J.14_Attachment_14.docx

FEDRAMP MODERATE READINESS ASSESSMENT REPORT (RAR)

This FedRAMP Readiness Assessment Report (RAR) template is intended for systems categorized at the Moderate security impact level, in accordance with the Federal Information Processing Standards (FIPS) Publication 199 security categorization. A RAR template for High systems is available on the FedRAMP web site. FedRAMP Ready status is valid for one calendar year after designation from the FedRAMP PMO.

Third Party Assessment Organization (3PAO) Attestation An Accredited 3PAO must attest to the readiness of the Cloud Service Provider’s (CSP) system. To be considered FedRAMP-Ready, the CSP must meet all the requirements in Section 4.1, Federal Mandates. In addition, the 3PAO must assess the CSP’s ability to meet the requirements in Section 4.2, FedRAMP Requirements. The 3PAO must use its expert judgment to subjectively evaluate the CSP’s overall readiness and factor this evaluation into its attestation.

THE 3PAO SHOULD SUBMIT THE RAR ONLY IF THE CSP IS FULLY READY TO PURSUE A FedRAMP AUTHORIZATION AT THE TIME OF ASSESSMENT.

The FedRAMP Director will make a determination, based on the RAR, whether the Cloud Service Offering (CSO) is suitable for a FedRAMP JAB Provisional ATO (P-ATO) and/or FedRAMP Agency ATO. The FedRAMP Director will provide a letter to the CSP that outlines the results of the review and JAB P-ATO/Agency ATO suitability.

[3PAO name] attests to the accuracy of the information provided in this FedRAMP Readiness Assessment Report (RAR) and the [CSP name and system name]’s readiness to meet the FedRAMP requirements as described in this RAR. [3PAO name] recommends that the FedRAMP PMO grant [CSP system name] “FedRAMP-Ready” status, based on the CSP’s security capabilities as of [Assessment Completion Date]. This attestation is based on [3PAO name]’s 3PAO Accreditation by the American Association of Laboratory Accreditation (A2LA) and FedRAMP, experience and knowledge of the FedRAMP requirements, and knowledge of industry cybersecurity best practices. This FedRAMP RAR was created in alignment with FedRAMP requirements and guidance. While this report only contains summary information regarding a CSP’s ability to meet the FedRAMP requirements, it is based on [3PAO name]’s active validation of [CSP name and system name]’s security capabilities through observations, evidence reviews, personnel interviews, and demonstrated capabilities of security implementations. This FedRAMP Readiness Assessment Report (RAR) is valid for one calendar year after designation from the FedRAMP PMO. Lead Assessor’s Signature: X_______________________________ Date: _______________ <Lead Assessor’s Name> <3PAO Name>

Readiness Assessment Activities Instruction: In one or two paragraphs, provide the date(s) and location(s) of the readiness assessment, as well as a brief description of what actions the 3PAO performed to gather and validate the information provided in this report. If interviews were conducted, state the role(s) of the individuals interviewed. Names are not necessary. If testing or examination was performed, briefly state what testing was conducted and what was examined.

Executive Summary Instruction: In the space below, provide a one-paragraph description of the system that includes all the information provided in Table 3-1, System Information.

In the space below, make a statement as to the CSP’s overall readiness, then provide up to four paragraphs that summarize the information provided in Sections 4.1, 4.2, and 4.3, based on the 3PAO’s cybersecurity expertise and knowledge of FedRAMP, including notable strengths and other areas for consideration. At a minimum, the 3PAOs must describe the following: Overall alignment with the National Institute of Standards and Technology (NIST) definition of cloud computing according to NIST SP 800-145; Notable strengths and weaknesses; Ability to consistently maintain a clearly defined system boundary; Risks associated with interconnections used to transmit federal data/metadata or sensitive system data/metadata; Risks associated with the use of external systems and services that are not FedRAMP authorized; Clearly defined customer responsibilities; Unique or alternative implementations; Overall maturity level relative to the system type, size, and complexity; and Overall operational maturity relative to how long the system and required security controls have been in operation.

