Are You Really FedRAMP Ready? What It Actually Takes

Many cloud services and SaaS providers are eager to enter the federal market, but many underestimate what it really takes to achieve a FedRAMP authorization. FedRAMP is not just a checklist or an exercise in paperwork; it’s a high stakes, high complexity, and high-cost project that demands the right people, the right systems, the right documentation, and most importantly, full executive-level commitment, with extensive governance applied continuously.

In this post, we break down what “really ready” means when preparing for FedRAMP Moderate, why it’s tied tightly to NIST SP 800-53 Revision 5, and what potential risks, costs, and pitfalls companies should be prepared for.

FedRAMP = NIST SP 800-53 Rev. 5 in Action

Understanding this connection is crucial because FedRAMP readiness isn’t just about meeting compliance checkboxes; it’s about demonstrating that your security controls are operationally mature and audit ready.

What “FedRAMP Ready” Actually Looks Like

Preparing for FedRAMP authorization requires a disciplined, comprehensive approach to both fully implementing and extensively documenting all the required security controls. One major first step is to map all your system controls to the NIST 800-53 Rev. 5 control families. This mapping indicates that every aspect of your environment has been meaningfully evaluated against the federal security requirements. This comprehensive mapping is crucial to ensure organizations do not overlook critical controls, which can lead to findings during assessments, cause delays in authorization processes, and failures to meet federal compliance standards. Each control family has specific objectives that protect the Confidentiality, Integrity, and Availability (the “CIA Triad”) of data, making the thorough mapping essential for demonstrating a secure and compliant system right out of the gate.

Once controls are mapped, next steps are to ensure controls are fully implemented, documentation is thoroughly prepared, and evidence is ready, in order to support the impact level relevant to the CSP (Cloud Service Provider). FedRAMP does not accept aspirational compliance, and auditors expect validated, verifiable evidence that each control is in place and functions as intended, fully aligned to the impact level. Proper implementation indicates that the system is not only secure, auditable, but can provide the confidence federal agencies need to trust the platform, and assume the risk of the CSP for federal data processing.

Additionally, of equal importance is the alignment of plans, policies, procedures, and technical baselines to Rev. 5 requirements, before the formal assessment takes place. A proactive alignment indicates that required organizational governance, operational processes, and technical configurations are all consistent with required federal standards. When there is misalignment at this stage, it often results in gaps between documentation and actual system implementations and behaviors, which auditors will flag as gaps and deficiencies. By preparing for and addressing these gaps proactively, organizations can help reduce the risk of costly remediation needs, rework, retesting, repeat assessments, and even delayed approvals/authorizations.

 

The Hidden Costs That Can Catch Companies Off Guard

The “TCO” (Total Cost of Ownership) for FedRAMP compliance can be significantly higher than for a typical commercial Cloud Security Offering (CSO) due to both the breadth and depth of federal requirements. Many companies underestimate these costs as FedRAMP not only mandates robust security controls, but also requires extensive documentation, continuous monitoring, and independent assessments that go beyond standard commercial compliance frameworks.

Additional factors that drive higher costs include the need for specialized tooling, US-based personnel for in-boundary work, multiple 3PAO engagements, and ongoing efforts to maintain authorization. Organizations often fail to anticipate the cumulative impact of these requirements on staffing, vendor management, and operational overhead, leading to budget overruns if FedRAMP-specific costs are not carefully planned for from the start.

Specialized Tooling Requirements

FedRAMP-aligned security tools, ticketing systems, SIEM platforms, vulnerability scanners, and documentation frameworks often come at a premium price because they must meet stringent federal requirements for security, auditability, and reporting. Unlike standard commercial tools, FedRAMP-compliant solutions are designed to provide continuous monitoring, detailed audit logs, and automated evidence collection to satisfy rigorous control baselines. Cost drivers include licensing fees for enterprise-grade capabilities, ongoing maintenance and support, integration with other compliance systems, and the need for specialized configuration to align with FedRAMP controls. Vendors that are FedRAMP approved may charge higher fees, reflecting the specialized functionality and the assurance that the tooling can withstand federal-level audits and assessments.

Staffing Requirements

US citizens must perform FedRAMP-related work, per federal requirements, which clashes with the use of “offshore” development teams if your code is “in scope”. US citizens are required to perform FedRAMP-related work due to federal regulations, which directly affects companies that rely on offshore development teams when the code or systems in question fall “in scope” for FedRAMP. For organizations with existing offshore teams, this requirement can create significant business impacts, including the need to restructure development workflows, reassign or hire US-based personnel, and potentially increase payroll costs due to higher salaries in the US compared to offshore locations.

