Source URL: https://www.schellman.com/blog/federal-compliance/fedramp-moderate-equivalency-for-csps-explained
Source: CSA
Title: FedRAMP Moderate Equivalency for Cloud Providers
Feedly Summary:
AI Summary and Description: Yes
Summary: The text discusses significant developments in December 2023 concerning cybersecurity compliance requirements issued by the Department of Defense (DoD) for Cloud Service Providers (CSPs) dealing with Controlled Unclassified Information (CUI). The release of the CMMC Proposed Rule and FedRAMP Moderate Equivalency memorandum aims to clarify these requirements, indicating that CSPs must achieve stringent compliance standards and documentations to protect CUI, which has implications for contractors within the Defense Industrial Base (DIB).
Detailed Description:
The DoD’s recent publications represent critical shifts in how cloud service providers engaged with the Department must manage and safeguard sensitive information. Here are the vital points addressed:
– **CMMC Proposed Rule**: The release of the Cybersecurity Maturity Model Certification (CMMC) Proposed Rule indicates a regulatory push towards standardizing cybersecurity measures across the Defense Industrial Base (DIB).
– **FedRAMP Moderate Equivalency**: The memorandum clarifies that Cloud Service Offerings (CSOs) must adhere to a stringent standard of equivalency to the FedRAMP Moderate baseline. CSOs will now need to achieve 100% compliance with all 323 security controls, validated by a Third-Party Assessment Organization (3PAO).
– **Documentation Requirements**: To demonstrate FedRAMP Moderate Equivalency, CSPs must collect and present comprehensive documentation, which includes:
– **System Security Plan (SSP)**: Detailed implementation of controls, interconnections, defined boundaries, roles/responsibilities.
– **Security Assessment Plan (SAP)**: Outlines assessment scope and methodology.
– **Security Assessment Report (SAR)**: Summarizes assessment processes and findings.
– **Plan of Action and Milestones (POA&M)**: Documents corrective or remediation actions.
– **Incident Response Obligations**: Contractors must now ensure that their CSPs have effective incident response plans in place and are responsible for reporting any compromises accordingly.
– **Validation Process**: The Defense Contract Management Agency (DCMA) will oversee the validation of the compliance reports submitted by CSPs, ensuring that these meet the stringent security measures laid out in the memo.
– **Operational POA&Ms**: While control-related POA&Ms are not permitted following a 3PAO assessment, operational POA&Ms are allowed, indicating a need for ongoing remediation of security weaknesses.
– **Implications for DIB Contractors**: This shift emphasizes a need for thorough vetting of CSPs’ security postures to ensure compliance and protection of Controlled Unclassified Information (CUI), wherein contractors will have a say about whom they choose to do business with based on these stringent requirements.
Overall, this memo and the proposed rule signify a more rigorous stance on cybersecurity standards in the defense contracting sphere, compelling CSPs to take urgent measures in achieving compliance.