Template Revision History

TABLE OF CONTENTS

List of Tables

Introduction Purpose This report and its underlying assessment are intended to enable FedRAMP to reach a FedRAMP-Ready decision for a specific Cloud Service Provider’s system, based on organizational processes and the security capabilities of the Moderate-impact information system. FedRAMP grants a FedRAMP-Ready designation when the information in this report indicates the CSP is likely to achieve a FedRAMP Authorization for the system.

Outcomes A 3PAO should only submit this report to FedRAMP if it determines the CSP’s system is fully ready to pursue, and likely to achieve, a FedRAMP Authorization at the Moderate security impact level. Submission of this report by the 3PAO does not guarantee a FedRAMP-Ready designation, nor does it guarantee a FedRAMP Authorization.

The FedRAMP Director will make a determination, based on the RAR, if the CSO is suitable for a FedRAMP JAB Provisional ATO (P-ATO) and/or FedRAMP Agency ATO. The FedRAMP Director will provide a letter to the CSP that outlines the results of the review and JAB P-ATO/Agency ATO suitability.

FedRAMP Approach and Use of This Document The RAR identifies clear and objective security capability requirements, where possible, while also allowing for the presentation of subjective information. The clear and objective requirements enable the 3PAO to concisely identify whether a CSP is achieving the most important FedRAMP Moderate baseline requirements. The combination of objective requirements and subjective information enables FedRAMP to render a readiness decision based on a more complete understanding of the CSP’s security capabilities.

Section 4, Capability Readiness, is organized into three sections:

· Section 4.1, Federal Mandates, identifies a small set of the Federal mandates a CSP must satisfy. FedRAMP will not waive any of these requirements.

· Section 4.2, FedRAMP Requirements, identifies an excerpt of the most compelling requirements from the NIST Special Publication (SP) 800 document series and FedRAMP guidance. A CSP is unlikely to achieve a FedRAMP Authorization if any of these requirements are not met.

· Section 4.3, Additional Capability Information, identifies additional information, not tied to specific requirements, that has typically reflected strongly on a CSP’s ability to achieve a FedRAMP Authorization.

General Guidance and Instructions Embedded Document Guidance This document contains embedded text intended to instruct the 3PAO on how to complete each section. These instructions ensure FedRAMP receives all the information necessary to render a FedRAMP-Ready decision.

The instructional text is in blue and should be removed after the report is fully developed, and before it is submitted to FedRAMP.

Additional Instructions to 3PAOs 3PAOs must adhere to the following instructions when preparing the RAR:

1. Do NOT submit the completed Moderate RAR without first coordinating with the FedRAMP PMO via info@fedramp.gov.

2. On the Title Page, enter the CSP name, system name, version number and date of this RAR submission. If this is a re-submission, be sure to increment the version number and adjust the date.

3. The RAR must provide:

a. An overview of the system;

b. A subjective summary of the CSP’s overall readiness, including rationale such as notable strengths and other areas for consideration;

c. An assessment of the CSP’s ability to meet the Federal Mandates identified in Section 4.1, the FedRAMP Requirements identified in Section 4.2, and Additional Capabilities identified in Section 4.3;

d. A clear description and diagram of system components and services within the authorization boundary, as well as any interconnections to external systems and services that are outside of the authorization boundary;

e. A clear Data Flow diagram(s) and description(s) that accounts for all federal information, data, and metadata that flows through the authorization boundary and to/from external systems and services; and

f. The 3PAO’s attestation regarding the CSP’s readiness to meet FedRAMP Moderate baseline requirements.

4. FedRAMP will not consider a CSP for a FedRAMP-Ready designation unless all the requirements in Section 4.1, Federal Mandates, are met. Please note: Meeting these requirements does not guarantee a FedRAMP-Ready designation.

5. 3PAOs must assess the system’s technical, management, and operational capabilities using a combination of methods, including interview, observation, demonstration, examination, and onsite visits (for example, in-person interviews and data center visits as needed). 3PAOs may use CSP-provided diagrams, but must validate the diagrams as though the 3PAO created them. 3PAOs must not conduct this Readiness Assessment exclusively by reviewing a CSP’s written documentation and performing interviews. Active validation of all information provided within this report is required.

