Understanding the Vital Role of 3PAOs in StateRAMP Certification

StateRAMP, akin to FedRAMP, is a meticulous process designed to enable Cloud Service Providers (CSPs) to serve crucial government agencies. To ensure CSPs are current with the latest and most robust security and risk management tools and procedures, both FedRAMP and StateRAMP mandate that CSPs collaborate with an independent entity known as a Third-Party Assessment Organization (3PAO). If you’re embarking on your journey as a CSP in the government sector or are a security firm keen on understanding the prerequisites for becoming a 3PAO, it’s essential to grasp the role of a 3PAO in these security frameworks.

What is a Third-Party Assessment Organization?

A StateRAMP Third-Party Assessment Organization (3PAO) is a professional entity that collaborates with businesses prepared to pursue StateRAMP certification. These organizations offer an independent evaluation of a business’s readiness to undergo StateRAMP certification and their ongoing adherence to compliance standards. 3PAOs play a pivotal role in the StateRAMP assessment process by providing an unbiased approach to evaluating a company, free from any professional affiliations with state organizations or cloud businesses. Consequently, 3PAOs have several responsibilities to their partners and the StateRAMP governing body.

A 3PAO must:

Maintain independence from any CSP or related technical provider they assess.
Operate exclusively as a Type A (third-party independent) or Type C (internal and self-inspecting) Inspection Body.
Conduct precise, fair, and high-quality security inspections of their partner CSPs.
Acquire and maintain up-to-date knowledge of relevant StateRAMP regulations.
Engage in internal continuing training and education to stay abreast of pertinent security guidelines related to StateRAMP.

When a company can demonstrate these requirements, they can be certified as a StateRAMP 3PAO.

Why is a 3PAO Necessary for StateRAMP Certification?

Every phase of the StateRAMP process necessitates the involvement of a 3PAO to ensure an impartial assessment of the CSP in question while guaranteeing the proper progression of the process.

Key areas of the StateRAMP certification process include:

Documentation: The 3PAO assists the CSP by initially determining the level of security controls an organization must have in place for StateRAMP authorization. These levels are dictated by the types of data the CSP will manage: Low, Moderate, and High Impact. State agencies are seldom in the High Impact category, so controls typically fall under Low, Medium, or a combination of the two.
Authorization and Readiness: When a CSP initiates the StateRAMP process, they must undergo a readiness assessment to ascertain their capability for the undertaking. The 3PAO aids the organization by creating a StateRAMP Readiness Assessment Report (SR-RAR) to demonstrate to StateRAMP that the CSP is prepared for assessment.
StateRAMP Ready and Preparation: Once the CSP has been designated as “ready,” the 3PAO then assists in preparing a Security Assessment Plan (SR-SAP). The SAP is the outcome of a general risk and security assessment of the CSP by the 3PAO and outlines the testing steps and schedule it will use to assess StateRAMP compliance.
Assessment: The 3PAO conducts tests of the CSPs systems to determine if they meet the requirements of StateRAMP for the security level outlined by their intended partnership. This testing includes an audit of reporting and logging capabilities, determining security measures in place, and different levels of penetration testing. These tests follow the SAP.
Authorization: The 3PAO is responsible for taking the results of the test and reporting to StateRAMP in an official document called the StateRAMP Security Assessment Report (SR-SAR). This report highlights successful tests and any changes, updates, or additions the CSP must make to address vulnerabilities.
Continued Maintenance: 3PAOs collaborate with CSPs to continue reporting and maintenance to ensure that they meet current requirements and have plans in place to do so.

It’s evident from this section that the 3PAO is not only essential to the process but also a valuable asset for CSPs unfamiliar with the process. A competent and experienced 3PAO can guide a CSP with little or no experience in security compliance or StateRAMP through the system successfully.

How Do I Find the Right 3PAO?

Certified 3PAOs must demonstrate to StateRAMP that they possess the necessary knowledge, experience, and capacity to audit and assist CSPs throughout the process. Fortunately, CSPs aren’t left to their own devices in finding a partner.

The StateRAMP website includes a database of 3PAOs, complete with contact information, websites, and assessed solutions. CSPs exploring a 3PAO can utilize this resource to find a local vendor who can support them.

Finding the right 3PAO will depend on several unique aspects of your needs, including regional considerations, industry requirements, the state agency partner you plan on working with, and so on.

How Does My Organization Become a 3PAO?

The requirements for a StateRAMP 3PAO are identical to those of a FedRAMP 3PAO, and StateRAMP uses FedRAMP requirements to determine fitness for StateRAMP auditing.

These requirements include:

A 3PAO must be able to accommodate assessments by the StateRAMP Program Management Office upon request.
All 3PAO personnel working within StateRAMP must attest to their knowledge and proficiency of critical StateRAMP requirements, including the NIST Risk Management Framework, NIST 800-53 security controls, and StateRAMP requirements (among others). 3PAO candidates will be assessed on their knowledge of these documents.
3PAOs must be accredited by the StateRAMP PMO. The American Association for Laboratory Accreditation (A2LA) will provide evidence regarding the expertise, proficiency, and capabilities of the potential 3PAO, and the PMO will make the final decision.
The StateRAMP PMO must sign off on the final authorization.

StateRAMP 3PAOs must have a demonstrable understanding of the core frameworks used in FedRAMP certification (NIST 800-53 and Risk Assessment Framework) among other security documents and frameworks.

Conclusion

A cloud service provider cannot receive a StateRAMP certification without working with a 3PAO. Rather than treating this as a formality, consider it an opportunity to partner with a security expert that can not only help you navigate the complexities of StateRAMP but also enhance your overall security posture.