Federal Risk and Authorization Management Program (FedRAMP) compliance is a complex journey that requires several key documents and deliverables. Two of the most important are the Security Assessment Plan (SAP) and the Security Assessment Report (SAR).
The SAP and the SAR play pivotal roles in ensuring cloud offerings undergo a thorough, standardized assessment of their implemented security controls prior to receiving a FedRAMP Authority to Operate (ATO).
Take the first step to securing your spot in the FedRAMP Marketplace: Get in touch with a cybersecurity expert today.
SAP vs. SAR – What’s the Difference?
The SAP is a proactive and strategic document provided by the FedRAMP Third-Party Assessment Organization (3PAO) that outlines the methodical approach to assessing the security controls of an information system.
Learn more: How to Choose the Right FedRAMP 3PAO to Partner With
It serves as a blueprint, guiding the assessor through the assessment process and ensuring a systematic and consistent evaluation. It specifies the assessment procedures, techniques, and tools to be employed, as well as the roles and responsibilities of all parties involved.
On the other hand, the SAR is a comprehensive document that evaluates the controls in place for an information system. It analyzes the system’s compliance with FedRAMP requirements and provides insights to help the Cloud Service Provider (CSP) and authorizing officials determine if the system is ready for authorization.
To oversimplify: The SAP lays out the how for the assessment process, and the SAR is the result of said assessment.
The SAP’s methodology and the SAR’s findings, forming an essential duo, work in tandem to provide a comprehensive understanding of the cloud service offering (CSO) and its security posture. It enables well-informed decisions regarding the system’s authorization and the residual risks.
These two documents also ensure a rigorous evaluation process, enhancing the overall security and compliance of cloud-based systems within the federal government landscape.
Learn more about developing an authorization package for FedRAMP: I’m a Cybersecurity Technical Writer. Here are My Best Tips on Documentation Development
Wait Wait — Is It “System” or “Security?”
You may have heard the terms “system assessment plan” and “system assessment report” used to refer to SAP and SAR. While technically correct and universally understood, the official verbiage is “security” instead of “system.”
You won’t get points knocked off if you interchange the two, but it’s helpful to know!
Let’s dive into more detail and explore the SAP and the SAR.
The FedRAMP SAP
What is it?
The SAP is developed collaboratively between the FedRAMP-accredited 3PAO and the CSP early in the assessment process.
It specifies the comprehensive scope, methodology, rules of engagement, and required security controls from the applicable FedRAMP baseline that will be evaluated based on the system’s categorization as low, moderate, or high impact.
What does it do?
The SAP describes the specific techniques like interviews, document reviews, configuration scans, and penetration testing that will be used to assess each control requirement.
It defines the testing environment specifications, personnel roles and responsibilities, timelines and milestones, constraints or risks, and criteria for determining control implementation status.
How is it used?
The SAP essentially serves as the master plan, outlining how the 3PAO will validate the cloud system’s compliance with federal security requirements.
What are the goals of the System Assessment Plan?
The goals of a System Assessment Plan (SAP) in the context of FedRAMP (or similar security frameworks) are to ensure that the security assessment process is well-structured, comprehensive, and effective in evaluating the security controls of a cloud service offering (CSO). Specifically, the goals of an SAP include:
Define the Scope of the Assessment
The SAP should clearly delineate what parts of the system will be assessed, including the boundaries of the system, the specific security controls to be evaluated, and the extent of the testing (e.g., network, applications, data).
It ensures that all relevant components of the system are covered and that the assessment team and stakeholders have a common understanding of what will be evaluated.
Establish Clear Assessment Objectives
The SAP must set specific goals for what the assessment aims to achieve, such as verifying the implementation of security controls, identifying vulnerabilities, and evaluating the effectiveness of the security measures.
It provides direction and focus for the assessment, ensuring that the activities are aligned with the overall purpose of evaluating the system’s security posture.
Detail Assessment Methodology and Procedures
One objective of this document is to describe the methods, tools, and techniques that will be used to evaluate the security controls, including manual testing, automated tools, interviews, and document reviews.
