FedRAMP has been a cornerstone of cloud adoption in the federal sector, ensuring that cloud service providers meet rigorous security standards. However, as digital transformation accelerates and government agencies seek faster adoption of innovative solutions, traditional compliance methods have proven time-consuming and resource-intensive.

To address these challenges, FedRAMP has introduced the Agile Delivery Pilot, a groundbreaking initiative to streamline the authorization process and promote iterative innovation and improvement without incurring compliance penalties.

This article discusses the details of the Agile Delivery Pilot, examining its methodology, how it improves upon traditional FedRAMP processes, and what it means for the future of cloud services and compliance frameworks.

What Is the FedRAMP Agile Delivery Pilot?

The FedRAMP Agile Delivery Pilot emphasizes real-time collaboration, iterative assessments, and automation by integrating agile methodologies into compliance. It departs from the linear compliance model—a sequential and exhaustive process that often takes months or even years—toward a more dynamic approach that cuts some of the red tape regarding department approvals.

The Agile Delivery Pilot allows CSPs to create new services or features without undergoing pre-approval with a sponsoring agency. By breaking down the compliance journey into manageable phases, the program ensures faster feedback, quicker identification of security gaps, and a more adaptable security posture for cloud solutions.

This integration of modern practices is designed to meet the needs of today’s rapidly evolving cybersecurity landscape, where threats emerge faster than traditional compliance processes can adapt.

How Does It Differ from Traditional FedRAMP?

While robust, FedRAMP’s traditional compliance process has faced criticism for being slow and unresponsive. This legacy approach involves three phases:

Preparation Phase: CSPs prepare documentation and implement controls based on FedRAMP’s security requirements.
Authorization Phase: An independent third-party assessment organization (3PAO) validates the CSP’s compliance, followed by a detailed review by federal agencies or the Joint Authorization Board (JAB).
Continuous Monitoring Phase: Post-authorization, CSPs must conduct regular audits and reporting to maintain their security status.

This process, though comprehensive, is often resource-intensive, especially when a provider attempts to roll out new features on an already-authorized cloud offering. CSPs frequently encounter delays due to extensive documentation reviews and unclear requirements.

Who Will Be Eligible for the Program?

The FedRAMP Agile Delivery Pilot introduces a streamlined process to efficiently implement new features and services. Currently, six organizations are undertaking the pilot, all of whom meet the following criteria:

Planned Deployment of New Features: CSOs must have one or more new services or features scheduled for deployment during the pilot period, which runs from October 15, 2024, to December 31, 2024. These features should offer an opt-in capability for agencies, ensuring that adoption is at the agency’s discretion.
Mature Configuration and Change Management Processes: Applicants must have well-documented and automated configuration and change management plans. Implementing frameworks like NIST Special Publication 800-218, the Secure Software Development Framework (SSDF) Version 1.1, or similar secure software development frameworks is encouraged.
Automated Deployment and Verification Mechanisms: CSOs should utilize automated mechanisms to deploy services and features and verify their secure implementation. Non-manual configuration implementations, such as infrastructure as code, are encouraged to enhance consistency and security.
Incorporation of Vulnerability Scanning and Developer Testing: The CSO’s change and deployment processes should include vulnerability scanning and developer testing to proactively identify and mitigate potential security issues.
Willingness to Share Processes and Security Artifacts: Participants should be open to sharing their mature processes and plans, including security artifacts, to contribute to the FedRAMP knowledge base and assist in refining the pilot program.
Strong Compliance Record: CSOs must demonstrate strong compliance, with no open corrective action plans in the past six months due to issues with configuration management or failures to adhere to existing significant change request processes.
Diverse Representation: The selection process aims to include a diverse representation of CSOs, encompassing various business sizes and different cloud service deployment models (IaaS, PaaS, SaaS).
Agency Customer Participation: CSOs should have agency customers willing to participate in the pilot, facilitating real-world testing and feedback.

It follows that these criteria will apply, in part or in whole, to anyone who participates in the program once it is implemented.

