Most organizations pursuing FedRAMP can tell you how much they’re paying their assessor. They know what their consultants cost, what they’ve budgeted for specialized tooling, and how much they’re spending to maintain their federal cloud environment.
Ask how much engineering time goes into preparing for an assessment, however, and the calculation becomes considerably more complicated.
How many weeks did security engineers spend gathering evidence? How much time went into reconciling documentation, preparing for interviews, responding to assessor requests, or explaining changes made since the previous review?
And what work was delayed while those engineers were busy preparing to demonstrate security?
These costs rarely appear as separate line items in a FedRAMP budget. Nevertheless, they are real, recurring, and potentially substantial.
FedRAMP 20x creates an opportunity to change that equation. Understanding the financial implications requires looking beyond assessment fees and examining how organizations spend money throughout the lifecycle of their cloud systems.
In a new 38North Security white paper, Sam Leestma, our Vice President of Solutions Engineering and former Deputy Program Manager at the FedRAMP PMO, examines how continuous validation changes the economics of certification. One of the most interesting implications is the cost that rarely appears on an invoice: engineering time.
The Hidden Cost of Proving Security
Consider the engineering effort involved in a typical assessment cycle. Security and engineering teams may spend weeks collecting screenshots, locating artifacts, validating documentation, reviewing system configurations, and responding to questions about how their environments operate.
Some of this work is unavoidable. Independent assessment requires careful examination, technical judgment, and reliable information. Other activities are repeated largely because the information needed for assessment must be assembled, reconciled, or reconstructed each time.
An engineer spending three weeks preparing for an assessment represents three weeks of labor expense. It also represents three weeks unavailable for improving vulnerability management, reducing technical debt, strengthening security architecture, or developing new capabilities.
Multiply that effort across several engineers, recurring assessments, and years of operation, and the opportunity cost becomes significant.
Organizations may have perfectly reasonable budgets for assessments while substantially underestimating the internal resources those assessments consume.
The financial consequences extend beyond engineering hours, too. Maintaining duplicated environments, purchasing FedRAMP-specific versions of commercial tools, and coordinating significant changes can introduce additional expenses throughout the system’s lifecycle.
Understanding the total cost of FedRAMP requires accounting for all of them.
What changes when validation becomes continuous?
FedRAMP 20x establishes a different operating model for demonstrating and maintaining security: Instead of concentrating so much effort around periodic evidence collection, cloud providers maintain current verification and validation information as their systems operate.
That includes information from authoritative operational sources, applicable automated Key Security Indicator (KSI) checks, historical validation results, vulnerability evaluation, and recurring reporting.
Consider a relatively straightforward example: verifying whether multifactor authentication is enabled for applicable accounts. Under a periodic assessment approach, demonstrating this requirement may involve collecting screenshots, reviewing configurations, preparing supporting documentation, and answering questions about the implementation.
With an appropriate automated validation method, a team can query its authoritative identity system, compare the current configuration against the expected result, and maintain a history of those checks. The information becomes available for operational review throughout the year and can support independent assessment when the time comes.
The underlying security requirement still needs to be implemented correctly. The organization still needs to understand what the results mean, investigate failures, and maintain appropriate records.
But the work required to demonstrate the current state of that security measure can become considerably more repeatable. For Classes B, C, and D, annual independent assessments remain part of FedRAMP 20x. Continuous validation changes the information maintained between those assessments and the preparation required to support them.
That creates a financial opportunity worth examining: How much effort could an organization avoid repeating if accurate, reviewable information were already available?
There is an upfront price for doing this well
Continuous validation introduces its own engineering requirements. Cloud providers need to identify authoritative data sources, establish appropriate telemetry, configure system security context, develop reliable integrations, and implement verification and validation methods suited to their environments.
Good system design becomes particularly important. An organization with mature cloud infrastructure, dependable operational data, and established automation may already have much of the necessary foundation.
Another organization may need substantial investment before its systems can consistently produce the information required for continuous validation. That work has a cost, and organizations should account for it when evaluating their FedRAMP path.
The potential return comes from building capabilities that can be used repeatedly. Reliable operational data can support security monitoring, validation, vulnerability evaluation, assessment readiness, and reporting. Integrations and automated methods can serve ongoing requirements instead of being recreated for individual compliance activities.
There may also be opportunities to reduce duplicated infrastructure and unnecessary tooling expenses through careful scoping and architecture decisions.
The financial benefits depend on how well the operating model is designed, how much existing technology can be reused, and how much recurring effort can be reduced.
A different way to build the FedRAMP business case
For cloud providers evaluating FedRAMP 20x, the business case should include several questions that traditional certification budgets may overlook.
How much engineering effort does each assessment cycle consume? Which activities involve repeatedly gathering or reconstructing information? How much does the organization spend maintaining parallel systems or specialized tooling? What investments would be necessary to maintain current validation information? And how many other operational requirements could benefit from those same capabilities?
These questions matter because the economics of FedRAMP accumulate over time.
A lower initial assessment fee offers an immediate financial benefit. A well-designed operating model may create savings across years of assessment preparation, reporting, significant change coordination, and system maintenance.
Those savings are neither automatic nor uniform. They depend on system scope, engineering maturity, architecture, existing tooling, and the work necessary to implement continuous validation.
For some organizations, the upfront investment could be considerable. For others, the shift may allow them to make better use of capabilities they already have.
The important decision is understanding where the costs will accumulate and what investments can reduce repeated work over the life of the system.
The economics follow the operating model
FedRAMP 20x gives cloud providers an opportunity to reconsider some longstanding assumptions about the cost of federal certification. Assessment fees are one part of that calculation. Infrastructure, tooling, engineering effort, recurring preparation, and operational disruption all contribute to the total.
Continuous validation changes how those activities can be organized, supported, and maintained. And for organizations that build the right foundations, the economic value can extend well beyond the next assessment.
Where can FedRAMP 20x actually reduce costs?
Our white paper, FedRAMP 20x and the New Economics of Certification, examines five areas where continuous validation may change the cost of certification.
Drawing on 38North Security’s practitioner experience, it includes illustrative cost comparisons, scoping considerations, assessment economics, significant change expenses, and the technical investments required to realize long-term value.
What Could FedRAMP 20x Change for Your Bottom Line?
Every cloud environment has a different cost profile, and the opportunities to reduce recurring work depend on your architecture, existing tools, and engineering maturity.
38North Security can help you evaluate your current FedRAMP operating model, identify where time and money are being spent, and develop a practical approach to continuous validation.
Let’s talk about what FedRAMP 20x could look like for your organization.
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