FEDRAMP Moderate Equivalency for Cloud Service Providers

This memorandum from the Department of Defense outlines requirements for cloud service providers (CSPs) seeking FEDRAMP Moderate equivalency. It details the necessary assessments and documentation, including security plans and testing procedures, that CSPs must meet. The memorandum emphasizes the importance of compliance with specified Defense Federal Acquisition Regulations Supplement clauses. Finally, it clarifies the roles and responsibilities of the contractor, CSP, and assessing organizations. The document aims to ensure the security of covered defense information processed by these cloud services.

Ref: https://dodcio.defense.gov/Portals/0/Documents/Library/FEDRAMP-EquivalencyCloudServiceProviders.pdf

Transcript

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Alright. So today, we're gonna, dive deep into DOD cloud security. Yep. Specifically, into, how the Department of Defense Right. Ensures its data is safe when they have to use Yeah. Cloud services. They haven't gone through the typical FedRAMP authorization. Right. We've got this DOD memo from December 21, 2023 Okay. That lays out their new approach to this whole thing. Yeah. Well, the interesting thing here is it's not really about replacing FedRAMP. Okay. It's more about addressing these kind of unique situations Okay. Where the DOD absolutely needs to use a particular cloud service provider Mhmm. But that provider hasn't completed the whole authorization process. So it's like, we need this now, but we can't compromise security. Yeah. Exactly. Like an urgent operational need, but security is still paramount. I see. So what's their solution? They're calling it FedRAMP Moderate Equivalency. Moderate equivalency. Yeah. Think of it like, you know how FedRAMP authorization is like the super exclusive club Okay. With a really long waiting list? Well, moderate equivalency is like getting a VIP pass to get in faster. I see. But you still have to prove you belong there. Okay. That makes sense. But is it really as secure as going through the full FedRAMP authorization process? That's a great question, and that's what the memo is trying to address. Okay. They lay out a whole bunch of assessments that these providers have to go through Okay. To demonstrate their security capabilities. So what are we talking about here? What do they actually have to do? So first off, they need to create a system security plan, an SSP. Okay. This is like their security bible. Got it. It outlines everything from how they manage user access Mhmm. To what happens if there's a breach. It even includes a user guide, an incident response plan. Wow. So it's super comprehensive. Yeah. They have to show they've actually got the processes in place. Because that's the planning phase, but how do they prove they're actually implementing it? Right. So for that, there's the security assessment plan, the SAP, and this is where they actually have to hire penetration testers. Oh, wow. Like ethical hackers. Exactly. To try and break into their systems and find vulnerabilities. Like a stress test for their security. Yeah. And they also have to develop security test cases themselves. Okay. And all this testing has to be validated annually by a third party. Oh, wow. So there's no cutting corners? Nope. So what happens if they actually find something? So that's where the risk assessment report, the SAR, comes in. Right. It's vulnerability report card conducted by a FedRAMP recognized third party assessor. Right. It identifies any security gaps and analyzes how bad the potential impact could be. So what if the report card isn't great? Do they just get kicked out? Not necessarily. This is where the plan of action and milestones comes in, the POA and M. Okay. So what is that? It's basically a road map for fixing any problems found in those assessments. Okay. The provider has to say exactly how they're gonna address those vulnerabilities with timelines and who's responsible. Okay. So the DOD doesn't just take their word for it. Right. They don't there's this whole other group called the Defense Industrial Base Cybersecurity Assessment Center. Wow. That's a mouthful. I know. DIBC for short. DIBC. They're like the watchdogs, making sure these cloud service providers are actually doing what they say they are. So they're maintaining that moderate equivalency. Well, exactly. That's pretty intense. It's not just a rubber stamp at all. Yeah. The DOD is trying to strike that balance. Yeah. They need to be able to move fast and use the cloud. Mhmm. But they also can't compromise on security. So FedRAMP moderate equivalency is how they're trying to do both. Right. I see. Okay. So how does the provider actually prove they meet all these requirements? I imagine it's a ton of paperwork. Oh, yeah. Definitely some paperwork. But But it's more than just that. Okay. It's about showing a comprehensive and proactive approach to security. Alright. So walk me through this. What kind of proof are we talking about? Sure. Well, they've gotta provide a control implementation summary report or CIS. A CIS? Yeah. It basically lays out how they've implemented specific security controls. Okay. It's based on this framework called NIST SP 853. NIST SP 800 53. Yeah. So it's kinda like a checklist. Okay. But instead of just checking boxes, they have to explain how they're meeting each requirement. So it's not just like, yep. We did it. They have to show their work. Exactly. Show your work. Okay. I like that. What else? Then there's the FIPS 199 9 workbook. FIPS 199. What is that? It stands for federal information processing standard 199. K. And this one focuses on, categorizing how sensitive the information they're handling is. Okay. That makes sense. So is it top secret, classified, or something else? Yeah. This helps determine the right level of security controls they need. Right. The higher the stakes, the tighter the security. Precisely. What else is in this package? They also need to provide a separation of duties