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FedRAMP authorization is a mandatory procurement gate — no ATO, no federal contracts
FedRAMP Moderate Compliance Consulting

FedRAMP Moderate: The mandatory path to handling government data.

FedRAMP Moderate is the required security authorization for cloud service providers and federal agencies handling sensitive but unclassified federal data. Whether you're seeking a JAB P-ATO or an Agency ATO, we help you build the SSP, close the controls, and navigate the SA&A process — from gap assessment to authorization.

Check Your Security Posture → FedRAMP Engagement
Authorization scope
FedRAMP Moderate NIST SP 800-53 SSP Development SA&A Workflow JAB P-ATO Agency ATO
The framework

FedRAMP is the mandatory security authorization for any CSP handling federal data.

FedRAMP (Federal Risk and Authorization Management Program) was established in 2011 to provide a standardized approach to security assessment, authorization, and continuous monitoring for cloud services used by the federal government. The program is administered by the FedRAMP Program Management Office (PMO) within the General Services Administration (GSA). Without a FedRAMP authorization, a cloud service provider cannot offer its services to any federal agency — regardless of contract value or relationship.

Low
Low Baseline
~90 controls · Self-assessment or 3PAO
Appropriate for cloud services handling publicly available federal information where the loss of confidentiality, integrity, or availability would have limited impact. Rarely used for commercial CSPs — primarily for internal government systems.
NIST SP 800-53 Low baseline
Self-assessment or 3PAO for higher assurance
Annual assessment and recertification
Continuous monitoring requirements
Moderate
Moderate Baseline
~300 controls · 3PAO required · JAB P-ATO or Agency ATO
The most common authorization level for commercial CSPs. Required for systems where the loss of confidentiality, integrity, or availability could have serious adverse effects on organizational operations, assets, or individuals. Covers PII, financial records, health information, and other sensitive federal data.
NIST SP 800-53 Moderate baseline
Third Party Assessor Organization (3PAO) required
JAB P-ATO or Agency ATO pathway
Ongoing continuous monitoring
High
High Baseline
~335 controls · 3PAO government-led · JAB P-ATO required
Required for cloud services where the loss of confidentiality, integrity, or availability could have severe or catastrophic effects on organizational operations, assets, or individuals. Typically for national security systems, law enforcement, or financial systems handling highly sensitive data.
NIST SP 800-53 High baseline
3PAO assessment with government oversight
JAB P-ATO required for multi-agency deployment
Strict continuous monitoring and incident response
Authorization pathways

Moderate vs High — which baseline does your system need?

The choice between FedRAMP Moderate and High depends on the sensitivity of the federal data your cloud service will process, store, or transmit. Most commercial CSPs start with Moderate. The distinction matters because High adds approximately 35 additional controls, requires a government-led 3PAO assessment, and imposes more stringent continuous monitoring obligations. Getting the baseline wrong in either direction — over-engineering or under-engineering — creates cost and risk.

Dimension FedRAMP Moderate FedRAMP High
NIST SP 800-53 Controls ~300 controls (Moderate baseline) ~335 controls (High baseline)
Assessment Type 3PAO assessment (Commercial or Government) 3PAO assessment with government oversight / DIBCAC
Authorization Pathway JAB P-ATO or Agency ATO JAB P-ATO required for multi-agency use
Typical Data Types PII, financial records, health information, operational data National security systems, law enforcement data, highly sensitive federal records
Typical Customers Civilian agencies (GSA, HHS, DoE, DHS), commercial CSPs DoD, intelligence community, law enforcement, national security
PTR / ATR Process Pre-assessment w/ 3PAO, then formal assessment package review More rigorous threat assessment, additional POA&M constraints
Continuous Monitoring Monthly vulnerability scans, annual assessment More frequent scanning, real-time monitoring, stricter incident thresholds
NIST CSF & FedRAMP

Your NIST CSF program is the foundation for FedRAMP Moderate.

FedRAMP authorization maps to NIST SP 800-53 controls — but NIST CSF provides the organizational context and risk management framework that makes the SSP defensible. Organizations with mature NIST CSF policies cover substantial portions of the FedRAMP Moderate control family. A NIST CSF gap assessment reveals exactly where your existing policies satisfy FedRAMP requirements and where additional evidence or implementation is needed. Here's how NIST CSF functions map to FedRAMP Moderate control coverage.

NIST CSF Function Scope FedRAMP Moderate Control Families Est. NIST CSF Overlap
GV — Govern Organizational context, risk management, supply chain Risk Management (RM), Supply Chain Risk Management (SCRM), Security Assessment (CA)
~55%
ID — Identify Asset management, risk assessment, improvement planning Asset Management (AM), Configuration Management (CM), Identification & Authentication (IA)
~65%
PR — Protect Access control, awareness, data security Access Control (AC), Media Protection (MP), Physical Protection (PE), Awareness & Training (AT)
~75%
DE — Detect Continuous monitoring, anomaly detection Audit & Accountability (AU), System & Communications Protection (SC), Monitoring (MO)
~60%
RS — Respond Incident management, analysis, mitigation Incident Response (IR), Contingency Planning (CP), Communications (COM)
~60%
RC — Recover Recovery planning, improvements Contingency Planning (CP), System Recovery (RE), Planning (PL)
~50%

What this means for you: If your organization has already invested in NIST CSF policies, you have a significant head start on FedRAMP Moderate. A NIST CSF gap assessment identifies which controls your existing documentation and implementation satisfy, saving weeks of redundant documentation work before your 3PAO assessment. See the NIST Policy Package →

How we work

From scoping to ATO. No black boxes.