6. 3PAOs must complete all sections and address all elements of each question. 3PAOs must also describe observations of any missing elements (for example, if the CSP fails to meet all of the question elements). If a capability is fully inherited, answer “yes” and write "fully inherited" in the column provided for the capability description.

7. Control references are provided with each of the questions in Section 4.2, FedRAMP Requirements. These references are provided to help the 3PAO understand the basis for each question; however, the 3PAO is expected to consider all relevant FedRAMP security controls and capabilities when assessing the CSP’s capabilities.

8. FedRAMP believes a typical level of effort for conducting a readiness assessment for mid-size, straightforward systems is between two and four weeks, with the first half focused on information gathering and the second half focused on analysis and report development.

System Information Instruction: Provide and validate the information below. For example, if the deployment model is Government only, ensure there are no non-Government customers. The RAR template is intended for systems categorized at the Moderate security impact level, in accordance with the FIPS Publication 199 security categorization.

Table 31. System Information CSP Name:

System Name:

Service Model: (IaaS, PaaS, SaaS) FIPS PUB 199 System Security Level: (Moderate) Fully Operational as of: Enter the date the system became fully operational.

Number of Customers (US Federal/Others): Enter # of US Federal customers / # of other customers.

Deployment Model: Public Cloud, Government-Only Cloud, Federal Government-Only Cloud, or DOD Cloud.

System Functionality: Briefly describe the functionality of the system and service being provided.

Authorization Boundary IMPORTANT: Ensuring authorization boundary accuracy in the RAR is critical to FedRAMP authorization activities. Inaccuracies within the RAR may give authorizing officials and FedRAMP grounds for removing a CSP from assessment and authorization activities.

An authorization boundary provides a diagrammatic illustration of a CSO’s internal services, components, and other devices, along with connections to external services and systems. An authorization boundary accounts for all federal information, data, and metadata that flow through a CSO.

Instruction: The 3PAO must perform full authorization boundary validation for the RAR, ensure nothing is missing from the CSP-identified boundary, and ensure all included items are actually present and are part of the system inventory. To achieve this, the 3PAO must perform activities including, but not limited to, discovery scans, in-person interviews, and physical examinations where appropriate. 3PAOs should use the FedRAMP Authorization Boundary guidance as a reference when assessing and validating the authorization boundary.

Instruction: Insert 3PAO-validated network and architecture diagram(s) and provide a written description of the Authorization Boundary. The 3PAO must ensure the diagram:

· Includes a clearly defined authorization boundary that accounts for the flow of all federal information, data, and metadata through the system;

· Clearly defines services wholly within the boundary;

· identifies all interconnections to external systems and services (including corporate shared services);

· Depicts all major physical components or groups within the boundary;

· Depicts all major software/virtual components (or groups of) within the boundary; and

· Is validated against the inventory.

NOTE: The diagram must include a predominant border drawn around all system components and services included in the authorization boundary. The diagram must be easy to read and understand. If necessary, adjust the page orientation to landscape and/or use multiple diagrams to provide the best representation of the authorization boundary.

Leveraged FedRAMP Authorizations Instruction: If this Moderate system leverages another FedRAMP Authorized CSO (for example, an IaaS that provides compute, network, and storage; or a SaaS that provides operational support services), provide the relevant details in Table 3-2 below. Please note:

· The CSO must be listed on the FedRAMP Marketplace with a Status of “Authorized”;

· 3PAOs must validate that all sub-services listed in Table 3-2 are included in the leveraged CSO’s authorization boundary. (Refer to the CSO Service Description on the FedRAMP Marketplace.) Services that are not included in a FedRAMP-authorized boundary must be listed in Table 3-3; and

· If the system is leveraging external services from a FedRAMP authorized system, the interfaces to the services must be included in the boundary and must also be assessed by the 3PAO.

IMPORTANT: If there is a leveraged CSO, be sure to note every capability in Section 4 that partially or fully leverages the CSO. When doing so, indicate the capability is fully inherited or describe both the inherited and non-inherited aspects of the capability.

Table 32. Leveraged FedRAMP Authorizations

External Systems and Services CSPs often establish interconnections to external systems and services to (i) exchange data and information or (ii) augment system functionality and operational support services.

