USGov RMF Series: Achieving FISMA Compliance (P-ATO) for Cloud Service Providers

In preview post, we have discussed achieving compliance from the perspective of a government agency. However, Cloud Service Provider (CSP) like Microsoft Azure, Amazon AWS, and Google GCP are also mandated to satisfy FISMA compliance to enable them offer services to the U.S. government. Achieving a Provisional Authorization to Operate (P-ATO) guidelines is a methodlogy that signals to government agencies that a CSPs cloud services are secure, reliable, and ready to be consumed by the government.

In this post, will explore the steps a CSP needs to take to achieve FISMA compliance and secure a P-ATO from the three critical federal bodies responsible for issuing the authorization:

• FedRAMP process - To provide cloud services to Federal Civilian Agencies
• Defense Information Systems Agency (DISA) process - To provide cloud services to Department of Defense
• Intelligence Community (IC) process to provide cloud services to the Intel Community.

FedRAMP Cloud Authorization (P-ATO) Process

The Federal Risk and Authorization Management Program (FedRAMP) is the primary framework used by civilian agencies to assess the security of cloud products and services. FedRAMP establishes a standardized approach to security assessment, authorization, and continuous monitoring.

Key Steps for a FedRAMP P-ATO:

1. Initiate the Process:
   Start by identifying the FedRAMP baseline that aligns with your service offering: Low, Moderate, or High. These baselines determine the level of security required based on the sensitivity of the data handled.

2. Prepare the System Security Plan (SSP):
   This document outlines how your system meets the necessary security controls specified in NIST SP 800-53. It will include technical details about your infrastructure, data protection measures, incident response plans, and more.

3. Third-Party Assessment Organization (3PAO) Audit:
   A 3PAO performs an independent audit of your cloud system. The auditor will assess whether your security controls are correctly implemented and effective in mitigating risks.

4. P-ATO from the JAB or Agency ATO:
   A Joint Authorization Board (JAB) consisting of representatives from the Department of Defense (DoD), General Services Administration (GSA), and Department of Homeland Security (DHS) will review your application for P-ATO. Alternatively, individual federal agencies can grant you an Authority to Operate (ATO).

5. Continuous Monitoring:
   Once authorized, your system is subject to continuous monitoring. You will need to submit regular security assessments and updates to maintain your status.

FedRAMP compliance is the baseline for doing business with federal civilian agencies, but for CSPs working with the DoD or intelligence community, additional layers of authorization are required.

DISA’s Cloud Authorization (P-ATO) Process

The Defense Information Systems Agency (DISA) provides security standards for CSPs working with the Department of Defense (DoD). The process to secure a P-ATO through DISA can be more stringent than FedRAMP due to the sensitivity of military data. The details is outlined in the DISA Cloud Computing Seurity Requirements Guide (DISA CC SRG)

Key Steps for DISA P-ATO:

1. DoD Cloud Computing Security Requirements Guide (SRG):
   DISA’s security requirements are outlined in the DoD Cloud SRG, which defines Impact Levels (IL) ranging from IL2 to IL6 based on the sensitivity of data. For example, IL4 covers Controlled Unclassified Information (CUI), while IL6 covers classified data up to SECRET.

2. Submit to DISA’s Security Review Process:
   The DoD requires CSPs to submit a package that includes an SSP, security controls tailored to the SRG, and a vulnerability assessment.

3. DISA’s Risk Management Framework (RMF):
   Like FedRAMP, DISA uses the NIST RMF to ensure CSPs meet the necessary security controls. The DoD’s authorization process may also include a more detailed review of your physical and logical security measures.

4. Granting of P-ATO or DoD Agency ATO:
   Once reviewed, a CSP can receive a P-ATO from DISA or, depending on the use case, individual DoD agencies.

DISA compliance opens doors to defense contracts and access to highly sensitive government information, but the complexity of these requirements necessitates rigorous preparation.

IC Cloud Authorization (P-ATO) Process

When working with the Intelligence Community (IC), which includes agencies such as the CIA, NSA, and DIA, the security bar is set even higher. IC agencies operate under the Intelligence Community Directive (ICD) 503, which builds on the NIST RMF but adds additional controls specific to intelligence missions.

Key Steps for IC P-ATO:

1. ICD 503 Compliance:
   ICD 503 is the principal framework governing IT security in the intelligence community. It shares similarities with NIST SP 800-53, but includes unique controls to address the risks of handling classified information.

2. Alignment with Intelligence Community Security Control Catalog (IC SCC):
   The IC SCC defines the specific security controls for cloud services based on the classification of data, ranging from unclassified to Top Secret.

3. Agency-Specific Reviews:
   Unlike FedRAMP and DISA, where P-ATOs are reviewed by a centralized board, each IC agency conducts its own security assessment process based on ICD 503. This can involve multiple security assessments by different intelligence bodies.

4. Classified Data Handling:
   CSPs seeking authorization for classified data need to demonstrate extensive measures to protect against unauthorized access, including compliance with encryption standards and physical security requirements for data centers.

5. P-ATO from IC Agency:
   Once your cloud services meet the stringent security criteria, you can receive a P-ATO from the specific intelligence agency you are working with.

The Path Forward for CSPs

Achieving FISMA compliance and securing a P-ATO from FedRAMP, DISA, and IC agencies requires a significant investment of time and resources, but the benefits far outweigh the challenges. Not only does it open your cloud services to new federal markets, but it also demonstrates your commitment to securing sensitive government data.

By adhering to FedRAMP’s standardized security processes, meeting DISA’s military-grade controls, and navigating the IC’s classified data requirements, CSPs position themselves as trusted partners in the U.S. government’s digital transformation journey.

For CSPs, this process is more than just checking regulatory boxes—it’s about ensuring the integrity and security of some of the most critical digital infrastructures in the world.

Conclusion

While the journey to achieving FISMA compliance and securing P-ATO from FedRAMP, DISA, and the IC is complex, the rewards are substantial. By navigating these frameworks, CSPs not only gain access to lucrative federal contracts but also solidify their reputation as leaders in cloud security. The path to authorization may be challenging, but with the right preparation, partnerships, and security posture, it is an attainable goal for any cloud service provider looking to serve the U.S. government.