GovCon Expert Warren Linscott Demystifies FedRAMP for Government Contractors

By Warren Linscott, Senior Vice President & Chief Product Officer at Deltek

In an era where data breaches can weaken national security and cripple major companies, securing cloud services is not just prudent—it’s imperative. FedRAMP, the Federal Risk and Authorization Management Program, exists as a trusted measure of security excellence, ensuring that cloud services meet rigorous security standards before they can be adopted by U.S. government agencies and government contractors.

Seeking and achieving FedRAMP Moderate or High authorization or equivalency signifies to anyone looking to work with a cloud service offering that it has been rigorously vetted by third parties and is recognized on the FedRAMP Marketplace. It’s similar to earning an advanced degree from a university: it validates capability and commitment. FedRAMP was designed to make federal buyers plainly aware of which cloud services meet their standards in order to expedite the government procurement processes and cybersecurity compliance audits.

Aligning with the FedRAMP standard for cloud security demonstrates a commitment to excellence in cybersecurity and can also present opportunities to win and maintain highly competitive government contracts. At Deltek, we’ve made this commitment to excellence ourselves.

What Is FedRAMP and Why Is It Important?

FedRAMP, established in 2011, stands as a critical initiative for implementing secure cloud solutions across the federal government. It provides a standardized approach to security assessment, authorization and continuous monitoring for cloud products and services. The program supports the U.S. federal government’s shift toward cloud adoption while prioritizing the resilience and security of computing environments.

It is important to understand that for cloud service providers—or CSPs—engaged with government data, FedRAMP is not just recommended—it is mandatory. Built upon the foundational bedrock of NIST SP 800-53, a catalog of privacy and security controls for information systems originally published in 2005, FedRAMP doesn’t just match but elevates the standard for security with a process that is both rigorous and uniform. CSPs must successfully complete a comprehensive security assessment, which could take many months, and then maintain the high bar of security through relentless, ongoing monitoring to keep their FedRAMP status current.

FedRAMP also mandates that CSPs promptly report any alterations or surfaced issues with their security measures. This transparency is the fulcrum upon which the lever of trust pivots, offering agencies a clear and timely view of the security health of their cloud services. Through constant risk mitigation, vulnerability scanning and assessments, to having a robust and actionable incident response framework, FedRAMP’s monitoring requirement is a major differentiator and value-added service among cloud service offerings and providers.

With the Department of Defense’s Cybersecurity Maturity Model Certification enforcement rule racing toward the finish line and assessments beginning soon thereafter, defense contractors will need to be prepared to meet the necessary security standards. DOD contractors need to be cautious and aware that CSPs cannot inherit FedRAMP Authorization from third-party providers such as Amazon GovCloud or Microsoft GCC High.

What Is the Difference Between FedRAMP Ready and FedRAMP Authorized?

FedRAMP Ready designation is available to CSPs who have initiated the process of obtaining a FedRAMP authorization. This designation allows them to demonstrate their commitment to securing government data and positions them as potential partners for federal agencies. While being FedRAMP Ready is not equivalent to being fully authorized, CSPs with this designation have taken the necessary steps to meet the FedRAMP requirements and are confirmed to be actively working toward achieving full authorization. Those CSPs can then work to obtain FedRAMP Authorized status if they have a government sponsor, or work with their third-party assessor to produce a body of evidence to demonstrate equivalency.

Achieving FedRAMP underscores a CSP’s allegiance to cybersecurity excellence. With a formidable and robust list of 325 controls derived from the FedRAMP Moderate baseline, getting the FedRAMP stamp of approval isn’t simply about compliance—it’s a testament to the CSP’s unwavering commitment to customer trust and security effectiveness.

Does FedRAMP Only Apply to Federal Agencies?

No, FedRAMP is not only for government agencies. It also applies to government contractors who utilize cloud services in their work with government agencies — especially with the DOD. Many government contractors use cloud services to store and process sensitive information, making it crucial for them to comply with the same security standards and requirements as CSPs. Government contractors with DOD contracts are responsible for ensuring that the cloud services they use are FedRAMP Moderate authorized or equivalent per the DFARS 252.204-7012 clause. Soon, contractors will also have to demonstrate compliance with a similar requirement for their CMMC certification.

On July 25, 2024, the Office of Management and Budget released updated guidance to the FedRAMP program which establishes potential new paths to achieve an authorization to operate, a.k.a. ATO, for CSPs without an agency sponsor. Through these additional paths, such as program authorization, CSPs may have the opportunity to gain FedRAMP Authorization for software solutions that are designed specifically for use by government contractors, not federal agencies. These potential new avenues for FedRAMP ATO could help greatly expedite contractor compliance audits as FedRAMP Authorized is the easier path for auditors to verify the cybersecurity requirements for CSPs that are not selling directly to U.S. federal agencies.

Benefits Gained by GovCons Working With FedRAMP-Listed CSPs

• Trust with government agencies: Seeking FedRAMP Ready and/or Authorized status is an indication that a CSP adheres to the robust security controls found within NIST SP 800-53, fostering trust and credibility amongst federal agencies and government auditors.
• Streamlined audits: FedRAMP Ready and Authorized providers are listed on the FedRAMP Marketplace, a centralized hub that helps federal agencies and assessors quickly find and confirm vetted, secure cloud solutions.
• Market opportunities: Partnering with a FedRAMP Ready or Authorized CSP signals a dedication to security to federal agencies, unlocking business opportunities across a wide range of government sectors.
• Continuous compliance: FedRAMP’s Continuous Monitoring mandates keep CSPs at the forefront of cybersecurity, ensuring they maintain a dynamic security posture necessary for today’s threats.
• Competitive edge: Since many agencies require FedRAMP authorization or equivalence (e.g., aligned with DFARS 7012, NIST 800-171 and CMMC), CSPs with a FedRAMP designation are better positioned as trusted vendors, outpacing competitors not carrying the certification.

Potential Risks Partnering With Non-FedRAMP Ready or Authorized CSPs

The potential consequences of working with a CSP that is not FedRAMP Ready or Authorized cannot be overlooked when it comes to government contracting, especially with the DOD. Using a CSP that is not FedRAMP Ready or Authorized for government contracts can present several risks:

• Security vulnerabilities: Without FedRAMP validation, the CSP may not meet the rigorous security standards required for government data, increasing the risk of data breaches and cyber-attacks.
• Compliance issues: Businesses with DOD contracts are required to use FedRAMP-authorized or equivalent providers. Using a CSP without the FedRAMP distinction can lead to non-compliance with federal regulations, resulting in legal and financial repercussions, increased scrutiny and potential loss of funding for government projects.
• Data privacy concerns: The CSP might not have the necessary controls to ensure data privacy, potentially exposing sensitive government information to unauthorized access.
• Operational disruptions: Lack of FedRAMP authorization or equivalency might indicate insufficient operational maturity, leading to potential service outages or disruptions that could impact government operations.
• Reputation damage: The CSP could damage the credibility and reputation of your business, affecting trust and stakeholder confidence.

In essence, FedRAMP is more than just a compliance milestone; it’s a strategic investment in a CSP’s viability and long-term stability with a clear signal of quality assurance in secure cloud service offerings. By choosing a CSP that has made the investment in going through the FedRAMP evaluation process, government contractors have the benefit of knowing they are working with a CSP that has made cybersecurity a priority.