Leveraging CISA's Software Acquisition Guide to Excel in FedRAMP Compliance

On August 1, 2024 the Cybersecurity & Infrastructure Security Agency (CISA) released the Software Acquisition Guide for Government Enterprise Consumers: Software Assurance in the Cyber-Supply Chain Risk Management (C-SCRM) Lifecycle. On top of CISA creating another acronym you’ll need to learn, they provided a playbook that Cloud Service Providers can use to build a rock solid Secure Software Development Lifecycle (SSDLC) program for their organization. Let’s get into how this guide impacts you.

Intro

We all know getting into the federal marketplace can be challenging, but the Federal Risk and Authorization Management Program (FedRAMP) leverages the cloud which opens opportunities for software developers previously not available to them. The federal government wants to use a product that increases their agility and enhances their mission capabilities, but they want that product to be secure, so they need you to give them a warm fuzzy that it is.

Securing a FedRAMP authorization is a critical milestone for Cloud Service Providers (CSPs) entering the federal marketplace. The CISA Software Acquisition Guide offers a robust framework for implementing SSDLC practices, aligning with federal expectations, and enhancing overall security maturity. By adopting the guide’s principles, CSPs can streamline compliance, reduce risks, and gain a competitive edge.

What’s the Guide Saying?

The guide emphasizes “Secure by Design,” “Secure by Default,” and “Secure by Demand” principles, integrating security into every phase of software development. It outlines controls across governance, supply chain, development, and deployment, aligning with FedRAMP’s NIST 800-53 standards, Executive Order 14028, and NIST SP 800-161. The guide is directed at government agencies to use when evaluating CSP’s cloud service offering (CSO) for purchase. While CSPs are not directed to implement the frameworks in the guide, it provides a roadmap for the future of software acquisition requirements for the federal government. So why not use the federal government’s playbook on how they’re going to evaluate a CSO for purchase and build a framework to support it?

How About Some Things to Consider?

Change can be scary, change can be costly, but sometimes change is good. If you’re selling to the federal government, security is the name of the game. Your product might be doing some great things but if it’s not secure the government will go shopping elsewhere. Why should you adopt a SSDLC and specifically a framework from the CISA Software Acquisition Guide for Government Enterprise Consumers? 

Perks for Adoption

• Confidence and Trust: Demonstrate product security to federal customers
• Framework Alignment: Meet multiple federal audit requirements, including FedRAMP and NIST standards
• Enhanced Third-Party Oversight: Gain control over third-party software components
• Support for Federal Audits: Simplify attestation processes with pre-built controls
• Cost Savings: Reduce future risks, including breaches and legal challenges

Challenges

• Implementation Complexity: Integrating SSDLC organization-wide is resource-intensive
• Increased Burden: Creating new policies and artifacts can strain existing resources
• Third-Party Dependencies: Ensuring supplier compliance adds another layer of complexity
• Unforeseen Costs: Overhead for additional work hours and compliance efforts can grow

Creating Opportunities

• Enhanced Reputation: Aligning with the guide builds trust with federal agencies
• Competitive Edge: Positioning as an industry leader in secure development practices
• Improved Risk Management: Strengthened awareness and mitigation of product threats
• Future Cost Savings: Proactive security investments reduce incidents and compliance hurdles

What if I say, “This isn’t important for me or my product?”

• Delayed or Cancelled Contracts: Failure to meet security requirements can result in missed opportunities
• Reduced Buyer Interest: Lack of SSDLC processes may disqualify products from purchase
• Increased Breaches and Incidents: Non-compliance raises vulnerability to exploitation
• Damaged Reputation: A poor security record erodes trust and market standing

Wrap-up

Adopting the practices in the CISA Software Acquisition Guide is a strategic move for CSPs targeting FedRAMP compliance. While initial implementation may present challenges, the long-term benefits—enhanced security, compliance readiness, cost savings, and improved reputation—outweigh the efforts. By embedding security into every stage of software development, CSPs position themselves as trusted partners in the federal marketplace, ready to meet evolving cybersecurity demands. An added perk is that leveraging this guide will aid in meeting compliance across multiple NIST 800-53 control families and significantly helps with the new Supply Chain Risk Management (SR) control family introduced in Revision 5.

Utilizing some of the strategies outlined in this guide go further than just getting into the FedRAMP marketplace.  It can benefit the organization as a whole because industry wants secure products. If you decide to start working with finance, healthcare, logistics, etc. they’ll be happy to know you’re bringing a secure product to the table and have the processes in place to prove it. Security is everyone’s job, so apply it to your foundation and you’ll have a stronger product in the end.