Instruction: 3PAOs must identify all interconnections to external systems and services in Table 3-3. 3PAOs should not rely solely on CSP-provided boundary diagrams or interviews, but should use a combination of methods, such as analyzing data flows and ingress/egress rules, reviewing all open ports and service accounts, and examining solutions used to manage and operate the system. Interconnections to all external systems and services should also be depicted on the authorization boundary diagram in Section 4.1.

NOTE: FedRAMP defines an interconnection as any communication path used to push, pull, or exchange data and/or information, including Application Programming Interfaces (APIs). For example, the collection of traffic information via the Microsoft Bing Maps API set or integration with the DocuSign service via the DocuSign Enterprise API set are both considered interconnections. 3PAOs must identify all API sets in Section 3.4, Table 3-4.

Table 33. External Systems and Services

Description: Describe the purpose of the external system/service and the hosting environment (for example, corporate network, IaaS, or self-hosted).

Risk/Impact/Mitigation: Describe potential risks introduced by the external system/service and impact to the CSO or federal customer data if the confidentiality, integrity, or availability (CIA) of the system/service were compromised. Please note: 3PAOs should carefully consider impact levels associated with metadata and the risk to the CSO or customer data if CIA of the metadata were compromised. Describe any mitigations or compensating controls in place to reduce risk.

Agreements: Indicate whether an Interconnection Security Agreement (ISA), Service Level Agreement (SLA), or other contractual agreement exists for this system/service.

Description:

Risk/Impact/Mitigation:

Agreements:

Description:

Risk/Impact/Mitigation:

Agreements:

FEDRAMP MODERATE READINESS ASSESSMENT REPORT (RAR)

CSP Name | Information System Name Version #.#, Date

| 7 APIs CSPs often leverage public or custom APIs to push, pull, or exchange data and information with external resources. CSPs may use publicly available API sets provided by vendors such as Amazon, Microsoft, and Google, or may develop custom APIs.

Instruction: Examples of public API sets are provided in Table 3-4 and the URL below. 3PAOs must identify all public or custom CSP-leveraged API sets that allow data to flow to and from the system. Remove the examples and use the blank rows in Table 3-4 to enter the API sets. Add new rows as needed. https://www.programmableweb.com/apis/directory Table 34. APIs

center Layer 2 and Layer 3 infrastructure with Cisco Nexus® products

Trusted Internet Connection (TIC) [CA-3(3)] Instruction: Describe the CSP’s ability to support an Agency customer’s TIC requirements.

Data Flow Diagrams Instruction: Insert 3PAO-validated data flow diagram(s), and provide a written description of the data flows. The diagram(s) must:

· Clearly identify anywhere Federal data is to be processed, stored, or transmitted;

· Clearly delineate how data comes into and out of the system boundary, including data transmitted to/from all external systems and services;

· Clearly identify data flows for privileged, non-privileged, and customer access; and

· Depict how all ports, protocols, and services of all inbound and outbound traffic are represented and managed.

NOTE: The data flow diagram must be easy to read and understand. If necessary, adjust the page orientation to landscape and/or use multiple diagrams to provide the best representation of the data flows.

Separation Measures [AC-4, SC-7] Instruction: Assess and describe the strength of the physical and/or logical separation measures in place to provide segmentation and isolation of tenants, administration, and operations; addressing user-to-system; admin-to-system; and system-to-system relationships.

The 3PAO must base the assessment of separation measures on strong evidence, such as the review of any existing penetration testing results, or an expert review of the products, architecture, and configurations involved. The 3PAO must describe the methods used to verify the strength of separation measures.

Capability Readiness Federal Mandates This section identifies Federal requirements applicable to all FedRAMP authorized systems. All requirements in this section must be met. Some of these topics are also covered in greater detail in Section 4.2, FedRAMP Requirements, below.

Instruction: Only answer “Yes” if the requirement is fully and strictly met. The 3PAO must answer “No” if an alternative implementation is in place.

Table 41. Federal Mandates

FedRAMP Requirements This section identifies additional FedRAMP Readiness requirements. All requirements in this section must be met; however, alternative implementations and non-applicability justifications may be considered on a limited basis.