The FedRAMP authorization process follows a structured sequence from initial scoping to final ATO. We start by determining the appropriate baseline (Moderate or High) and the best authorization pathway (JAB P-ATO vs. Agency ATO), then build your SSP and evidence package through to a successful 3PAO assessment and authorization. The timeline depends on your current control posture and evidence readiness.

01
Phase 1 · Week 1–2
FedRAMP Scoping & Authorization Pathway Selection

Determine the appropriate FedRAMP baseline (Moderate vs. High) based on the data types your system will handle and the federal agencies you plan to serve. Select the authorization pathway — JAB P-ATO for multi-agency deployment or Agency ATO for a specific agency's needs. Scope the assessment boundary: which systems, facilities, and data flows are in scope. The scoping decision determines the control surface and the evidence burden — over-scoped means wasted effort; under-scoped creates uncovered risk before assessment.

02
Phase 2 · Week 2–6
SSP Development & Control Gap Analysis

Develop the System Security Plan (SSP) documenting all in-scope controls, their implementation status, and the evidence artifacts that support each control. Conduct a systematic gap analysis against the target FedRAMP baseline — for Moderate, the ~300 NIST SP 800-53 Moderate controls. Each control is marked Implemented, Partially Implemented, Not Implemented, or Not Applicable with supporting evidence citations. You receive a prioritized gap register with remediation effort estimates.

03
Phase 3 · Week 6–20
Remediation & Evidence Package Assembly

Execute technical remediation for all gaps identified in Phase 2. Develop or update policies, procedures, and technical controls across all control families. For organizations with existing NIST policies and technical controls, this phase is substantially faster. Assemble the complete evidence package: policy documents, system architecture diagrams, configuration baselines, access logs, incident response records, and continuous monitoring output — organized for 3PAO review and AO assessment.

04
Phase 4 · Final
3PAO Assessment & ATO Issuance

Engage your selected 3PAO for the formal security assessment. For Moderate: a commercial 3PAO conducts the assessment and issues an assessment report. For High: the 3PAO works with government oversight for the assessment. Submit the completed security assessment package to the FedRAMP PMO (for JAB pathway) or to your Agency AO. Address any POA&Ms or findings from the 3PAO. Receive your ATO and enter the continuous monitoring phase — monthly vulnerability scans, annual assessments, and incident reporting per FedRAMP requirements.

Don't let a control gap delay your ATO.

Start with a free security posture check. Understand your FedRAMP baseline requirements and current gaps before your next contract opportunity.

Check Your Security Posture → FedRAMP Engagement
Frequently asked

Common FedRAMP questions.

What is FedRAMP and who is required to obtain authorization? +
FedRAMP (Federal Risk and Authorization Management Program) is a mandatory security authorization program for cloud service providers (CSPs) and federal agencies that handle data for the U.S. government. Any CSP offering a cloud service that processes, stores, or transmits federal data must obtain a FedRAMP authorization before deployment on government systems. Federal agencies using commercial cloud services are also required to use FedRAMP-authorized providers. The program is administered by the FedRAMP Program Management Office (PMO) within the General Services Administration (GSA).
What is the difference between FedRAMP Moderate and High baselines? +
FedRAMP Moderate is the most common authorization level, required for CSPs handling sensitive but unclassified federal data — including personally identifiable information (PII), financial records, and health information. High adds approximately 35 additional controls from NIST SP 800-53 and is required for systems where the loss of confidentiality, integrity, or availability could have a severe or catastrophic effect on organizational operations, assets, or individuals. The choice between Moderate and High depends on the data types your system handles and the impact of a potential breach on government operations.
What is an Authority to Operate (ATO) and how is it obtained? +
An Authority to Operate (ATO) is the official management decision approving a federal information system to operate at an acceptable level of risk. For FedRAMP, the ATO is granted by the Authorizing Official (AO) — typically a senior federal official — after reviewing the security assessment package and supporting evidence. The ATO process involves developing a System Security Plan (SSP), conducting a security assessment (either via a Third Party Assessor Organization (3PAO) for Moderate/High or self-assessment for Low), submitting the package to the FedRAMP PMO, and receiving AO approval. Once granted, the ATO is documented in the FedRAMP Marketplace and the CSP can offer services to federal agencies.
What is the difference between a JAB P-ATO and an Agency ATO? +
A JAB (Joint Authorization Board) Provisional ATO (P-ATO) is issued by the FedRAMP Joint Authorization Board — composed of the Department of Defense, the Department of Homeland Security, and the General Services Administration — and is accepted by all federal agencies, eliminating the need for each agency to conduct its own authorization. An Agency ATO is issued directly by an individual federal agency's Authorizing Official after their own review. JAB P-ATO is generally preferred for commercial CSPs seeking to serve multiple agencies, as it provides authorization recognition across the entire federal government. Agency authorizations are more common for custom or niche systems built for a specific agency's needs.
How does NIST CSF relate to FedRAMP authorization? +
NIST CSF (Cybersecurity Framework) provides a voluntary risk-based framework that maps well to FedRAMP requirements, but it is not itself a FedRAMP authorization pathway. FedRAMP authorization requires compliance with NIST SP 800-53 security controls at the Moderate or High baseline. That said, a mature NIST CSF program substantially covers the control families required in FedRAMP — particularly in the areas of Risk Management (Govern), Asset Management (Identify), Access Control (Protect), and Incident Response (Respond). Organizations with existing NIST CSF policies are well positioned to accelerate their FedRAMP SSP development and security assessment.