The 2 Things I Wish I Could Change About FedRAMP

How could FedRAMP improve without lowering security standards? Kenny's got thoughts.

Kenny Scott
|
53
min read

In This Article

If I had the Elder Wand, here’s how I'd immediately change FedRAMP:

1- Eliminate the Agency Sponsorship Requirement

Empower companies to pursue FedRAMP independently – no more waiting for the stars to align. Removing this barrier would accelerate innovation without sacrificing quality.

2- PMO Oversight of 3PAOs (Not CSPs) 

The FedRAMP PMO should borrow a page from the AICPA's playbook for CPA firms and directly audit and oversee 3PAOs. 

This change would streamline approvals while maintaining the rigorous standards FedRAMP demands.

Why These Changes to FedRAMP Could Help

These two simple shifts would dramatically improve accessibility without lowering FedRAMP’s high security standards

Achieving FedRAMP compliance means operating at the highest levels of security – beneficial even if you never directly sell to the government. Your customers that do sell to the government will thank you.

What would you change? Share your ideas over on LinkedIn.

PS, if you've been scared of FedRAMP – it's faster, less expensive, and easier than ever with Paramify. Check out a demo today to see how much better it can be.

Kenny Scott
Kenny is an accomplished leader with a two decade tenure in Information Security and IT Audit. He's widely acknowledged in the industry and has a profound dedication to it. In addition to his technical expertise, Kenny's portfolio includes substantial experience in business strategy, investment, and programming. On the personal side, Kenny is a devoted husband to Angie Scott and a proud father of five. A music enthusiast, he relishes playing the guitar and enjoys surfing when a beach is within reach.
Mar 2025
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Once authorized, can I sell to any federal agency?

Yes — authorization can be reused by multiple agencies via the FedRAMP Marketplace, but some agencies may request additional requirements.

How is FedRAMP 20x different from traditional FedRAMP?

20x introduces automation, key security indicators (KSIs), continuous monitoring validation, and streamlined authorization (sometimes without sponsor requirements).

Compare KSIs to Rev 5 controls

What are the most common reasons for delays or failures in FedRAMP authorization?

Incomplete documentation, insufficient evidence, failing initial gap assessments, lack of executive support, and underestimating resource requirements.

How to create the most accurate documentation for audit success

What's the difference between FedRAMP and other frameworks (SOC 2, CMMC, ISO 27001)?

FedRAMP is U.S. government-specific and NIST-based, more prescriptive and granular than commercial standards.

How do inherited controls from my cloud infrastructure provider (e.g., AWS, Azure, GCP) work?

FedRAMP allows CSPs to “inherit” controls from IaaS providers; you must document and verify this inheritance with shared responsibility models.

What kind of technical controls are required under FedRAMP?

Controls follow NIST SP 800-53 Rev 5 (with additional FedRAMP overlays) — covering access control, incident response, risk assessment, configuration management, etc.

→ Get your custom accelerated FedRAMP implementation roadmap

How often do I need to update and submit security documentation?

At minimum: 

  • Monthly POAMs and vulnerability scans
  • Annual security assessments
  • Ad hoc submissions for significant changes.

What is a POA&M?

Plan of Action and Milestones: a document tracking remediation plans for open vulnerabilities, findings, and compliance issues.

→ Learn more about POAMs

What is continuous monitoring (ConMon) and why is it important?

ConMon involves ongoing assessments, vulnerability scanning, reporting POAMs, and keeping security posture current post-authorization.

What documentation is required for FedRAMP?

Major deliverables include a System Security Plan (SSP), Security Assessment Plan (SAP), Security Assessment Report (SAR), Plan of Actions and Milestones (POA&M), Continuous Monitoring (ConMon) documentation, policies/procedures, and more.

Do I need an agency sponsor?

Yes, for now. But, agency sponsorship requirements are evolving — FedRAMP 20x does not require a sponsor.

How do I pick the best 3PAO for my project?

Consider experience with similar environments, references, price, and knowledge of specific cloud implementations.

Find the best assessor for your CSP with these tips

What is a 3PAO?

A Third Party Assessment Organization is an accredited independent assessor that conducts key security testing and assessment for FedRAMP. 

→ Find a recommended 3PAO

How much does FedRAMP Authorization cost?
  • Initial costs range from ~$150k to $3M+ for gap assessments, remediation, 3PAO audits, and documentation/reporting. 
  • Annual costs can range from $50k to $1m to maintain documentation, do continuous monitoring, and resource allocation. 

→ Learn more about what FedRAMP could cost your organization and whether or not it’s worth the effort

How long does it take to achieve FedRAMP Authorization?

Typical processes take 6–24 months. Paramify accelerates the process to take between 1-10 months with a fully prepared package in less than a month. 

Your timeline will vary depending on your impact level, whether you take a manual or automated approach to implementation & documentation, and PMO wait times.

→ Learn about the FedRAMP Authorization process and what it costs.

What’s the difference between FedRAMP Ready, FedRAMP In Process, and FedRAMP Authorized?
  • Ready: Preliminary review for capability and documentation.
  • In Process: CSP is actively working toward authorization, usually with an agency sponsor or as part of the JAB program.
  • Authorized: Successfully completed security assessment and continuous monitoring.
What are the different impact levels for FedRAMP?

Low, Moderate, and High — based on the type and sensitivity of federal data hosted (FIPS 199 categories: confidentiality, integrity, availability).

→ Get the details on impact level to know which impact level is right for you.

Do You Need FedRAMP?

Any cloud service provider (CSP) that wants to sell cloud products or services to U.S. federal agencies must be FedRAMP authorized.

→ Learn more to find out if FedRAMP is a good choice for your cloud-based business.

What is FedRAMP

FedRAMP stands for the Federal Risk and Authorization Management Program; it standardizes the security assessment, authorization, and continuous monitoring for cloud products and services used by U.S. federal agencies.

How long will it take to generate my SSP?

If you’re new to FedRAMP: The time required depends on how long it takes to implement your security controls. With Paramify’s living gap assessment dashboard, you can build your compliance roadmap and generate documents instantly with one click.

If you’re already FedRAMP authorized: It can take as little as 3.5 hours or up to a week.

Can you help me transition from NIST 800-53 Rev 4 to Rev 5?

Yes! No one will help you transition to FedRAMP Rev 5 as affordably and painlessly as Paramify. Learn how you can make a seamless, inexpensive transition to Rev 5.

Can I use my existing SSP?

Yes, we offer this service and have provided it for many clients. Most of our customers, including those for whom we’ve ingested their SSP, have found that starting from scratch and adopting the full power of Risk Solutions was the better option.