FedRAMP Continuous Monitoring
FedRAMP authorization is not a one-time achievement. Continuous monitoring (ConMon) is an ongoing obligation that requires regular security activities, reporting, and assessments throughout the life of your authorization. Failure to meet ConMon requirements can result in revocation of your authorization.
Monthly Requirements
Every month, FedRAMP-authorized CSPs must deliver vulnerability scan results (infrastructure and database), POA&M updates documenting the status of all open findings, and an inventory of all system components with any changes. Scans must cover all system components within the authorization boundary.
Quarterly Requirements
Quarterly activities include vulnerability scan results for web applications and containers, evidence of security training completion for new personnel, and updates to any system documentation that has changed.
Annual Requirements
Annual requirements include a full security assessment of a subset of controls (typically one-third, so all controls are assessed over three years), penetration testing, incident response plan testing, contingency plan testing, and an updated SSP reflecting any changes over the year.
Vulnerability Management
FedRAMP has strict timelines for remediating vulnerabilities. Critical vulnerabilities must be remediated within 30 days. High vulnerabilities within 30 days. Moderate vulnerabilities within 90 days. Low vulnerabilities within 180 days. Vulnerabilities not remediated within these timeframes must be documented in the POA&M with justification and a remediation plan.
Significant Change Requests
Any significant change to your system — new services, architecture changes, data flow modifications, or boundary changes — must be reported to your authorizing official and FedRAMP. Significant changes may trigger additional assessment before implementation. Plan for the approval process in your change management timeline.
POA&M Management
The Plan of Action and Milestones is a living document tracking all open findings. Maintain it meticulously — it is reviewed monthly by your authorizing official. Each entry should include the finding, risk rating, remediation plan, milestones, responsible parties, and target completion date.
Operational Considerations
Budget for continuous monitoring from day one. The annual cost of ConMon ranges from $200,000 to $500,000 depending on system complexity. Automate scanning and reporting where possible. Maintain a dedicated team or contractor responsible for ConMon deliverables. Treat ConMon as an ongoing operations function, not a compliance project.