing monitoring capabilities.

  5. Agency review and ATO issuance. The sponsoring agency’s Authorizing Official reviews the package, accepts the residual risk, and issues the ATO. The authorization is then listed in the FedRAMP Marketplace, making it available for reuse by other agencies.

FedRAMP Marketplace and Reuse

Once authorized, a CSP’s package is available in the FedRAMP Marketplace. Other agencies can review the existing authorization package and issue their own ATO based on the work already done, rather than requiring a new full assessment. This reuse model is the core value proposition of FedRAMP — it reduces duplicated assessment effort across the federal government.

Agencies that reuse an existing authorization may conduct their own review and may add agency-specific requirements, but the baseline assessment work does not need to be repeated.

The Authorization Process in Detail

Regardless of the path, the authorization process follows a consistent lifecycle.

Preparation Phase

  • System categorization. Determine the FIPS 199 impact level based on the types of federal data the system will process.
  • Boundary definition. Clearly define the system authorization boundary — what is included in the assessment scope and what is external. This includes identifying interconnections with other systems and inherited controls from underlying infrastructure (e.g., IaaS controls inherited by a SaaS provider).
  • SSP development. Document every control in the applicable baseline, describing how it is implemented within the system. The SSP is the most labor-intensive artifact in the authorization process and typically runs hundreds of pages.
  • Control implementation. Close gaps identified during SSP development. Every control in the baseline must be implemented or documented as a planned POA&M item (with a compelling justification for the delay).

Assessment Phase

  • 3PAO engagement. Select an accredited 3PAO from the FedRAMP-recognized list. The 3PAO must be independent and accredited by the A2LA (American Association for Laboratory Accreditation).
  • Test plan development. The 3PAO develops a Security Assessment Plan (SAP) defining the scope, methodology, and schedule of the assessment.
  • Control testing. The 3PAO tests each control through a combination of documentation review, interviews with system personnel, and technical testing (including vulnerability scanning and penetration testing).
  • SAR production. The 3PAO documents all findings, categorized by risk level, in the Security Assessment Report.

Authorization Phase

  • POA&M development. For any findings in the SAR, the CSP develops a Plan of Action and Milestones documenting the finding, the planned remediation, the responsible party, and the target completion date.
  • Package review. The Authorizing Official (at the sponsoring agency) reviews the complete package — SSP, SAR, and POA&M — and makes a risk-based authorization decision.
  • ATO issuance. If the residual risk is acceptable, the Authorizing Official issues the ATO.

Continuous Monitoring Phase

Authorization is not the finish line. FedRAMP requires ongoing continuous monitoring throughout the life of the authorization.

  • Monthly vulnerability scanning with results reported to the agency and FedRAMP PMO.
  • Annual security assessments covering a subset of controls (typically one-third of the baseline per year, on a rotating basis).
  • POA&M management with regular updates on remediation progress.
  • Significant change reporting for any material changes to the system architecture, boundary, or control implementation.
  • Incident reporting in accordance with US-CERT and agency-specific requirements.

Failure to maintain continuous monitoring obligations can result in revocation of the authorization. Our audit readiness checklist provides a practical approach to maintaining ongoing compliance readiness.

Typical FedRAMP Authorization Timeline

PhaseDurationKey Activities
Preparation3–6 monthsSystem documentation, SSP development, control implementation, POA&M creation
Assessment3–6 months3PAO selection, Security Assessment Plan, testing, Security Assessment Report
Authorization1–3 monthsAgency review, risk acceptance, ATO issuance, FedRAMP Marketplace listing
Continuous MonitoringOngoingMonthly vulnerability scans, annual penetration testing, annual assessment, ConMon reports

Total estimated timeline: 12–24 months from preparation start to ATO, depending on system complexity, existing security posture, and agency responsiveness. Organizations with existing SOC 2 or ISO 27001 certifications can often accelerate the preparation phase.

Common Challenges in FedRAMP Authorization

Underestimating the SSP effort. The System Security Plan is not a template you fill out in a few weeks. For a Moderate system, the SSP typically requires 6-12 months of dedicated effort to develop. Each of the 325+ controls requires a specific, detailed implementation statement — not generic language, but a description of how your specific system satisfies the control.

Boundary ambiguity. Poorly defined authorization boundaries create problems throughout the process. If the boundary is too broad, you are responsible for more controls than necessary. If it is too narrow, you may have undocumented interconnections that the 3PAO will flag. Define the boundary early and precisely.

Inherited control confusion. Cloud service providers built on top of other authorized cloud platforms (e.g., a SaaS application running on an authorized IaaS provider) can inherit certain controls from the underlying platform. However, inherited controls must be clearly documented, and the CSP remains responsible for any customer-configured or hybrid controls.

Continuous monitoring neglect. Some CSPs invest heavily in achieving authorization and then underinvest in maintaining it. Monthly scanning, annual assessments, and POA&M management are not optional. Agencies and the FedRAMP PMO actively monitor compliance.

How SCF Connect Maps FedRAMP Requirements

SCF Connect includes FedRAMP as a supported framework, mapping its control baselines within the broader Secure Controls Framework taxonomy. This mapping provides several advantages for CSPs pursuing or maintaining authorization.

Because FedRAMP baselines are derived from NIST 800-53, and because many CSPs also need to comply with other frameworks that share NIST 800-53 controls (SOC 2, HIPAA, ISO 27001), SCF Connect’s cross-framework mapping eliminates the need to assess overlapping controls multiple times. A common control framework approach means a control that satisfies FedRAMP Moderate, SOC 2 CC6.1, and ISO 27001 A.9.1 is assessed once in SCF Connect, with the mapping ensuring coverage is reflected across all three frameworks.

The SCF controls reference provides visibility into how individual controls map across frameworks, helping CSPs understand the relationship between their FedRAMP implementation and their broader compliance obligations.

For organizations managing the ongoing continuous monitoring requirements, SCF Connect’s assessment and tracking features provide a structured environment for maintaining compliance evidence, tracking POA&M items, and generating the documentation that FedRAMP requires on a recurring basis.

Getting Started

FedRAMP authorization is a significant undertaking, but it opens the door to the largest single market for cloud services in the world. Understanding the control baselines, choosing the right authorization path, and investing in a compliance infrastructure that supports both the initial authorization and ongoing continuous monitoring are the keys to a successful program.

Start your free trial to see how SCF Connect maps FedRAMP controls within the broader Secure Controls Framework.

Frequently Asked Questions

How long does FedRAMP authorization take?

FedRAMP authorization typically takes 12-24 months from start to finish, including 3-6 months for preparation, 3-6 months for assessment, and 1-3 months for authorization review. The timeline varies significantly based on system complexity, your existing security posture, and whether you pursue agency authorization or the FedRAMP Ready designation first.

What is the difference between FedRAMP Low, Moderate, and High?

FedRAMP Low covers systems with limited impact (110 controls), suitable for publicly available data. FedRAMP Moderate addresses systems where loss could have serious adverse effects (325 controls) and covers most government SaaS. FedRAMP High protects systems where loss could have severe or catastrophic effects (421 controls), required for law enforcement, financial, and health systems.

What is a 3PAO?

A Third Party Assessment Organization (3PAO) is an independent entity accredited by the American Association for Laboratory Accreditation (A2LA) to conduct FedRAMP security assessments. 3PAOs evaluate cloud service providers against FedRAMP requirements and produce the Security Assessment Report (SAR) that agencies use to make authorization decisions.

Can FedRAMP controls satisfy other framework requirements?

Yes — FedRAMP baselines are built on NIST 800-53, which maps extensively to other frameworks. Organizations with FedRAMP authorization often find significant overlap with ISO 27001, SOC 2, and CMMC. Using a common control framework like the SCF makes this overlap visible and eliminates redundant compliance work.

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