Got FedRAMP? CSPs may need it for CMMC

The United States Department of Defense (DoD) has introduced the Cybersecurity Maturity Model Certification (CMMC), marking a pivotal change in cybersecurity standards for defense contractors. Starting this year, CMMC will become a contract requirement for hundreds of contractors, and over the next seven years, it is expected to affect more than 180,000 members of the defense industrial base. In the making for over 5 years, this initiative is set to become one of the largest cybersecurity authorization and accreditation programs in the world. 

The Growing Importance of FedRAMP

Over the past decade, the Federal Risk and Authorization Management Program (FedRAMP) has become a cornerstone for cloud service providers (CSPs) aiming to offer their services to federal agencies. With over 350 cloud service offerings assessed annually and significant costs associated with maintaining FedRAMP authorization, the program has proven to be both rigorous and essential for ensuring secure cloud services.

CMMC and Its Implications for Defense Contractors

The CMMC framework introduces three levels of certification, with Levels 2 and 3 requiring independent assessments.  Level 2 is the minimum level for handling controlled unclassified information (CUI). According to the DoD, this means that over 75,000 defense contractors must demonstrate robust cybersecurity practices, in accordance with NIST 800-171 standards, to meet CMMC. However, achieving CMMC compliance is not just about internal processes; it also involves ensuring that any cloud services used are secure and compliant.  That is where FedRAMP comes in.

Why FedRAMP Matters for CMMC Compliance

For cloud service providers, achieving FedRAMP Moderate equivalency allows them to support defense contractors who are required to meet CMMC compliance across their supply chain. This not only helps CSPs maintain existing contracts but also positions them to win new business with DoD contractors and other organizations in the defense industry that rely on FedRAMP standards to demonstrate their cybersecurity posture.

Defense contractors can significantly streamline the process of achieving CMMC compliance by using cloud services that are either FedRAMP-authorized or meet FedRAMP equivalency at the moderate impact level or higher. Here’s why:

1. Mandatory Requirement for CUI: Defense contractors must use cloud services that meet FedRAMP Moderate equivalency if those cloud services are going to process, store, or transmit controlled unclassified information (CUI). This ensures that sensitive information is handled within a secure and compliant cloud environment. This requirement has been in force since 2017, but it is just now falling into the scope for independent CMMC audits.  
2. Proven Security Standards: Validated FedRAMP compliance ensures that a CSP has met stringent security standards. This provides defense contractors and the DoD confidence that their data is protected according to federal guidelines.
3. Simplified Compliance: By using FedRAMP Moderate compliant services, defense contractors can more easily demonstrate compliance with CMMC requirements. This is because FedRAMP’s rigorous assessment process aligns closely with the security controls required by CMMC.
4. Cost Efficiency: While the initial investment in achieving FedRAMP authorization can be high, it can ultimately save defense contractors money. By leveraging FedRAMP-authorized services, contractors can avoid the costs and complexities of conducting separate security assessments for their cloud services.
5. Market Advantage: Cloud service providers that achieve FedRAMP authorization can differentiate themselves in the market. As defense contractors seek to meet CMMC requirements, they will likely prefer CSPs that already have FedRAMP authorization, providing a competitive edge.

The Path Forward for Cloud Service Providers

Given the DoD’s ambitious plans for CMMC, cloud service providers have a unique opportunity to support defense contractors in their compliance journey. By achieving FedRAMP authorization, CSPs can position themselves as trusted partners in the defense sector, helping contractors navigate the complexities of CMMC and ensuring the security of sensitive information.

If a CSP cannot get formally FedRAMP authorized because they do not sell directly to the federal government, they can still demonstrate FedRAMP Moderate equivalency for CMMC Level 2 by implementing the required FedRAMP moderate controls, undergoing an assessment conducted by a 3PAO, and providing documentation to support their security posture. This approach enables CSPs to work with DoD contractors while ensuring they meet CMMC compliance expectations. 

The intersection of FedRAMP and CMMC represents a critical juncture for cloud service providers and defense contractors alike. By meeting FedRAMP requirements, CSPs can play a pivotal role in helping their customers achieve CMMC compliance, ultimately contributing to a more secure and resilient defense industrial base.  

Explore Coalfire's CMMC services at https://coalfire.com/services/assessment/cmmc-compliance-services.