What does FedRAMP continuous monitoring require us to submit each month?

FedRAMP continuous monitoring primarily requires Cloud Service Providers (CSPs) to submit an updated Plan of Action and Milestones (POA&M) report monthly. This submission must detail all identified security weaknesses, their remediation status, and planned completion dates. Additionally, monthly vulnerability scan results, including authenticated scans of operating systems, databases, and web applications, are mandatory to demonstrate the ongoing security posture and compliance with authorization requirements.

The monthly POA&M submission is a critical artefact for demonstrating active risk management. It must comprehensively list all security weaknesses identified through various means, such as vulnerability scans, penetration tests, audits, or system changes. For each weakness, the POA&M requires a detailed remediation plan, including specific tasks, responsible parties, and target completion dates. Accurate and timely updates are paramount, reflecting the dynamic nature of an operational environment. Concurrently, CSPs must submit results from authenticated vulnerability scans covering all in-scope components, ensuring that new vulnerabilities are promptly identified and integrated into the POA&M for tracking and remediation.

Failure to adhere to these monthly submission requirements can have significant consequences, potentially leading to increased scrutiny from the Agency Authorising Official (AO) or the FedRAMP Program Management Office (PMO), and in severe cases, the revocation of a Provisional Authority to Operate (P-ATO) or Agency ATO. Practitioners often err by submitting incomplete POA&Ms, lacking sufficient detail on remediation actions, or failing to provide adequate evidence of vulnerability remediation. Establishing robust internal processes for continuous monitoring, including automated vulnerability scanning and a structured POA&M management system, is essential to maintain compliance and avoid disruptions to service delivery to government customers.

Sources

  • FedRAMP Continuous Monitoring Strategy Guide, Section 4.1.1
  • FedRAMP Plan of Action and Milestones (POA&M) Template

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