This is important because it ensures a consistent and repeatable approach to the assessment, allowing for accurate and reliable results.
Assign Roles and Responsibilities Related to the Assessment
Another objective of the SAP is to identify the personnel involved in the assessment, including the responsibilities of the assessment team (e.g., third-party assessment organization, or 3PAO), cloud service provider (CSP) staff, and any other stakeholders.
This ensures that everyone involved understands their role, responsibilities, and the expectations for their participation, leading to a more efficient and effective assessment process.
Develop a Detailed Assessment Schedule
Your SAP must create a timeline for the assessment activities, including key milestones, deadlines, and deliverables.
It helps manage time and resources effectively, ensuring that the assessment is completed on schedule and that all required activities are carried out in a timely manner.
Identify the Process’s Potential Risks and Challenges
The SAP should anticipate and address potential issues that could arise during the assessment, such as access limitations, resource constraints, or technical challenges.
This allows the assessment team to prepare for and mitigate potential obstacles, reducing the likelihood of delays or incomplete assessments.
Ensure Compliance with the Evaluation Requirements
An SAP must align the assessment with FedRAMP guidelines and requirements, ensuring that the process meets the standards necessary for a successful authorization.
Facilitate Communication and Coordination
Establish a plan for effective communication and coordination among all parties involved in the assessment.
This ensures that stakeholders are kept informed throughout the process, which is critical for addressing issues promptly and ensuring the assessment proceeds smoothly.
Prepare for a Thorough Evaluation
The SAP must lay the groundwork for a comprehensive evaluation of the system’s security controls, ensuring that the assessment will identify any weaknesses or gaps in security.
The SAP ensures that the assessment will be thorough and that the resulting findings will accurately reflect the security posture of the system.
Support the Development of the SAR
A good SAP should provide a clear and structured approach to the assessment that will produce reliable data and findings, which will be used to generate the SAR.
A well-executed SAP leads to a robust SAR, which is critical for the decision-making process regarding the system’s authorization to operate.
The FedRAMP SAR
What is it?
The SAR is a critical component of the FedRAMP authorization process for cloud service providers seeking to work with federal agencies. It represents the culmination of a comprehensive independent security assessment performed by an accredited FedRAMP Third-Party Assessment Organization (3PAO).
This evidence-based report details the test methods, tools, and artifacts examined for every security control. It assigns an implementation status, documents vulnerabilities found, provides an overall risk determination, and includes the 3PAO’s recommendation for risk acceptance or remediation.
How is it used?
The 3PAO conducts in-depth testing and evidence collection to thoroughly evaluate the cloud system’s implementation of the required security controls specified in the FedRAMP baselines.
This includes testing security capabilities across different control families such as access control, audit and accountability, configuration management, incident response, and many others.
The SAR represents the culmination of assessment activities, substantiating whether the cloud offering has adequately implemented the mandatory security controls.
What does it do?
The evaluation aims to identify any potential vulnerabilities, threats, and risks associated with the cloud offering.
Red-Flag Findings
The following are some examples of critical findings that would raise red flags and would be highlighted in a SAR:
- Insecure authentication mechanisms
- Weak password policies
- Lack of multi-factor authentication
- Insufficient access controls
- Failure to properly implement least privilege principles
- Lack of segregation of duties
- Misconfigured security settings
- Insecure default configurations
- Excessive permissions granted to users/services
- Vulnerabilities in software components
- Unpatched or outdated system components
- Use of unsupported or end-of-life software
- Inadequate data protection measures
- Insufficient encryption of data at rest and in transit
- Lack of secure key management practices
- Network security weaknesses
- Insecure network architectures and segmentation
- Lack of effective firewalling and traffic filtering
- Insufficient logging and monitoring capabilities
- Lack of comprehensive audit logging and review processes
- Failure to monitor for and detect incidents
- Physical security risks
- Lack of robust access controls to data centers and facilities
- Insufficient environmental safeguards (e.g., power, cooling)
- Supply chain risks
- Reliance on untrusted or unvetted third-party components/services
- Lack of visibility into the practices of subcontractors/vendors
- Inadequate security awareness and training programs
- Lack of comprehensive security awareness and role-based training
- Failure to instill a strong security culture within the organization
The 3PAO maps the cloud provider’s security posture and implemented controls to the FedRAMP baseline requirements for the desired data sensitivity level (low, moderate, or high).