Approved Cryptographic Modules [SC-13] Instruction: The 3PAO must ensure FIPS 140-2 Validated cryptographic algorithms and modules are used. FIPS 140-2 Compliant is not sufficient. The 3PAO may add rows to the table if appropriate, but must not remove the original rows. The 3PAO must identify all non-validated cryptographic modules in use.

Table 42. Cryptographic Modules

(If Applicable) Describe Missing Elements or N/A Justification

Transport Layer Security [NIST SP 800-52, Revision 1] Instruction: The 3PAO must identify all protocols in use. The 3PAO may add rows to the table if appropriate, but must not remove the original rows.

Table 43. Transport Layer Security

Identification, Authentication, and Access Control Instruction: Only answer “yes” if the answer is consistently “yes.” For partially implemented areas, answer “no” and describe what is missing to achieve a “yes” answer. If inherited, please indicate partial or full inheritance in the “Describe Capability” column. Any non-inherited capabilities must be described.

Table 44. Identification, Authentication, and Access Control

State the Digital Identity Level and provide sufficient details demonstrating that the system complies with this level, consistent with NIST SP 800-63 and FedRAMP guidance.

The capability description is not required here, but must be included in Section 3.7, Separation Measures.

The capability description is not required here, but must be included in Section 3.7, Separation Measures.

Audit, Alerting, Malware, and Incident Response Instruction: Only answer “yes” if the answer is consistently “yes.” For partially implemented areas, answer “no” and describe what is missing to achieve a “yes” answer. If inherited, please indicate partial or full inheritance in the “Describe Capability” column. Any non-inherited capabilities must be described.

Table 45. Audit, Alerting, Malware, and Incident Response

If the system contains no custom software development, do not answer Y or N. Instead, state “NO CUSTOM CODE” here.

Contingency Planning and Disaster Recovery Instruction: Only answer “yes” if the answer is consistently “yes.” For partially implemented areas, answer “no” and describe what is missing to achieve a “yes” answer. If inherited, please indicate partial or full inheritance in the “Describe Capability” column. Any non-inherited capabilities must be described.

Table 46. Contingency Planning and Disaster Recovery

Configuration and Risk Management Instruction: Only answer “yes” if the answer is consistently “yes.” For partially implemented areas, answer “no” and describe what is missing to achieve a “yes” answer. If inherited, please indicate partial or full inheritance in the “Describe Capability” column. Any non-inherited capabilities must be described.

Table 47. Configuration and Risk Management

If “yes,” describe whether the configuration settings are based on Center for Internet Security (CIS) Benchmarks or United States Government Configuration Baseline (USGCB), or “most restrictive consistent with operational requirements.”

For the following questions, 3PAOs may use Table 4-18, (Continuous Monitoring Capabilities – Additional Details) to enter the capability descriptions, supporting evidence, and missing elements.

Describe how the 3PAO validated that vulnerability scans were fully authenticated.

Describe how the 3PAO validated that the CSP remediates High vulnerabilities within 30 days and Moderate vulnerabilities within 90 days.

Data Center Security Instruction: Only answer “yes” if the answer is consistently “yes.” For partially implemented areas, answer “no” and describe what is missing to achieve a “yes” answer. If inherited, please indicate partial or full inheritance in the “Describe Capability” column. Any non-inherited capabilities must be described.

Table 48. Data Center Security

Policies, Procedures, and Training Instruction: The 3PAO must indicate the status of policy and procedure coverage for the NIST 800-53, Rev 4, control families listed in Table 4-9 below.

To answer “yes” to a policy, it must be fully developed, documented, and disseminated; and it must address purpose, scope, roles, responsibilities, management commitment, coordination among organizational entities, and compliance. A single policy document may address more than one family, provided the NIST requirements of each “dash one” controls are fully addressed.

To answer “yes” to a procedure, it must be fully developed and consistently followed by the appropriate staff. List all applicable procedure documents for each family.

CSPs must establish their own set of Policies and Procedures (P&Ps). They cannot be inherited from a leveraged system, nor can they be provided by the customer. Any exceptions and/or missing policy and procedure elements must be explained in Table 4-10 below.