Companies may also face project delays as they transition responsibilities from offshore to onshore teams, and there can be challenges in maintaining institutional knowledge and continuity if experienced offshore developers are no longer permitted to work on newly regulated systems. These compliance-driven constraints require careful workforce planning and budgeting to ensure FedRAMP obligations are met without severely disrupting ongoing operations and business requirements.

Specialized Expertise Gap

FedRAMP engagements demand highly specialized expertise that goes far beyond general cloud technology or DevOps skills. Teams must have a deep understanding of NIST 800-53 Rev. 5 controls, including how to implement and document them appropriately for federal systems, as well as knowledge of inheritance models, boundary scoping, and continuous monitoring practices. This level of specialization ensures that security controls are not only in place but also auditable and aligned with the stringent FedRAMP requirements.

The reality is that FedRAMP expertise is rare, and consultants and staff with FedRAMP-specific experience command premium rates, which can significantly increase project costs (see TCO). Organizations without in-house specialists typically need to engage external advisors and/or hire highly skilled personnel, adding both upfront expenditures and ongoing operational costs for maintaining FedRAMP compliance. In practice, these skill requirements influence budgeting, project timelines, expand the scope, and even highly influence the selection of partners, making careful workforce and financial planning essential for a successful FedRAMP outcome.

The Sponsorship Reality

You cannot simply “submit” for FedRAMP on your own; you need an active federal sponsor to champion your authorization package. FedRAMP is a government compliance framework, not just a security standard you apply for independently. Here are some important points:

• The sponsoring agency owns the risk of using your cloud system.
• The agency reviews, accepts, and submits your package to the FedRAMP PMO.
• The FedRAMP PMO does not authorize you directly.

Multiple Third Parties & Assessment Partners

A company embarking upon a FedRAMP journey will typically need both an advisory 3PAO (to guide readiness) and a formal assessment 3PAO (to conduct the audit), where these entities cannot be the same firm to avoid conflicts of interest. Organizations typically engage two distinct types of FedRAMP 3PAOs: an advisory 3PAO and a formal assessment 3PAO. The advisory 3PAO provides guidance and readiness support, helping the organization understand the requirements, implement security controls, and prepare documentation in alignment with FedRAMP standards. The formal assessment 3PAO is responsible for conducting the official audit and issuing the security authorization package.

It is critical that these two roles are filled by separate firms to prevent conflicts of interest, as the advisory 3PAO could otherwise have an incentive to influence the audit outcome in favor of its considerations. Organizations must clearly define the scope of work, establish NDAs, and maintain transparent documentation practices to ensure compliance, avoid any duplicate efforts, and uphold the integrity of the assessment process.

 

What You Actually Need In Place To Be FedRAMP Ready

This comprehensive checklist represents the foundational requirements that must be fully operational and documented before beginning your formal FedRAMP assessment. These aren’t aspirational goals or work-in-progress items; each element must be complete, tested, and ready for audit scrutiny:

• System at ~99% operational for use, deployed in a FedRAMP authorized cloud offering
• System boundary diagram finalized, aligned to GovCloud architecture
• FedRAMP Moderate control implementations fully documented (how, where)
• Inherited controls clearly identified, mapped to GovCloud documentation
• Required Plans – versioned, reviewed, and approved, not in draft, and on FedRAMP templates, policies – versioned, procedures – versioned
• SIEM, centralized logging for GovCloud services systems, + app layers
• PAM accounts traceable to uniquely identified individuals
• MFA enforced for all remote + privileged access, + FIPS validated, Phishing resistant
• Firewall, WAF configs documented, tested
• External interconnections documented, pre authorized
• Internal and external vulnerability scans from the past 30 days
• Tickets mapped to POA&Ms for all findings
• Inventory of all components on the FedRAMP template
• Configuration baselines + all change management tickets documented
• IR executed and documented in the past 12 months, with full functionality testing annually
• Ticketing system in place for IR, CM, etc = full lifecycle management
• All “Not Applicable” controls justified and formally documented, per FedRAMP
• 90-day active, + 1-year total log retention, evidence

 

Common Pitfalls That Can Derail FedRAMP Projects

Navigating the FedRAMP authorization process is challenging, and organizations often underestimate the number and complexity of potential pitfalls. Understanding these common obstacles prior to your engagements can save on time, cost, and ultimately – frustration.

Federal Sponsorship Requirements

One of the first critical requirements is having a federal sponsor, as without an agency willing to sponsor your system, there is no legitimate path forward. FedRAMP mandates that a federal agency assume the risk for the CSP; otherwise, pursuing authorization is effectively a dead end. Unfortunately, this is a frequent stumbling block for companies that target federal business, yet have not established agency relationships early enough in their strategies.