Implications for Cloud Service Providers

The FedRAMP Agile Delivery Pilot will have profound implications for CSPs aiming to provide services to federal agencies. These include:

Accelerated Time to Authorization: For many CSPs, the time to market for their solutions is critical. The Agile Delivery Pilot reduces the time required to achieve FedRAMP authorization for iterative features, allowing CSPs to deploy their offerings more quickly. This is especially important in the healthcare, defense, and emergency management sectors, where innovative cloud solutions can directly impact mission success.
Lower Compliance Costs: Traditional FedRAMP processes can be costly, particularly for small and medium-sized CSPs. The pilot reduces redundant documentation and review cycles, enabling CSPs to allocate resources more efficiently. Automation tools also reduce labor-intensive tasks, further lowering costs.
Continuous Security Improvement: The Agile Delivery Pilot’s iterative nature ensures that security measures are implemented and refined over time. CSPs can integrate lessons from initial assessments into subsequent iterations, resulting in a more robust security posture.
Competitive Advantage: Achieving FedRAMP authorization faster provides CSPs with a competitive edge in the federal marketplace. CSPs can differentiate their services and capture more opportunities by positioning themselves as agile and responsive.

What It Means for Government Agencies

Federal agencies stand to benefit significantly from the Agile Delivery Pilot as well:

Faster Access to Secure Technologies: The streamlined process enables agencies to adopt secure cloud technologies more quickly, helping them keep pace with mission-critical demands. This is particularly beneficial for agencies dealing with rapidly evolving needs, such as disaster response or public health emergencies.
Enhanced Collaboration with CSPs: The pilot fosters a collaborative environment where agencies and CSPs work together to address security risks. This partnership approach leads to better solutions tailored to each agency’s needs.
Improved Risk Management: By integrating risk assessments early in the compliance process, the Agile Delivery Pilot allows agencies to identify and mitigate potential security issues before they become critical. This proactive stance enhances overall risk management.

Potential Changes and Challenges with Agile Delivery

While the Agile Delivery Pilot offers a groundbreaking approach to streamlining cloud compliance, it comes with challenges and considerations that both Cloud Service Providers and federal agencies must address. Understanding these potential obstacles is critical to ensuring the success and scalability of this initiative.

Cultural Transformation and Organizational Buy-In: Transitioning from traditional, linear compliance processes to an agile framework demands a fundamental cultural shift between CSPs and federal agencies. This change can be particularly challenging for organizations with deeply entrenched hierarchical decision-making structures or those reliant on legacy systems. Success requires cultivating an environment where collaboration, flexibility, and rapid response to change are embraced.
Navigating the Agile Learning Curve: CSPs unfamiliar with agile methodologies may face a steep learning curve. Unlike traditional compliance approaches, which focus on exhaustive documentation and phased reviews, the Agile Delivery Pilot emphasizes continuous integration, iterative assessments, and automation.
Maintaining Robust Security in an Accelerated Framework: One of the most critical challenges lies in balancing the faster compliance timelines of the Agile Delivery Pilot with the need to maintain comprehensive security standards. CSPs must integrate advanced vulnerability scanning, continuous monitoring, and automated risk assessments into their workflows to ensure that speed does not come at the expense of security.
Resource Constraints for Smaller Providers: While promising, the Agile Delivery Pilot could present scalability challenges for smaller CSPs with limited resources. Agile methodologies often rely on automated tools, advanced infrastructure, and highly skilled teams—all of which require significant investment. Smaller providers may struggle to meet these demands, potentially creating a gap between well-resourced CSPs and their smaller counterparts. This might call for smaller businesses (or those without dedicated security teams) to work with third-party vendors to pick up the slack.

Keep up with Changing FedRAMP Approaches with Lazarus Alliance

If you’re a CSP delivering services as part of your FedRAMP infrastructure, you’ll need a trusted partner to help you audit it. That partner is Lazarus Alliance.

To learn more about how Lazarus Alliance can help, contact us.

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