Compliance

A survey of FedRAMP’s new supply chain requirements

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Adam Smith

Senior Director, Commercial Services, Coalfire

Blog Images 2022 Fed RAMP Survey tile

Over the past few years, supply chain management has shifted from a background requirement that everyone unknowingly relies upon, to being a commonly talked about aspect of our everyday lives. The Federal government has ramped up its effort to gain a handle on supply chain threats as a result of many recent compromises to government information systems and critical infrastructure.

Key takeaways:

  • Supply chain management is not brand new. It has existed for a while now within Defense Federal Acquisition Regulation Supplement (DFARS) Part 252 and SA-12, first existing in NIST 800-53 revision 3 for systems with a High FIPS-199 categorization.
  • FedRAMP’s focus in 2022 on supply chain requirements have significantly increased through the publication of the new supply chain risk management (SR) control family in NIST 800-53 revision 5.
  • CSPs adhering to the FedRAMP standard will need to itemize their Cloud Service Offering (CSO) vendors and develop a risk management plan for supply chains.
  • Vendors will need to be reviewed for NIST 800-171 compliance by the CSP on an annual basis.
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Over the past few years, supply chain management has shifted from a background requirement that everyone unknowingly relies upon, to being a commonly talked about aspect of our everyday lives. The Federal government has ramped up its effort to gain a handle on supply chain threats as a result of many recent compromises to government information systems and critical infrastructure. Through the presidential executive order on improving the nation’s cybersecurity (May 2021)<\/a> and the earlier finalized publication of NIST 800-53 revision 5 (September 2020)<\/a>, it will come as no surprise that FedRAMP will place a special emphasis on this domain once the FedRAMP 800-53 revision 5 baselines are finalized later this year.<\/p>\r\n\r\n

This isn’t the first time supply chain security has come under scrutiny from regulators. DoD has been evaluating their supply chain using