Vulnerability Scans Outsized Impact on FedRAMP ATO

Though vulnerability scanning is only one FedRAMP control requirement, it has an outsized impact on the FedRAMP process. In the journey toward receiving authorization to operate (ATO), for many companies, it presents a major challenge. Cloud service providers (CSPs) have to demonstrate a well-developed vulnerability management program. The discovery of high-severity vulnerabilities can detail the ATO recommendation process. Making vulnerability scanning a priority during the pre-assessment phase is the critical path for a smoother ride through FedRAMP requirements.

The importance of FedRAMP's focus on vulnerability scanning cannot be overstated. Any missteps in vulnerability scanning, or neglect in resolving high-severity issues, will lead to substantial delays in receiving authorization. That's true even if all other FedRAMP controls are satisfactorily met. Prioritizing the proactive mitigation of vulnerabilities as part of a solid vulnerability management strategy is key. This approach not only aids in efficient progress through the FedRAMP certification but also helps forestall serious risks that could prove costly later on.

Key Takeaways

• Vulnerability scanning is a key component of the FedRAMP security authorization process, with high-severity findings able to block ATO recommendations.
• CSPs must have a mature vulnerability management program in place, with the right people, processes, and technologies to successfully navigate FedRAMP requirements.
• Addressing vulnerabilities and demonstrating a robust scanning program in the pre-assessment phase can help avoid delays and create a more seamless FedRAMP certification journey.
• Incorrect vulnerability scanning procedures or failure to address severe findings can significantly impact the timeline for ATO recommendation.
• Proactive vulnerability management is essential for a successful FedRAMP authorization.

Significance of Vulnerability Scanning for FedRAMP

With its eye on maintaining system security, the FedRAMP program makes continuous monitoring (ConMon) key. This method ensures that cloud service providers (CSPs) keep their authorized systems secure. A vital part of ConMon, vulnerability scanning, offers monthly insights to the Joint Authorization Board (JAB) and authorizing officials (AOs) about the security of these systems.

Continuous Monitoring Expectation

The FedRAMP Continuous Monitoring Strategy Guide stipulates that CSPs must scan their systems monthly. This includes operating systems, web applications, and databases. Such monthly vulnerability scans are crucial. They identify and fix security weaknesses and promptly reduce the chances of breaches and a loss of business continuity. This practice ensures that FedRAMP-authorized systems remain compliant.

Core Component of Security Authorization

Vulnerability scanning is critical, not just for continuous monitoring but also for program authorization. The FedRAMP security control framework, especially RA-5, outlines these scanning requirements. It underscores the need to find, fix, and report system vulnerabilities to keep security intact.

These scanning requirements are designed to enhance the efficiency and the quality of security information for the FedRAMP program. By meeting these standards, CSPs demonstrate their dedication to security and compliance. This approach is foundational in the FedRAMP authorization journey.

"Vulnerability scanning is a critical component of the FedRAMP program, ensuring the continuous security and compliance of cloud systems."

Overall, vulnerability scanning plays a crucial role in both monitoring and securing systems. By actively detecting and remedying vulnerabilities, CSPs can ensure the security and compliance of their systems.

Vulnerability Scans and their outsized impact on getting Your FedRAMP ATO

A discovery of critical flaws during vulnerability scanning can halt ATO approval. As such, it marks a pivotal stage in the assessment process. By uncovering and addressing these faults early, firms enhance their progress toward ATO success.

Besides standard infrastructure and web vulnerabilities, container image scanning is now a FedRAMP requirement. This demands that applications and services in containers are free of threats. It bolsters the security posture of these deployments.

"Approximately 60-90 days from an expected security assessment report (SAR), a CSP should provide the 3PAO a recent set of scans, preferably from the most recent three months."

Being proactive in vulnerability scanning, both before and during assessments, greatly aids in gaining FedRAMP approval. Addressing serious and medium risks promptly is key. Such action increases the likelihood of securing the FedRAMP ATO.

Because scan failures represent a significant barrier to ATO, CSPs should begin reviewing them in the pre-assessment phase, and work with skilled implementers to create a plan to address them even before engaging in an initial audit.