Skills and Expertise Gaps

Another significant challenge is skill gaps inside the company; while general cloud or DevOps experience is valuable, it is not sufficient for FedRAMP compliance. You will need staff who understand the FedRAMP-specific controls, documentation requirements, continuous monitoring necessity, and the exhaustive evidence collection processes.

Vendor Management and Conflicts

Conflicts of interest also represent a major pitfall, where a 3PAO that provides advisory guidance can not also serve as the formal assessor. Engaging the same firm for both roles is not permitted, compromises the objectivity of the audit, and, most crucially, violates FedRAMP requirements. Organizations often overlook this requirement and attempt to consolidate vendors for convenience or cost savings, only to encounter delays and rejected submissions.

Budget and Documentation Oversights

Another major area of concern is underestimating the costs, such as those associated with FedRAMP authorized tooling, additional US-based personnel for in-scope work, and the fees for employing multiple 3PAOs. Documentation tends to be another critically overlooked area where missing evidence or incomplete policies can significantly delay FedRAMP readiness assessment. Proactively recognizing the existing barrier to entry for FedRAMP, addressing them early, and with proper planning, training, and engagement of qualified partners, can lead to a more efficient path forward to FedRAMP readiness, and ultimately, authorization.

 

FedRAMP Ready Frequently Asked Questions (FAQs)

Organizations frequently ask questions like “What are the minimum security requirements?”, “How long is the authorization process?”, or “What internal resources are needed?” Clients can also be uncertain about mapping their security controls to the NIST SP 800-53 Rev 5 requirements, preparing documentation, or even implementing continuous monitoring strategies once authorized. Let’s drill down on some of the more common questions we get from clients about whether they’re actually ready to embark upon a FedRAMP authorization endeavor.

What Does It Mean to Be FedRAMP “Ready”?

Being FedRAMP Ready indicates that a Cloud Service Provider (CSP) has completed an initial assessment with a Third Party Assessment Organization (3PAO) and demonstrated that it is prepared to pursue a full FedRAMP authorization. It is a pre-assessment status showing that the CSP has implemented key security controls, has appropriate documentation, and is on track for a formal security assessment. FedRAMP Ready does not mean the system is fully authorized to operate; it simply signals there is a status of “readiness” for the full audit process.

How Do You Get FedRAMP “Ready” Status?

To achieve FedRAMP “Ready”, a CSP must:

• Engage a 3PAO to perform an initial readiness assessment of the system’s security controls.
• Complete and submit the required documentation, including the System Security Plan (SSP) and all required artifacts.
• Implement the baseline security controls for the appropriate impact level (Low, Moderate, or High).
• Demonstrate a clear track record of security compliance, including vulnerability lifecycle management, extensive logging, and full incident response processes.

Once a 3PAO verifies readiness, the FedRAMP PMO publishes the CSP’s “Ready” status on the FedRAMP Marketplace, which helps agencies identify CSP offerings that are actually prepared for a full authorization.

What Does FedRAMP “Approved” Mean?

FedRAMP Approved (“Authorized”) means a CSP has successfully completed a full security assessment by a 3PAO, and the system has been officially authorized to operate (ATO) by a federal agency. At this stage, the system now meets all required FedRAMP security controls for its designated impact level, and federal agencies can confidently use the CSP’s offering in production.

How Do You Prepare for FedRAMP?

• Gap analysis is performed, where the current security controls are assessed against the FedRAMP requirements.
• Documentation is prepared for the System Security Plan (SSP), to include policies, procedures, and tangible evidence of controls.
• Security tooling is fully implemented, and FedRAMP aligned – SIEM, ticketing system, vulnerability management scanning, and lifecycles.
• Personnel must all be US citizens performing any in-boundary, and adjacent FedRAMP work.
• Advisory support where a 3PAO is engaged in an advisory role to assist and guide readiness.
• Training and processes for staff to understand and embrace FedRAMP requirements, reporting obligations, and continuous monitoring (ConMon) practices.

FedRAMP preparation is actively aligning people, processes, and technology to meet the rigorous federal security standards prior to undergoing the formal assessment process to become FedRAMP Authorized.

Final Takeaway: FedRAMP Readiness Is Much More Than Just Documentation

At Linford & Co., we advise our clients that FedRAMP readiness is not just about paperwork. It’s about organizational maturity, operational discipline, and strategic alignment to federal risk frameworks.

If you’re not sure whether you’re really FedRAMP ready, reach out!  We can help you assess your current posture, identify gaps, and build a roadmap that sets you up for success, not surprises.

If you’re preparing for FedRAMP Moderate, planning your sponsorship engagement, or just trying to understand your total cost and effort, our team is here to help! Contact us today to start the conversation!