What Does it Take to Create a New FedRAMP Revision?

Kenny Scott
Feb 2024

Tune in to hear Kenny Scott and Christian Hansen of Moss Adams talk all things Rev 5: 

The Dynamics of Decision-Making

Guidance and regulation, especially in the realm of cybersecurity, can often come across as complex. Behind each rule or suggestion lies a plethora of discussions, disagreements, and the pursuit of consensus.

It's a collaborative effort where experts, although well-intentioned, sometimes offer varying insights. This variation isn't necessarily due to inconsistency but because of the intricacies of the issues they're handling. In essence, the guidance provided today might evolve or shift depending on the latest data, technological trends, or security threats.

The Quest for Consensus

Achieving agreement is no easy task. Consider the process for updates or changes to FedRAMP guidelines. Government agencies like the Department of Defense, General Services Administration, and Homeland Security all have stakes in the game. Within these entities, various levels of decision-makers, from the CISOs to the CIOs, bring their perspectives, leading to a myriad of viewpoints.

At times, external events or pressing concerns (like national security threats) can redirect focus, causing a delay in consensus for other issues. Balancing these multifaceted interests and concerns is a testament to the complexity of the process.

Looking Ahead: The Implications of Change

As revisions to regulatory guidance, such as FedRAMP, take shape, organizations must remain proactive and agile. For instance, potential changes in directives, like the hypothetical 'red team' scenarios, can bring about significant operational shifts. It's crucial to evaluate organizational readiness – whether there are internal capabilities for new mandates or if external expertise is needed.

Conclusion

Creating a new FedRAMP revision is a monumental task, blending collaboration, consensus-seeking, and a keen understanding of the evolving digital landscape. While organizations await clear directives, they must also remain adaptive, ensuring they're well-positioned to act decisively once new guidance is rolled out. The dance between regulatory bodies and the entities they guide is intricate, emphasizing the need for patience, understanding, and proactive preparation.

Kenny Scott
Oct 2024
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