matrix. Separation of duties. Okay. Let's make sure no one person has too much control. Yeah. You know? Okay. Could compromise security. Checks and balances? Yeah. Checks and balances within the provider itself. Smart. Anything else? Oh, yeah. There's also a doc outlining all the laws, regulations, and standards they follow and an integrated inventory workbook. Wow. They really gotta cover all their bases. Yeah. It's all about demonstrating a really thorough approach to security. So layers upon layers of security, no stone unturned. Right. But what happens if something slips through the cracks? Yeah. No system's perfect. Right. You're right. That's why the POA and M is so important. The plan of action and milestones. Yeah. If they find any issues during the assessment Right. The CSP has to have a plan for addressing them with timelines and responsibilities. So it's about being accountable? Yeah. And continuous improvement. So it's not just a one time thing? Nope. The DOD wants continuous monitoring. Continuous monitoring. Okay. It's an ongoing process, checking for issues, security updates, Mhmm. Addressing new threats like a cybersecurity treadmill. You gotta keep running to stay ahead. That's it. And DDP is there to make sure they don't fall off the treadmill. Exactly. DIB kick make sure they stay compliant. They do check ins and assessments. Mhmm. Make sure the CSP keeps up with their POA and M and maintains those FedRAMP moderate equivalency standards. So it's a dynamic process, always evolving. Right. I see. So it's really about creating a culture of security within these CSPs. You got it. And that's so important because incidents can still happen. Okay. Yeah. What happens if there is a security incident, like a breach? What then? Right. So remember that point of contact we talked about. Mhmm. They have to report any incidents to the DOD immediately Okay. With all the details, what happened, how bad it could be, and what they're doing to contain it and prevent more damage. So speed and transparency. Exactly. The DOD needs to know everything so they can act. Right. Makes sense. And protect their systems and data, work with other agencies if they need to. Okay. So we've talked about FedRAMP moderate equivalency as this alternative path. Right. But the DOD is clear. This isn't a replacement for full FedRAMP authorization. Right? Yeah. Think of full FedRAMP authorization as the gold standard. Okay. The goal. But sometimes the DOD needs to move faster. Right. And that's where this moderate equivalency comes in. So it's like bridging the gap. Exactly. Working with CSPs who aren't quite there yet. Okay. But why not just require full FedRAMP for everyone? Wouldn't that be simpler? In theory, yeah. But the full FedRAMP process takes a lot of time and resources. Oh, okay. And sometimes the DOD needs those cloud services right away. Mhmm. Especially for new technologies or special capabilities, they can't always wait. So it's about balancing security with being able to move quickly. You got it. Security and agility. But isn't there a risk that some CSPs might try to use this moderate equivalency to avoid the full FedRAMP process? That's a valid point. But remember, DIBSAC is there. Right. DIBSAC. They're actively assessing these CSPs, making sure they're doing what they should. They're the gatekeepers, ensuring only qualified CSPs get through. So it's not a free pass? Nope. Okay. That makes sense. But what about the companies using these cloud services? Where do they fit in? That's a great question. The contractor, the one using the services. Yeah. They have a huge responsibility here. They can't just trust the CSP blindly. Right? Right. They have to be involved in the vetting process. Okay. Review the CSP's documents, ask questions, make sure they understand how their data is protected. So due diligence is key. Absolutely. And they should know about the CSP's security history, any past incidents. Okay. So transparency is important. Yeah. Transparency is key. So it's a shared responsibility. Both sides have to be proactive. Exactly. The DOD is saying security is everyone's business. And especially when you're dealing with info that impacts national security. Absolutely. Okay. I think we've covered a lot from security assessments to this whole new approach. Yeah. I'm starting to understand this complex world a bit better. Glad to hear it. It's a lot to take in, but it's important stuff. Right. We're talking about protecting sensitive information. Exactly. Vital to national security. You know, all this talk about security and oversight can feel a bit overwhelming. Yeah. I can see that. Even for someone like me trying to dive deep into it Right. I can only imagine how someone less familiar with this world might feel. I hear you. It can be a lot, all the jargon and acronyms. Right. But all this complexity is meant to protect us. Exactly. It's all about protecting national security. Right. And while it seems daunting, understanding the basics can help you make informed decisions. Yeah. About the cloud services you use and how your data is protected. It's not about becoming an expert overnight. It's about being aware of the risks and asking questions. That's it. Knowledge is power, especially in cybersecurity. Right. The more you know, the better you can navigate this whole world. Absolutely. Okay. So let's zoom out for a second. Sure. This DOD approach, how do you think it'll impact cloud computing as a whole? That's a really interesting question. The DOD is a big player. Could this have a ripple effect? It could their requirements could raise the bar for security across the whole industry. So a win for everyone? Potentially. Yeah. Okay. If a CSP wants to work with the DOD, they have to meet these standards. Right. So other organizations might follow suit even if they're not working directly with the DOD. Okay. It could incentivize CSPs to prioritize security because they know it could open doors to more clients. I see. So meeting those standards could be good for business. Exactly. But