Why the System Security Plan (SSP) is Critical for FedRAMP Compliance

FedRAMP (Federal Risk Authorization Management Program) is a US government-wide approach to the security assessment, authorization and monitoring for cloud service providers (CSPs). CSPs are organizations that provide infrastructure, network, or business services on the cloud.

Some of the popular CSPs (or their products) include Microsoft Azure, Google Cloud Platform, AWS (Amazon Web Services), VMware, and Red Hat. In order to provide their services to the US government, CSPs must be FedRAMP compliant, following a standardized process including the creation of the System Security Plan (SSP).

What Is FedRAMP's SSP Report?

The SSP report is the first report in the list of required materials for the FedRAMP Security Package. The SSP report is one of the most detailed reports and describes the security controls a CSP has implemented. For each control, the plan must show:

• Documents, processes, devices, or any other deployed solutions.

• The responsibilities assigned to government customer and CSPs pertaining to the SSP implementation.

• Dates and times of implementation.

• How and why the solution addresses various controls.

In the initial “Preparation” phase, compiling the SSP means pulling together a wealth of internal information and documentation.

What Is Included in a FedRAMP SSP Compliance Checklist?

A robust FedRAMP System Security Plan (SSP) forms the backbone of a successful compliance journey. At its core, it's a comprehensive blueprint detailing your organization's approach to federal information security standards—no stone left unturned. So, what exactly needs to make the cut for a FedRAMP SSP compliance checklist?

Here's what every cloud service provider should prepare:

• Completed SSP Template: FedRAMP provides standardized templates tailored to each impact level—Low, Moderate, and High. These guide you in documenting required security controls in depth.

• Documented Security Controls: For each relevant control, outline the technical solutions in place (devices, policies, processes), who owns them—the CSP or government customer—and describe how, when, and why each was implemented.

• Evidence of Implementation: Attach or reference supporting documentation, such as diagrams, inventories, and system boundaries, to substantiate your claims.

• Roles and Responsibilities: Clearly map out organizational responsibilities supporting the controls—distinguishing federal agency tasks from those managed by your team.

• Assessment Materials: Be ready to present third-party assessments (often conducted by a 3PAO) validating your security implementations.

• Planned vs. Implemented Controls: Not all controls may be fully implemented at submission, but there must be explicit plans and timelines for any pending items.

• Inventory of Connections: Detail every network connection, data flow, device, and service interface in use—think of it as drawing a map for a visitor unfamiliar with your neighborhood.

• Authorization Boundaries: Define the limits—both technical and physical—of your cloud service's environment. This helps agencies understand where the FedRAMP boundary begins and ends.

• Contingency and Incident Response Plans: Explain how you'll handle things if (when) something goes awry, with clear strategies mapped for continuity and damage control.

By gathering each of these elements up front, you'll ensure your SSP meets the expectation of federal reviewers—and avoid unpleasant surprises midway through the compliance marathon.

Is It Hard to Create the SSP Report?

The System Security Plan has been a tough nut to crack right from the onset. According to a 2013 study, out of the 80 cloud providers that attempted to earn a FedRAMP certification, half of them were not prepared for the compliance process. Even today, CSP's struggle with the SSP report's comprehensiveness: the baseline template is over 350 pages requiring detailed descriptions for each of the provider's controls.

FedRAMP was designed so that once a CSP is compliant and listed on the FedRAMP Marketplace, Agencies can simply review the existing authorization package and grant an ATO (Agency Authority to operate) for their organization to use the service, instead of repeating the compliance process.

FedRAMP Impact Levels and Their Role in Authorization

Not all cloud service offerings (CSOs) are created equal in the eyes of FedRAMP. The standard recognizes that the potential consequences of a security incident can vary widely depending on what type of data or service is involved. To address this, FedRAMP uses three distinct Impact Levels—Low, Moderate, and High—to classify the sensitivity of data and the potential harm if that data were compromised.

Here's a quick breakdown:

• Low Impact Level: This category covers systems handling information that, if breached, would cause only minimal disruption or limited adverse effects to government operations or individuals. Think of public-facing or non-sensitive data, losing it would be inconvenient but not disastrous.

• Moderate Impact Level: The most common level for government cloud services, covering about 80% of FedRAMP-certified CSOs. Moderate-level systems contain data where loss of confidentiality, integrity, or availability could have more serious consequences. A security event here might significantly impact an agency’s operations or financial standing.

• High Impact Level: Reserved for the most sensitive government systems like those used by healthcare, law enforcement, or emergency services. Here, a data breach or system failure could have severe or even catastrophic effects, impacting human life, national security, or critical infrastructure.

The impact level assigned determines the rigor and complexity of the security controls required in your System Security Plan. As the stakes rise from Low to High, so too do the security expectations and scrutiny your cloud service must be prepared to withstand.

Two Paths to FedRAMP Authorization

When it comes to earning FedRAMP authorization, organizations must choose between two main pathways—each with its own set of steps and considerations.

• Agency Authorization:
  In this approach, a cloud service provider partners with a specific federal agency that intends to use their service. The agency sponsors the provider throughout the authorization process, guiding them through pre-authorization activities and ultimately issuing an Authority to Operate (ATO) if all security requirements are met. This route is often a good fit for CSPs with a strong relationship or contract with a particular agency.

