Achieve HIPAA Compliance – A Step-by-Step Guide
Introduction Importance of HIPAA Compliance for Healthcare Organizations Achieve HIPAA Compliance – HIPAA (Health Insurance Portability and Accountability Act) compliance
FedRAMP is an acronym that stands for Federal Risk and Authorization Management Program. This program was established in 2011 with the goal of providing a cost-effective and risk-based approach to the federal government’s adoption and use of cloud services.
FedRAMP is designed to empower government agencies to use modern cloud technologies without sacrificing the security of federal information.
In December 2022, the FedRAMP Authorization Act was signed as part of the FY23 National Defense Authorization Act.
This Act codified the FedRAMP program. It also declared it the authoritative and standardized approach for security assessment, cloud computing product authorization, and services that process unclassified federal information
We manage all areas of FedRamp ATO process as your outsourced cybersecurity department so you don’t have to.
Our FedRamp Security Program includes everything you need to meet FedRamp’s criteria items. This includes the following:
FedRAMP standardizes the security requirements for the authorization of cloud services (and the ongoing cybersecurity of these services).
The guidelines are written in accordance with other vital acts and essential documentation, including FISMA (the Federal Information Security Management Act), Office of Management and Budget (OMB) Circular A-130, and the FedRAMP Authorization Act as part of the National Defense Authorization Act.
FedRAMP and FISMA are similar, but FedRAMP is specifically meant for the cloud. Both FedRAMP and FISMA rely on the National Institute of Standards and Technology (NIST) SP 800-53 benchmarks and feature specific controls, parameters, and guidelines tailored to the unique aspects of cloud computing.
The mission behind FedRAMP is to promote the adoption of secure cloud services across the federal government. It aims to accomplish this by providing a standardized approach to security and risk assessment for federal agencies and the cloud technologies they utilize.
There are also three goals associated with FedRAMP:
Expand the use of secure cloud technologies by government agencies.
Enhance the framework by which government agencies secure and authorize cloud technologies.
Build strong partnerships with FedRAMP stakeholders (agencies, cloud service providers, third-party assessment organizations, etc.).
When properly implemented and followed, FedRAMP has the potential to produce the following positive outcomes:
Reduce the incidence and likelihood of duplicative efforts, inconsistencies, and cost inefficiencies.
Establish a public-private partnership that promotes innovation and the advancement of increasingly secure information technologies.
Enable the federal government to accelerate cloud computing adoption by creating transparent standards and processes and allowing agencies to utilize security authorizations on a larger scale that spans the entire government.
FedRAMP offers numerous benefits to cloud service providers as well, including these:
Businesses have the ability to sell services to federal agencies.
Businesses can gain confidence from clients and potential clients by demonstrating a commitment to the highest security standards.
Businesses can gain an Authority to Operate (or ATO) from multiple federal agencies with just one assessment.
Businesses can get a headstart on security protocols required by various federal and defense programs.
Put simply, it is advantageous to the agency, the provider, and everyone in between to prioritize cloud cybersecurity and develop robust plans to keep critical data safe.
Yes, FedRAMP is a mandatory program for all executive agency cloud deployments and service models.
Any cloud service provider (or CSP) that has developed a cloud service offering (or CSO) for a federal agency must comply with the FedRAMP guidelines. Furthermore, whenever a national agency shares sensitive data on the cloud, the agents must ensure they adhere to FedRAMP’s standards.
In other words, the onus is on both federal agencies and cloud service providers to achieve FedRAMP authorization and remain compliant.
Cloud service providers can authorize their cloud service offerings through FedRAMP in two ways: Through an individual agency (known as the Agency Process) or through the Joint Authorization Board (known as the JAB Process).
The agency authorization process involves these steps:
Preparation begins with an optional but highly recommended readiness assessment.
During the readiness assessment stage, a cloud services provider works with an accredited Third-Party Assessment Organization (or 3PAO). The 3PAO will produce a Readiness Assessment Report (or RAR) that will document the provider’s ability to meet federal security guidelines.