FedRAMP requires three types of scanning: Infrastructure, Web App, and Database

FedRAMP mandates regular vulnerability scanning at three layers: infrastructure, web applications, and databases.

Infrastructure vulnerability scanning focused on the operating system and hardware. It looks for and addresses potential issues. Scans include virtual machines, networks, and storage on the cloud.

The focus of webapp vulnerability scanning is web applications in FedRAMP's zone. It examines code, settings, and add-ons. The aim is to identify vectors that bad actors might use to get in.

Database vulnerability scanning is also required for FedRAMP. It requires special access to the database. This ensures any database weaknesses are revealed and fixed.

"FedRAMP compliance can reduce the cost of FISMA compliance by up to 30% and enable organizations to detect cybersecurity vulnerabilities at unprecedented speeds."

Pre-Assessment Vulnerability Scanning

Pre-assessment vulnerability scanning is key in navigating the FedRAMP authorization journey. The initial scans should occur before engaging a 3PAO, with skilled implementers assisting in the of plans to address vulnerabilities. This early scan provides a clear scope of required resources for the entire journey. A lack of awareness of vulnerabilities can show up later and add delays and unplanned expenses to the process.

More than software is required

The use of vulnerability scanning software helps to leverage and accelerate the process but should be applied with the help of implementers who have direct experience in FedRAMP compliance.  Because the vulnerability solutions identified have to fit the broader FedRAMP compliance architecture and process, implementer skill in assessing and creating efficient remediation plans can save both time and money.

Authenticated Scanning Requirement

For systems at Moderate and High levels, authenticated scans are required. They allow comprehensive vulnerability checks by gaining full system access. It’s essential that all plugins are active during the scan unless a specific exception is made.

Scanning with Full Authorization

All Moderate and High systems must undergo scanning with complete authorization. This measure prevents common scan failures due to restricted access, like issues with remote registry or limited file access. It ensures the scans are thorough and effective.

Addressing Potential Issues Early

Early submission of scan data allows you to flag and fix issues, preventing delays in your SAR. Addressing these issues promptly can safeguard against critical findings or timeline disruptions in the FedRAMP process.

It's important to use the pre-assessment phase to document any known false positives and your operational needs. This openness aids the assessment process, ensuring your 3PAO understands your system's unique aspects clearly.

Assessment Phase Scanning Requirements

Approaching the FedRAMP authorization's final steps, assessment phase scanning requirements become paramount. The Third Party Assessment Organization (3PAO) performs in-depth scrutiny of your vulnerability scans. This serves to paint a live image of your environment's security stance.

Current Vulnerability Snapshot

The 3PAO's in-depth assessment aims to unveil all vulnerabilities within your system. They meticulously analyze scan data, looking for red flags. Their goal is to verify the efficacy of your remediation steps.

This snapshot is pivotal for the 3PAO. It's their benchmark to affirm your environment adheres to federal assessments and FedRAMP requirements.

Validating Remediation Processes

The 3PAO digs into your remediation processes alongside assessing vulnerabilities. They ensure your actions have mitigated all identified risks. This includes validating recent scans on your container images and other vital elements.

If you've implemented changes to scanning tools, personnel, or the entire boundary covered by your system, subsequent validations are required. These confirm the ongoing efficacy of your security measures.

Final Vulnerability Scanning

As the ultimate phase of achieving FedRAMP compliance, the Cloud Service Provider (CSP) performs one last set of vulnerability scans. This occurs approximately 5 to 10 days before the Security Assessment Report's (SAR) issuance. The objective is to confirm that every identified vulnerability has been properly fixed. It also aims to give an updated view of the system's security state.

These final scans are tightly focused, primarily on the effectiveness of the remediation efforts. The CSP has to take great care to ensure that those carrying out the scans are well-qualified. 

By finalizing these vulnerability scans, the CSP equips the FedRAMP Joint Authorization Board (JAB) or Agency with the most current insights into security. This input is vital when deciding whether to grant the FedRAMP Authority to Operate (ATO).

These scans, when done at the end, offer a current and deep understanding to the FedRAMP JAB or Agency. This knowledge is key for the FedRAMP ATO decision process.