Overview
FedRAMP authorization is the gateway to selling cloud services to the U.S. federal government, a market worth over $60 billion annually. The process is rigorous, time-consuming, and expensive, but for cloud service providers, it unlocks access to thousands of federal agencies with a single authorization. This checklist covers the complete FedRAMP authorization journey from initial readiness through continuous monitoring, aligned with the latest FedRAMP Rev. 5 baselines.
Continuous Monitoring Requirements
- Monthly vulnerability scanning with remediation within 30 days for high-severity findings
- Annual 3PAO assessment of a subset of controls
- Significant change requests for any material changes to the authorized system
- Incident reporting to US-CERT within one hour of discovery for significant incidents
- Monthly POA&M updates showing remediation progress
- Annual security assessment report (SAR) update
- Ongoing supply chain risk management documentation
Cost and Timeline Planning
Budget realistically. A Moderate Impact FedRAMP authorization typically costs $1 million to $3 million and takes 12 to 18 months from readiness assessment through ATO. Major cost categories include 3PAO assessment fees, SSP development, control implementation and remediation, staffing for continuous monitoring, and FedRAMP-compliant infrastructure and tooling. The ongoing cost of continuous monitoring is roughly 30 to 40 percent of the initial authorization cost per year.
Frequently Asked Questions
How long does FedRAMP authorization take?
Typically 12 to 18 months for initial authorization, including preparation, 3PAO assessment, remediation, and PMO review. The timeline depends heavily on organizational readiness and the number of POA&M items that need remediation.
What is the difference between FedRAMP Low, Moderate, and High?
The impact levels correspond to the potential impact of a security breach. Low Impact systems handle publicly available data. Moderate Impact covers controlled unclassified information (most common for SaaS). High Impact involves data where a breach could cause severe harm, such as law enforcement or healthcare data.
Can we reuse an existing SOC 2 or ISO 27001 certification?
FedRAMP recognizes overlaps but does not accept them as substitutes. Your existing certifications can streamline the process by demonstrating control maturity, but you must still undergo the full FedRAMP assessment against the NIST 800-53 baseline.
What is a POA&M and how does it work?
A Plan of Action and Milestones documents security weaknesses found during assessment, along with planned remediation actions, responsible parties, and target completion dates. It is a living document updated monthly and reviewed by the authorizing official.
Is FedRAMP worth the investment for small CSPs?
It depends on your federal market opportunity. The authorization cost is significant, but once authorized, you gain access to a marketplace of federal buyers with reduced procurement friction. Many CSPs achieve ROI within two to three years through federal contracts.
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