Learn more: Decoding FedRAMP Baselines: Get to Know Low, Moderate, and High Impact Levels for Compliance
The SAR documents all findings from this rigorous assessment process, providing a detailed report on the extent to which the cloud system satisfies the mandatory FedRAMP security requirements.
It highlights any deficiencies or areas where additional safeguards may be needed.
What are the goals of the System Assessment Report?
Document Assessment Findings
The primary goal of the SAR is to document the findings and results of the independent security assessment conducted on the CSP’s information system. It captures the effectiveness of the implemented security controls and identifies any deficiencies or areas of non-compliance.
Provide Evidence for Authorization Decision
The SAR serves as a key piece of evidence for the authorizing official to make an informed risk-based decision regarding the authorization of the information system to operate. It provides a comprehensive evaluation of the system’s security posture and the residual risks associated with its operation.
Validate Compliance
The SAR aims to validate the CSP’s compliance with the FedRAMP security control baselines and other applicable requirements. It confirms whether the controls documented in the System Security Plan (SSP) are implemented correctly and operating as intended.
Identify Remediation Actions
If any deficiencies or vulnerabilities are identified during the assessment, the SAR provides the information for the CSP to develop remediation actions (POA&Ms) required to address those issues. This information helps the CSP prioritize and implement corrective measures to strengthen the system’s security posture.
The remediation guidance provided in the SAR serves as a roadmap for the CSP to enhance their capabilities and mitigate identified risks.
Support Continuous Monitoring
The SAR provides a baseline for continuous monitoring activities, enabling the CSP and the authorizing agency to track changes in the system’s security posture over time and ensure that controls remain effective.
By establishing a comprehensive baseline, the SAR facilitates ongoing monitoring and evaluation, allowing stakeholders to identify and address emerging threats or vulnerabilities proactively.
Facilitate Transparency and Accountability
The SAR promotes transparency and accountability in the FedRAMP authorization process by providing a detailed and independent evaluation of the system’s security controls. It serves as a record of the assessment activities and findings for stakeholders, including the authorizing official and oversight bodies.
This transparency enhances trust in the authorization process and enables stakeholders to hold CSPs accountable for maintaining adequate security measures.
Enable Reciprocity
By following the FedRAMP assessment process and documenting the findings in the SAR, the CSP can share and reuse the assessment across different federal agencies. This allows them to avoid having to redo the same assessment multiple times for each agency, saving effort and resources.
The reciprocity facilitated by the SAR promotes efficiency and consistency in the evaluation of cloud services across the federal government landscape.
Why is it needed?
The SAR serves as a crucial piece of evidence that the authorizing official (government or third-party) reviews when making the risk-based decision to grant or deny an Authority to Operate (ATO) for the cloud service at a specific data sensitivity level.
An ATO essentially means the cloud offering has been deemed secure enough to host federal data at that authorized level (low, moderate, or high impact).
What happens without an ATO?
Without an ATO, federal agencies cannot leverage that cloud service for processing, storing, or transmitting sensitive data subject to FedRAMP requirements.
The SAR provides transparency into the cloud system’s security posture and gives the authorizing official confidence in the degree of risk mitigation implemented by the provider. Favorable SAR findings increase the likelihood of the cloud service receiving an ATO.
It’s a critical quality assurance checkpoint in the FedRAMP process, ensuring cloud services meet the stringent security standards required before handling federal information systems and data.
More Questions?
Our team of experts at 38North Security have extensive experience in working with 3PAOs to develop SAPs, conduct assessments, and prepare SAR deliverables. We can provide invaluable insights to the CSP on the expectations and strategic advice to help you navigate this complex assessment process successfully.
Call us! 38North Security is a leader in building a compelling FedRAMP authorization package, which helps you obtain an Authority to Operate for your cloud service.
