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It is difficult for CTOs and CISOs to determine how to achieve software delivery compliance with regulatory standards such as FedRAMP. 

Google has a great deal of content that provides guidance at a high level, but very little on actual implementation steps for a secure life cycle, evidence collection, proof storage, and audit preparedness. 

In order to demonstrate compliance with FedRAMP and, by extension, portions of the NIST cybersecurity framework, regulated software companies that offer cloud services to the federal government must demonstrate that their software is delivered according to a life cycle process. And this concludes the counsel. 

In this article we will explain what FedRAMP is and prepare you to implement Continuous Monitoring for FedRAMP compliance in your organization.

How to document the software delivery procedure

Compliance with software delivery standards requires the capacity to provide authoritative answers to technical questions about how software is delivered to production environments. It entails the ability to generate audit traces for security scanning, unit testing, change approvals, pull requests, separation of duties, etc. 

According to our experience, customers want to know how they can do this without prolonging deployments, imposing ITIL service centers on their teams, or spending a great deal of time scouring for evidence and copy/pasting it across tools. 

The rapid delivery of modern software makes it more difficult than ever to maintain a secure audit and compliance posture, especially in light of recent and forthcoming cybersecurity regulations. FedRAMP compliance requires the capacity to perform a monthly audit. This is a significant challenge when your software systems are in a constant state of evolution. 

If you require a FedRAMP audit and compliance solution that integrates with your existing processes, DevOps tools, and production environments, learn more by reading a devops audit compliance blog.

Continue reading if you are interested in learning more about FedRAMP compliance, continuous monitoring, and NIST special publications NIST 800-137 and NIST 800-37.

What is the FedRAMP Security Assessment Framework?

The FedRAMP Security Assessment Framework (SAF) is a set of procedures and guidelines for assessing the security of cloud service providers (CSPs) seeking FedRAMP authorization. FedRAMP is a government-wide program that standardizes cloud service security assessment, authorization, risk management processes, and continuous monitoring.

The SAF outlines the requirements CSPs must meet to demonstrate conformance with FedRAMP security controls. Management, operational, and technical security controls comprise the framework. A CSP must demonstrate compliance with each of these controls in order to obtain a FedRAMP authorization.

Multiple phases make up the FedRAMP Security Evaluation Framework

By submitting an authorization request to the FedRAMP Program Management Office (PMO), the CSP initiates the security assessment procedure.

The CSP and the FedRAMP PMO collaborate to develop a security assessment plan that specifies the scope, controls, and testing methodology of the assessment.

A security evaluation is performed on the CSP, which includes both a review of the documentation and testing.

The CSP provides a Security Assessment Report (SAR) that documents the results of the security evaluation.

During the security assessment, if any issues or vulnerabilities are discovered, the CSP must remediate them and provide evidence of remediation.

Depending on the impact on government operations, the FedRAMP PMO grants either a provisional authorization to operate (P-ATO) or a full authorization to operate (ATO).

The FedRAMP Security Assessment Framework provides a standardized approach to security assessment for cloud service providers seeking to obtain a FedRAMP authorization, ensuring that the security of federal information is consistently evaluated and maintained at a high level.

What are NIST standards 800-137 and 800-37?

The publications NIST 800-137 and NIST 800-37 from the National Institute of Standards and Technology (NIST) provide important guidance on information security and risk management.

The document NIST 800-137, “Information Security Continuous Monitoring (ISCM) for Federal Information Systems and Organizations,” provides guidance for implementing a continuous monitoring program to improve the security posture of federal information systems and organizations. The document outlines a framework for implementing continuous monitoring, including the processes and tools necessary for continuously monitoring security controls and assessing risk. In addition, the guidance emphasizes the importance of integrating continuous monitoring into an organization’s overall framework for risk management.

The NIST 800-37 document, titled “Risk Management Framework for Information Systems and Organizations,” provides a standard method for managing the security and privacy risks associated with federal information systems and organizations. Beginning with categorizing information systems and selecting security controls and concluding with monitoring security posture and responding to incidents, the document outlines a six-step process for managing risk. The guidance highlights the importance of risk management as a continuous, iterative process that requires continual monitoring and adjustment.

How do I implement Continuous Monitoring for FedRAMP compliance?

Compliance with FedRAMP (Federal Risk and Authorization Management Program) requirements requires continuous monitoring. Some of these high-level measures to implement FedRAMP’s continuous monitoring are as follows:

  1. Develop a continuous monitoring plan
  2. Utilize continuous monitoring tools
  3. Conduct ongoing risk assessments.
  4. Ensure adherence to FedRAMP requirements
  5. Report on continuous monitoring results

You can implement an effective continuous monitoring program that ensures ongoing FedRAMP compliance and protects your system from emerging threats and vulnerabilities by adhering to these steps.