Beyond the Certification: Why FedRAMP Compliance is an Ongoing Commitment

Obtaining FedRAMP compliance is an achievement in itself. It is, however, far from the end of the road for FedRAMP compliance. With that in mind, here is a straightforward guide to why FedRAMP compliance is an ongoing commitment.

Understanding FedRAMP’s continuous monitoring requirements

FedRAMP’s continuous monitoring (ConMon) requirements ensure that cloud service providers (CSPs) maintain the same security standards after certification as they did during initial authorization. This ongoing process helps detect and address vulnerabilities, ensuring compliance with NIST 800-53 security controls.

Here are the four key continuous monitoring activities.

Monthly security scans: CSPs must conduct regular vulnerability scans on operating systems, databases, and applications to identify and mitigate security risks.
Annual security assessments: A third-party assessment Organization (3PAO) must perform a yearly evaluation to ensure security controls remain effective.
Incident reporting and response: CSPs must report security incidents to federal agencies and the FedRAMP Program Management Office (PMO) and take immediate action to resolve threats.
Real-time compliance monitoring: Automated tools track security configurations and access controls to prevent unauthorized changes.

The risks of compliance fatigue

The need to maintain ongoing compliance can result in compliance fatigue. Leaders need to take action promptly if this happens as it creates serious risks. Here are just three of the main ones.

Loss of FedRAMP authorization

Compliance fatigue can lead to missed security updates, delayed vulnerability remediation, or failure to meet continuous monitoring (ConMon) requirements. If a cloud service provider (CSP) fails to submit required reports or address security issues, they risk losing their FedRAMP authorization, resulting in revoked Agency ATO or JAB P-ATO status.

Increased security vulnerabilities

Organizations that deprioritize compliance may fall behind on security patches, access controls, and risk assessments. This creates gaps that cybercriminals can exploit, leading to potential data breaches, ransomware attacks, or insider threats. Given that FedRAMP focuses on protecting sensitive government data, lapses in compliance can have national security implications.

Reputation damage and loss of business

A lapse in compliance can erode trust with government agencies and potential clients. Organizations that fail to maintain FedRAMP security standards may struggle to win new contracts or retain existing ones, impacting long-term business growth.

The role of automation and security tools in ongoing compliance

Automation and security tools have made it much easier to ensure ongoing compliance. Here are just four of the ways they can help.

Streamlining continuous monitoring

Automated security monitoring tools help cloud service providers (CSPs) maintain continuous compliance by continuously scanning systems for vulnerabilities. These tools can perform real-time assessments and security checks, ensuring that any potential issues are immediately detected and addressed. Automation reduces the need for manual intervention, making monitoring more efficient and reducing human error.

Real-time threat detection and alerts

Automation tools like Security Information and Event Management (SIEM) systems enable CSPs to detect security incidents in real-time. These tools track network traffic, identify anomalies, and send alerts about potential security breaches. This allows CSPs to respond quickly to threats, which is crucial for maintaining compliance with FedRAMP’s incident reporting requirements.

Ensuring consistent security configurations

Automation tools ensure that security configurations remain consistent across all environments. By automating security patches and updates, CSPs can quickly apply fixes and prevent vulnerabilities caused by outdated software, a key aspect of FedRAMP’s continuous monitoring.

Automating reporting and documentation

Tools can automate the generation of compliance reports, saving time and ensuring that documentation is accurate and up-to-date. Automated reporting simplifies the process of maintaining FedRAMP’s stringent documentation requirements, such as security control assessments and vulnerability scan reports.

Best practices for maintaining FedRAMP compliance

Following these five best practices will help significantly with maintaining FedRAMP compliance.

Establish a dedicated compliance team

Assign a team or individual responsible for overseeing ongoing compliance efforts. This team should monitor security controls, manage documentation, and coordinate with third-party assessment organizations (3PAOs) for regular audits. Having a dedicated team ensures that compliance is prioritized and maintained consistently.

Conduct regular internal audits

Schedule frequent internal audits to evaluate the effectiveness of security controls and ensure alignment with FedRAMP requirements. These audits help identify gaps before external audits and enable timely remediation of any vulnerabilities.

Implement automated security monitoring

Use automation tools to continuously monitor systems for vulnerabilities, track access controls, and apply security patches. Automated tools reduce human error, improve response times, and ensure continuous compliance with FedRAMP’s security monitoring requirements.

Provide regular employee training

Ensure that employees are trained on FedRAMP requirements, cybersecurity best practices, and how their actions impact compliance. Regular training sessions help create a security-conscious culture and reduce the risk of compliance lapses due to human error.

Maintain updated documentation

Keep all compliance documentation up-to-date, including System Security Plans (SSPs), vulnerability scan reports, and incident response records. Well-maintained documentation facilitates audits and demonstrates ongoing compliance to federal agencies.