• Joint Authorization Board (JAB) Authorization:
  The Joint Authorization Board—comprising representatives from the Department of Homeland Security, General Services Administration, and Department of Defense—offers an alternative path. Here, the CSP seeks a Provisional ATO (P-ATO) via a more rigorous review conducted by the JAB. Achieving authorization through this board signals a high level of confidence in the provider’s security posture, opening doors to a broader pool of federal customers.

No matter which route is chosen, the initial steps—including the development of the comprehensive System Security Plan—can appear overwhelming. However, understanding the difference between these two options helps CSPs select the most strategic path forward.

What Roles and Expertise Are Needed on an SSP Implementation Team?

Bringing together the right team is crucial for navigating the SSP process successfully. Composing an effective SSP implementation team isn’t just about filling seats; it’s about securing a blend of skills that can cover the full spectrum of FedRAMP requirements.

Generally, your core team should include:

• Cloud Security Specialists: Experts with a deep understanding of cloud platforms such as AWS, Microsoft Azure, or Google Cloud Platform, who are well-versed in implementing robust security controls.

• Network Architects: Professionals capable of designing, visualizing, and documenting complex cloud and hybrid network environments, ensuring everything aligns with FedRAMP standards.

• Compliance Analysts: Individuals familiar with federal regulations who can map technical security controls to FedRAMP mandates and document evidence for each one.

• Project Managers: People who can coordinate input from different departments, keep the project moving forward, and manage timelines because without someone steering the ship, things can drift quickly.

• Technical Writers or Documentation Specialists: Skilled communicators who can translate intricate technical details into clear, comprehensive SSP documentation that passes muster with auditors.

In some cases, you may also need to bring in consultants or temporary experts to fill in specialized gaps, particularly if there’s a need for advanced diagramming or nuanced knowledge of specific compliance requirements. The goal is to form an interdisciplinary team that not only understands the technology but can also explain it clearly and thoroughly to achieve FedRAMP compliance.

What Are Benefits of the SSP Report?

Creating the SSP report does not only help you with the sale of cloud products and services in the federal landscape, but it also builds your credibility and authenticity in the industry as a company that follows strict regulations when it comes to cloud security. Here is why the FedRAMP SSP report is crucial for CSPs:

Proves Credibility

The FedRAMP SSP report is incredibly thorough, and the evaluation is extensive. A 4 step process: it begins with the creation and review of the CSP's System Security Plan, followed by the development and assessment of the Security Assessment Plan (SAP). Next is the Authorization process where the Security Assessment Report (SAR) is evaluated and tested by the CSP's Agency partner who would grant them an ATO (agency authority to operate). Finally, the FedRAMP PMO would present the CSP with FedRAMP authorization. Completing such a meticulous process assures government agencies your offerings are secure and compliant to FedRAMPs stringent requirements.

Click here for a full breakdown of the authorization process

Employ Cutting Edge Technology

FedRAMP requirements on using relevant technology are stringent to say the least. The goal here is to remove out of date, unsupported and potential insecure hardware. Updating hardware has many other positives including increased security visibility, productivity and enhanced system integrations.

Provides Visibility

In creating such a comprehensive document, the SSP report yields an overview of your controls and can expose previously unknown vulnerabilities. Highlighting the strengths and weaknesses, the SSP report provides CSP's with visibility into their security program, so companies immediately know where they need to improve in order to be FedRAMP compliant.

Improves Communication

Having a documented incident management and communication plan is an important part of FedRAMP and required to be documented in the SSP reports. During a security incident, a loss of even a minute can be extremely dangerous. Having the right information reach the right team, at the right time, can make all the difference when making critical decisions.

Managing Ongoing Compliance & Remediation Efforts

Achieving FedRAMP authorization is a major accomplishment, but it’s only the beginning. Maintaining compliance is a continuous journey. One that demands regular monitoring and swift action on any gaps identified along the way.

To streamline this process, cloud service providers should adopt automated solutions that help monitor compliance status in real-time. Tools from vendors like StandardFusion make it much easier to perform ongoing security assessments, track remediation activities, and keep a living inventory of assets and controls. By consolidating these tasks in one platform, you reduce the risk of missed updates or manual errors.

Key best practices for continuous authorization include:

• Scheduled Compliance Checks: Automate routine assessments to catch emerging vulnerabilities and newly non-compliant controls before they become issues.

• Integrated Asset Management: Keep all system components and documentation up to date, so nothing slips through the cracks.

• Automated Alerts and Workflows: Ensure that the right team members are immediately notified of incidents or control failures, enabling swift remediation.

• Centralized Documentation: Store audit trails, incident management plans, and evidence in one secure location for easy access during reassessments or audits.

Ultimately, leveraging automation not only saves time but provides greater peace of mind that your cloud environment remains secure and continuously FedRAMP compliant.

Can Companies Automate the Process?

SSP documentation is time-consuming. Manually creating the SSP report is inefficient at best. Instead, we suggest leveraging technology and automating as much of the report creation process as possible. Keep in mind that there is a lot of copy/pasting and editing in SSP, so an automated tool can turn out to be highly productive. GRC software solutions, like StandardFusion, are on the forefront of this type of automation. Which makes sense as they already allow you to document and manage your security controls and processes. Being able to generate reports such as the SSP is the logical next step. Automate the planning, reporting, and execution of activities related to cloud assessment, all in one platform.

Furthermore, the FedRAMP PMO (Program Management Office) plans to release tooling to reduce expenses and enhance the quality of a security review. GRC tools are poised to benefit from this again as the next wave of automation opportunities appear.

In an emerging marketplace there is a big push for GRC tools to include automation and the SSP report is just the beginning.