At this point, the 3PAO will perform an independent system audit. They will test the provider’s system and produce a Security Assessment Report (or SAR) detailing their findings and including a recommendation for authorization.
The provider will also develop a Plan of Action and Milestones (or POA&M) based on the 3PAO’s findings.
From here, the agency will conduct a security authorization review. This review may include a SAR debrief with the FedRAMP Program Management Office (or PMO). Remediation might be required based on the results of the agency review.
The agency will then implement, test, and document customer-responsible controls and perform a risk analysis. At this point, the agency will accept the risk and issue an Authority to Operate letter.
If an agency provides an ATO letter, the following actions will occur:
The CSP will upload the Authorization Package Checklist and the complete security package to FedRAMP’s secure repository.
The 3PAO will upload all security assessment material associated with the CSO security package to FedRAMP’s secure repository.
The FedRAMP PMO will review the security assessment materials to determine if they can be included in the FedRAMP Marketplace.
The listing on the FedRAMP for the service offering will be updated to reflect that it has attained FedRAMP Authorized status (it will also include the date of authorization).
The CSO security package will be made available to the agency’s information security personnel.
During this phase, the cloud services provider must provide periodic security deliverables (such as vulnerability scans and annual security assessments) to all agency customers. Each agency that uses the service will review the deliverables as needed.
If you decide to follow the Joint Authorization Board process instead, you’ll need to go through these steps:
The Joint Authorization Board prioritizes roughly 12 cloud service offerings each year. It evaluates them using a process called FedRAMP Connect.
Cloud service providers that are interested in partnering with the JAB must do the following:
Familiarize themselves with the JAB Prioritization Criteria and Guidance information
Complete the FedRAMP Business Case
Send it electronically to [email protected]
Offerings will be selected during specific time frames throughout the year, according to the FedRAMP Blog.
Cloud service providers must attain the FedRAMP Ready JAB designation for their specific offering. If the JAB selects an offering that hasn’t achieved Ready status, the provider has 60 days to become Ready.
To achieve the Ready designation, a provider must work with an accredited Third Party Assessment Organization (or 3PAO) to complete a Readiness Assessment.
After a CSO has been prioritized to work with the JAB and judged as FedRAMP Ready, the following steps will occur:
The CSP will finalize the System Security Plan (or SSP) and engage an accredited 3PAO.
The 3PAO will develop a Security Assessment Plan (or SAP), conduct a full security assessment, and produce a Security Assessment Report (or SAR).
The CSP will develop a Plan of Action and Milestones (or POA&M) to keep track of and correct any system security risks identified in the report.
All of these documents, plus one month of continuously monitoring deliverables, must be completed using templates provided by FedRAMP. The information must be submitted together as well, and the JAB must have a provider’s complete security package for at least two weeks.
The JAB Authorization Process relies on agile methodology, includes multiple stage gates, and is based on the “fail fast” principle.
This is the first stage gate. At this point, the CSP, 3PAO, and FedRAMP will collaboratively review the CSO’s system architecture, security capabilities, and risk posture. The JAB will either issue a “go” or “no-go” decision.
In-Depth Review: After the Kickoff, the JAB will conduct an in-depth review evaluating the security authorization package.
Remediation: When the review is finished, the CSP and 3PAO will remediate outstanding issues.
Formal decision: After remediation, the JAB will issue a formal decision and, if the decision is favorable, a Provisional Authority to Operate (or P-ATO).
When they reach the continuous monitoring phase, the cloud service provider must produce monthly deliverables, such as incident reporting, to the JAB and the agencies using their service.
The JAB does the following:
Regularly reviews continuous monitoring and security artifacts
Monitors, suspends, and revokes a system’s P-ATO as needed
Authorizes or denies significant changes and deviation requests
Ensures constant monitoring deliverables are promptly provided to leveraging agencies
If you want to deliver a cloud service offering to a federal agency, you must be FedRAMP authorized.
At Bluesteel Cybersecurity, we understand how complex it can be to achieve this authorization and remain FedRAMP compliant. That’s why we offer compliance preparation services to help you navigate the process and ensure you check all the necessary boxes.
Get in touch today to learn more or get started.
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