Table 49. Policies and Procedures

Policy:

Procedure(s):

Policy:

Procedure(s):

Policy:

Procedure(s):

Policy:

Procedure(s):

Policy:

Procedure(s):

Policy:

Procedure(s):

Policy:

Procedure(s):

Policy:

Procedure(s):

Policy:

Procedure(s):

Policy:

Procedure(s):

Policy:

Procedure(s):

Policy:

Procedure(s):

Policy:

Procedure(s):

Policy:

Procedure(s):

Policy:

Procedure(s):

Policy:

Procedure(s):

Policy:

Procedure(s):

Instruction: For any family with a policy or procedure gap, please describe the gap below.

Table 410. Missing Policy and Procedure Elements Missing Policy and Procedure Elements

Instruction: The 3PAO must answer the questions below.

Table 411. Security Awareness Training

Does the CSP train personnel on security awareness and role-based security responsibilities?

Additional Capability Information FedRAMP will evaluate the responses in this section on a case-by-case basis relative to a FedRAMP-Ready designation decision.

Staffing Levels Instruction: In the table below, the 3PAO must describe the CSP’s organizational structure and staffing levels currently dedicated to the security of the system, and any planned changes to these staffing levels. This description must clearly indicate roles and number of individuals, as well as identify which staff is full-time dedicated and which are performing their role as a collateral duty. It should be noted in the organizational structure who has the authority to perform activities on the system and how these differ between staff or teams of staff (e.g., who has authority to apply patches; who has authority over configuration management; who has authority over making changes to the environment; who is in charge of compliance reporting).

Table 412. Staffing Levels Staffing Levels

Change Management Maturity While the following change management capabilities are not required, they indicate a more mature change management capability and may influence a FedRAMP Readiness decision, especially for larger systems.

Instruction: The 3PAO must answer the questions below.

Table 413. Change Management

Vendor Dependencies and Agreements Instruction: The 3PAO must answer the questions below.

Table 414. Vendor Dependencies and Agreements

If “yes,” please complete Table 4-15, Vendor Dependency Details, below.

If any are not supported, answer, “No.”

If “yes,” please complete Table 4-16. Formal Agreements Details below.

Instruction: If there are vendor dependencies, please list each in the table below, using one row per dependency. For example, if using another vendor’s operating system, list the operating system, version, and vendor name in the first column, briefly indicate the CSP’s reliance on that vendor for patches, and indicate whether the vendor still develops and issues patches for that product. If there are no vendor dependencies, please type “None” in the first row.

Table 415. Vendor Dependency Details

Still Supported?

Instruction: If there are formal vendor agreements in place, please list each in the table below, using one row per agreement. If there are no formal agreements, please type “None” in the first row.

Table 416. Formal Agreements Details

Continuous Monitoring (ConMon) Capabilities Instruction: In the tables below, please describe the current state of the CSP’s ConMon capabilities, as well as the length of time the CSP has been performing ConMon for this system.

Table 417. Continuous Monitoring Capabilities

Instruction: In the table below, provide any additional details the 3PAO believes to be relevant to FedRAMP’s understanding of the CSP’s Continuous Monitoring Capabilities. If the 3PAO has no additional details, please state, “None.”

Table 418. Continuous Monitoring Capabilities– Additional Details Continuous Monitoring Capabilities – Additional Details

Status of System Security Plan (SSP) Instruction: In the table below, explicitly state whether the SSP is fully developed, partially developed, or non-existent. Identify any sections that the CSP has not yet developed. If the maturity of the SSP is low, or there is a high percentage that is not complete, please describe any risks the 3PAO believes this introduces to a full assessment.

Table 419. Maturity of the System Security Plan Maturity of the System Security Plan

Instruction: In the table below, state the number of controls identified as “Not Applicable” in the SSP. List the Control Identifier for each, and indicate whether a justification for each has been provided in the SSP control statement.

Table 420. Controls Designated “Not Applicable” <x> Controls are Designated “Not Applicable”

Instruction: In the table below, state the number of controls with an alternative implementation. List the Control Identifier for each.

Table 421. Controls with an Alternative Implementation <x> Controls have an Alternative Implementation

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