FedRAMP Moderate Equivalency Assessments for CSPs

FedRAMP

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FedRAMP Moderate Equivalency Assessments for CSPs

With CMMC requirements now finalized, Cloud Service Providers (CSPs) must prepare to meet emerging compliance standards for protecting Controlled Unclassified Information (CUI). Whether through FedRAMP Authorization or FedRAMP Moderate Equivalency, CSPs must provide a Body of Evidence (BOE) to contractors for JSVA or DIBCAC High assessments.

What is FedRAMP Moderate Equivalency?

FedRAMP Moderate Equivalency is an alternative pathway for CSPs whose business goals may not align with achieving full FedRAMP Authorization. Defined in the DoD Memo titled “Federal Risk and Authorization Management Program Moderate Equivalency for Cloud Service Provider’s Cloud Service Offerings” (December 2023), this approach requires CSPs to meet all NIST 800-53 Rev. 5 controls without exceptions or POA&Ms by the end of the assessment.

Key Considerations for CSPs:

  • High Standards: FedRAMP Moderate Equivalency demands that all controls are fully implemented and confirmed by a FedRAMP 3PAO, with no POA&Ms allowed.
  • Assessment Pathways: CSPs must evaluate whether to pursue FedRAMP Authorization or FedRAMP Moderate Equivalency, considering the lighter workload of FedRAMP Authorization versus the involvement of DIBCAC instead of the PMO for equivalency assessments.
  • Continuous Monitoring: Following equivalency, CSPs must maintain rigorous monitoring activities, including monthly meetings with DIBCAC and periodic updates to the BOE.

 

How Sentar Can Help

Sentar is an accredited FedRAMP Third-Party Assessment Organization (3PAO) with extensive experience conducting assessments aligned with FedRAMP Moderate Equivalency requirements. Our team follows the FedRAMP-established assessment methodology to ensure compliance with the DoD’s expectations while providing proactive support to maximize your success.

Why Choose Sentar for FedRAMP Moderate Equivalency?

  • Proactive Disclosure: Sentar assessors disclose findings as soon as they are detected, allowing CSPs additional time for POA&M remediation before the assessment ends.
  • Tailored Support: We work closely with CSPs to ensure readiness, avoid pitfalls, and minimize unnecessary costs.
  • Proven Methodology: Our assessments focus on potential CUI data flow and align with NIST 800-53 Rev. 5 controls, ensuring compliance with the DoD Memo.

FedRAMP Moderate Equivalency FAQ

What is the timeline for FedRAMP Moderate Equivalency?

The timeline depends on your CSP’s level of preparation before engaging a 3PAO. During the initial project kick-off, Sentar will determine whether your CSP is ready to proceed with the assessment. If not, we’ll set a target date for readiness, ensuring all preliminary requirements (e.g., SSP documentation) are met. Once ready, assessments typically take 4–6 months, depending on your CSP’s bandwidth to remediate findings and meet documentation requirements.

Who governs FedRAMP Moderate Equivalency assessments?

Assessments are governed by DIBCAC. Unlike FedRAMP Authorization, where the assessment package is submitted to the FedRAMP PMO, equivalency assessments are reviewed and confirmed by DIBCAC.

What are the post-equivalency requirements?

Following equivalency, CSPs must:

  • Conduct Continuous Monitoring activities (as specified by CA-7), including monthly meetings with DIBCAC to review POA&Ms, vulnerability scans, and other evidence.
  • Provide DIBCAC with an updated Body of Evidence (BOE) periodically (at least annually) to support clients pursuing JSVA or DIBCAC High assessments.

Why Sentar?

Sentar is a trusted partner for FedRAMP Moderate Equivalency, offering:

  • Accredited Expertise: As a FedRAMP 3PAO, we deliver high-quality assessments aligned with DoD requirements.
  • Proven Methodologies: Rigorous processes to ensure compliance with NIST 800-53 Rev. 5 controls.
  • Proactive Support: Dedicated assessors who work closely with CSPs to maximize success and minimize costs.

Get Started Today!

Don’t let compliance challenges delay your progress. Take the next step toward achieving FedRAMP Moderate Equivalency with Sentar.

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