couldn't there also be some downsides? I mean, these requirements seem pretty tough. Yeah. Could that make it harder for smaller companies to compete? Yeah. That's a valid concern. Okay. The resources and expertise needed to meet these standards could be too much for some CSPs Right. Potentially leading to, you know, less competition in the market. So bigger companies could end up dominating. It's possible. Okay. So it's kinda a double edged sword? Yeah. It's a complicated issue. Could be good, could be bad. Right. We'll have to see how it plays out. Will it lead to a more secure cloud, or will it stifle innovation? Yeah. It's a development worth keeping an eye on. Definitely. And for our listeners, this whole thing really emphasizes how important it is to be proactive about security. Yeah. Don't just assume your data is safe because a provider says they're compliant. Right. Ask questions. Do your research. Mhmm. Make sure you understand how your data will be protected. It's your data. Exactly. Okay. Before we wrap up this part, one final thought. Okay. We've been talking about the DOD securing IT's data. Mhmm. But what about national security as a whole? Now you're getting to the heart of it. Right. With all these cyber attacks happening Yeah. How can we make sure critical infrastructure and national assets are safe when they rely on the cloud? That's the big question, and it needs a multi pronged approach. We need government agencies, private industry, individuals Mhmm. All working together to build a more secure digital world. So it's not just about technical stuff. It's about people too. Right. Educating users about best practices, making sure everyone understands how important cybersecurity is. So building a culture of cybersecurity. You got it. And it's not just about external threats. Yeah. You gotta think about insider risks too, human error. Right. Sometimes people are the weakest link. Exactly. It's like this constant battle trying to stay one step ahead. That's a good way to put it. Cybersecurity is a journey, not a destination. And it's a journey we're all on together. Well said. Alright. I think we've covered a lot of ground today. We have. We've gone from the specifics of the DOD's approach to the broader picture of cybersecurity. Mhmm. I hope this deep dive has been insightful for everyone. It's been a great discussion. It's encouraging to see the DOD taking this seriously. Hopefully, others will follow their lead. I agree. And as always, keep exploring this topic. We'll have links in the show notes. And feel free to reach out on social media with questions or comments. We love hearing from you. Definitely. Until next time, stay curious, stay informed, and stay secure. Great advice. Thanks for diving deep with us. You know, we've talked about what the DOD is doing and how they're doing it. Right. But I'm curious about, like, the w h y. The w h y. What's the big reason behind this whole laser focus on securing data in the cloud? Well, I think it really comes down to the threats they face. Okay. We're in a world where cyber attacks are just constantly evolving. Mhmm. More sophisticated, happening more often. Yeah. And the DOD, with all its secrets, they're a prime target. Yeah. Makes sense. They're responsible for national security. Right. So they're gonna be at the crosshairs. But They are. Why the cloud, specifically? Wouldn't it be easier to just keep everything locked down in their own data centers? You would think. Right. But the cloud offers things they just can't pass up. Okay. Think about all the data they have to deal with, the need to work with people around the world Yeah. The ability to scale things up or down quickly. I see. The cloud changes the game, but it also opens up new vulnerabilities. So it's a trade off, the power of the cloud versus the risks. Yeah. Exactly. And this FedRAMP moderate equivalency Mhmm. Is how they're trying to balance that. It is. They're recognizing that the old ways might not be enough anymore. Right. They have to be able to adapt but without compromising security. You mentioned nation state actors before. I did. Most people probably think of China or Russia when they hear that. Right. Are there other countries that pose a serious threat? Oh, absolutely. China and Russia are big players. Mhmm. But we're seeing more from Iran, North Korea as well. Okay. And it's not just about stealing data. Right. Cyberattacks can disrupt infrastructure, spread fake news Wow. Even try to undermine democracy. So it's not just a military issue. Issue. It affects all of us. Yeah. It's a societal issue. Cybersecurity is part of everything now. It really is. It's not just for IT people anymore. Right. It affects everyone, our personal info, our money, our infrastructure. We're all potential targets. We are. Which is why education and awareness are so important. Exactly. We can't just rely on the DOD to protect us. Right. Yeah. We have to be proactive ourselves. We do. Understand the risks. Absolutely. Be careful with our data. It's about being vigilant. So back to this deep dive, The DOD's approach to CSP security is a sign of the times. It is. This realization that cybersecurity is everyone's problem. It's a national security issue, an economic issue, a societal issue. Exactly. And while it seems complicated Yeah. At the end of the day, it's about protecting our country, our privacy, our way of life. Well said. In this digital world we live in. Well, I think we've covered a lot today We have. From the specifics to the big picture. Yeah. I hope this deep dive has been helpful and maybe even giving you some things to think about. Me too. It's been a great discussion. It's good to see the DOD taking this seriously. Mhmm. Hopefully, you'll encourage others to do the same. I hope so. As always, keep learning about this stuff. We'll have some links in the show notes. And don't hesitate to reach out with any questions. We love hearing from you. Absolutely. Stay curious. Stay safe. Great advice. Thanks for diving deep with us.