Unpacking the NIST 800-53 Rev 5 FedRAMP Update

The release of NIST 800-53 Rev 5 is a bit like that time I thought I'd impressed my mom by tidying up my room. All I did was shuffle my laundry heap from the floor to the closet. She glanced around and cheered, "Voila! Spotless!" But we both knew it was the same mess in a different place – much like Rev 5’s Moved Requirements.

Then there's the charm of Split Requirements, akin to ordering a pizza and getting it delivered slice by slice. Still a whole pizza, sure, but it means answering the door eight times.

Don't forget Removed Requirements – I know you worked hard on that VOiP control, but no one cares.

And then, as if out of a bad horror movie sequel, here come the New Requirements, with fourth-party vendors emerging from the shadows like unexpected beasts.

While the control count appears to have shrunk, much like my eagerness to clean my room, the actual workload has mounted, jumping by 13% for high-risk categories. Akin to the spike in my stress levels every tax season.

Fun times! But fear not, we've got this. Let's dive in.

FedRAMP Control Counts

The burden of the transition relates mostly to documentation.

Alright, so if we're looking at the tables that came right out of the FedRAMP cookbook, we've got the control changes in the High, Moderate, Low, and Li-SaaS categories from NIST 800-53 Rev 4 to Rev 5:

Rev4 to Rev5: Changes to FedRAMP Controls

At first glance, you'd think, "Woohoo! Downhill run! Fewer controls in High and Moderate, sounds like an easy cruise, right?"

It's like when you start a diet and the first day, you lose 2 pounds. You think, "Hey, this isn't so bad!"

But then you notice the Low and Li-SaaS categories had to go and spoil the party. They've bulked up like they're preparing for a hibernation, going up by 25% and 127%, respectively.

But then, like a surprise twist in a sitcom, we get the Actual Requirements:

Actual FedRAMP Requirements

Just like realizing your preferred 'low-calorie' meal is brimming with carbs, the layers within these controls have a surprise in store.

These numbers have no intention of embarking on a weight-loss journey. High went up by 13%, Moderate by 16%, and Low and Li-SaaS?

They're getting their winter coats ready, going up by a solid 34% and 86%, respectively.

Rev4 to Rev5: Actual Changes in Requirements^[1]

Closer Look at Control Families

Then, we move onto the Control Families.

It's kind of like getting your whole extended family together for a reunion and realizing Aunt Mildred had triplets since the last gathering.

Looking at these numbers, it's clear that some families have definitely been busier than others. Things like Access Control, Configuration Management, Contingency Planning, and System and Services Acquisition have not been lazing around.

But wait, there's more!

To really spice up the compliance soup, we have a new category to consider – "Supply Chain Risk Management".

Big shoutout to Chris Hughes, a leader in this space, for his pioneering work. Dive into his illuminating book or his insightful podcast episode. Hats off to Chris for lighting the path!

FedRAMP (NIST 800-53 Rev 4) Requirements Breakdown

FedRAMP (NIST 800-53 Rev 5) Requirements Breakdown^[1]

Changes in the SSP

Crafting a quality System Security Plan (SSP) while keeping up with regulatory changes is like building a complex sandcastle on the beach, just to have the wave come in and scatter everything.

SSP Change Summary

But, let's not get too dramatic. Fortunately, for those using Risk Solutions, you've got 14 shiny new solutions at your disposal. They're like magic tricks for your security controls.

New Parameters in NIST 800-53 Rev 5

Oh Hey PARAMETERS! GOOD TO SEE YOU!

Just when you thought it was over, we need to update the new PARAMETERS. It's like finding another hidden level in your favorite video game, but way less fun.

Rev 4 to Rev 5 parameters

As you can see, the parameters have decided to jump up on the bandwagon as well, with increases in all categories. It's like adding extra toppings on an already overstuffed pizza.

You thought the supreme was enough?

Nope, here come the anchovies, olives, mushrooms, and extra cheese!

Steering through the twists and turns of the new NIST 800-53 Rev 5 can feel like attempting to navigate a labyrinth while blindfolded and juggling flaming torches. It's no leisurely stroll, but this is where Paramify comes to the rescue.

With our help, tackling these parameters becomes as breezy as a walk in the park on a sunny Sunday afternoon.

How Do Risk Solutions help?

Navigating the twists and turns of NIST 800-53 Rev 5 doesn't need to feel like an uphill battle. Armed with Paramify's Risk Solutions, you'll find a streamlined strategy for tackling the new requirements and changes.

Think of it as reducing a complicated riddle into a set of simple, solvable puzzles.

Risk Solutions act as your real-time compliance compass, providing clear visibility into your risk posture and allowing for swift, mid-course corrections.

With Risk Solutions, you're not just prepared to weather the compliance storm, but to steer confidently through it.

Check this out for a refresher on building your own Risk Solutions. You'll find helpful insights and practical advice to set you on the right path within the NIST 800-53 Rev 5 landscape.

Get a free demo to see for yourself!

Get a demo to see, in detail, how you can instantly, completely, and accurately upgrade your FedRAMP Package from Rev. 4 to Rev. 5 without hiring a tech writer.

The PMO would like your plans in their hands soon. The time to act is now.

^[1] These numbers have been updated based upon the newest control templates released by the FedRAMP PMO. Previous numbers were estimates.

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.

Jun 2023

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.

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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.

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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.

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