The Cloud Service Providers-Advisory Board (CSP-AB) has formally responded to the Office of Management and Budget’s (OMB) Request for Comments on Updated Guidance for Modernizing the Federal Risk Authorization Management Program (FedRAMP). This guidance represents an important step in aligning FedRAMP with the dynamic needs of cloud technology and cybersecurity, and CSP-AB commends OMB for its commitment to fostering innovation and collaboration.
Welcoming the Vision for Modernization
The CSP-AB recognizes the considerable evolution in cloud technology and security since FedRAMP’s inception in 2011. This updated guidance reflects the critical need to adapt the program to modern requirements while preserving its core objectives of security, scalability, and efficiency. OMB’s emphasis on a robust consultation process with industry stakeholders ensures this transformation is collaborative and comprehensive.
“We applaud the OMB for revising its timetable to ensure a robust and transparent consultation process,” said Laura Navaratnam, Executive Director of the CSP-AB. “FedRAMP reform holds great potential, and we encourage bold yet thoughtful changes that enhance both security and efficiency.”
Key Recommendations from CSP-AB
The CSP-AB’s detailed feedback, based on the insights of its member companies holding over 700 Authority to Operate (ATO) certifications, emphasizes the following priorities:
- Streamlining the FedRAMP Process:
- FedRAMP’s authorization timelines, which can range from 12-18 months for new products, need to be significantly reduced. Lengthy delays often create a gap between commercial innovation and government availability.
- Transitioning to data-driven, automated compliance approaches will help address this challenge.
- Supporting Velocity in Cloud Adoption:
- The government must adopt solutions that leverage the scalability and best practices of commercial cloud offerings without penalizing Cloud Service Providers (CSPs) already authorized under FedRAMP.
- The CSP-AB urges OMB to align FedRAMP with Department of Defense (DoD) reciprocity frameworks to prevent duplication and accelerate adoption across civilian and defense agencies.
- Enhancing Continuous Monitoring (ConMon):
- Shifting from static, point-in-time assessments to adaptive monitoring frameworks will ensure real-time visibility into cloud security. This approach aligns with the evolving threat landscape and reduces audit fatigue for CSPs.
- Clarifying Roles and Structures:
- The updated guidance introduces joint agency authorizations and program-level authorizations. CSP-AB recommends additional clarity around agency responsibilities and conflict resolution mechanisms.
- Building a Common P-ATO Standard:
- Agencies often impose varying requirements for FedRAMP authorizations, which hampers the “certify once, reuse many times” principle. CSP-AB advocates for a uniform standard to streamline compliance across agencies.
Looking Ahead
FedRAMP modernization is an opportunity to revolutionize the federal cloud landscape, creating an ecosystem that is secure, agile, and aligned with the needs of both government and industry. CSP-AB stands ready to assist OMB, the FedRAMP Program Management Office, and federal agencies in implementing these reforms.
Call to Action: Stakeholders are encouraged to contribute to the ongoing dialogue on FedRAMP modernization. By working together, we can build a program that accelerates secure cloud adoption while fostering innovation and collaboration.
For more details on CSP-AB’s feedback and recommendations, you can view the full response below:
