Why hosting alone doesn’t equal FedRAMP or GovRAMP compliance

Public sector teams across local, state, and federal agencies are under pressure to modernize, consolidate legacy systems, and adopt cloud services that deliver scalability, resilience, and lower total cost of ownership. These benefits are compelling—but they also widen the threat surface, introduce new dependencies, and require disciplined security governance. FedRAMP (Federal Risk and Authorization Management Program) and GovRAMP (formerly StateRAMP) exist to standardize security expectations for cloud services so agencies can adopt them confidently and consistently.

A persistent misconception is that simply hosting a solution in AWS GovCloud or Azure Government results in full compliance with FedRAMP or GovRAMP requirements. It does not. Authorized hosting environments provide foundational controls such as physical and environmental controls, but application‑level controls, continuous monitoring, and operational practices must also be implemented and authorized for the specific Software as a Service (SaaS) product. Failing to recognize this distinction can lead to procurement delays, audit findings, and, in worst cases, security incidents that erode public trust.

This article clarifies the difference between infrastructure authorization and application authorization, explains how FedRAMP and GovRAMP work, breaks down shared responsibility, and provides practical steps for verifying vendor claims. It is written for internal audit, procurement, risk, and IT teams that want a concise, actionable guide to getting cloud compliance right.

• What are FedRAMP and GovRAMP?
• Example: TeamMate authorization
• How authorization works
  • Preparation
  • Authorization
  • Continuous monitoring
• Impact levels explained
• Why hosting alone doesn’t equal compliance
• The shared responsibility model—in practice
• Control families
• Examples of non-inherited controls
• Case study 1: The logging gap
• Case study 2: Encryption ownership
• Procurement workflow
• Agency checklist
• Common misconceptions
• Risks of non‑compliance
• Quick FAQ
• Glossary of terms
• Key takeaways
• Next steps

Control families: Where hosting ends and SaaS begins

A practical way to understand responsibilities is to walk through major NIST SP 800‑53 families:

Access control (AC)

Platforms support IAM, but the vendor must design roles, enforce least privilege, implement MFA for privileged functions, manage session controls, and run periodic access reviews. Joiner, Mover, Leaver processes must be documented and automated where possible.

Audit and accountability (AU)

Infrastructure logging is useful, yet agencies need application events: admin actions, configuration changes, data exports, permissions changes, and failed access attempts. Vendors must define log retention, tamper resistance, correlation with platform logs, and alerting on high-risk events.

Configuration management (CM)

Baseline images and hardened OS builds may be inherited. The vendor owns application configuration baselines, change control, peer review, segregation of duties, and drift detection. Evidence includes change tickets, approvals, and rollback procedures.

Identification and authentication (IA)

The platform enables SSO and MFA, but the vendor must implement user lifecycle management, password/secret policies for service accounts, API authentication, and periodic credential hygiene checks.

Incident response (IR)

Cloud providers respond to infrastructure incidents. Vendors must maintain IR playbooks, conduct tabletop exercises, define customer notification thresholds/timelines, and perform post-incident reviews with documented corrective actions.

System and communications protection (SC) & media protection (MP)

Vendors decide and document cipher suites, TLS enforcement, certificate renewal, data flow protections, API security design, and token management. If customer-managed keys (CMK) are required, vendors must support and evidence key rotation and access controls.

Contingency planning (CP)

Backups can leverage platform services, but vendors must define RPO/RTO, test restoration, rehearse failover, document dependency maps, and maintain runbooks for disasters.

Personnel security (PS) & awareness and training (AT)

Vendors need background checks where applicable, role-based security training, phishing simulations, and policy acknowledgements for staff with system access.

These control families illustrate why a secure platform is necessary but is insufficient. Agencies must see design, operation, and evidence at the application tier.

Examples of non‑inherited controls

Common application owned‑ controls include:

• Incident response planning with roles, escalation paths, and customer communications.
• Authenticated vulnerability scanning of the application and rapid patch management.
• End-to-end encryption with documented key ownership and rotation.
• Role-based access control and access recertification for admins and sensitive data users.
• Continuous monitoring with dashboards, alerts, and monthly reporting.
• Configuration management with baselines, change tickets, and approvals.
• Backup and recovery drills with restoration evidence and failover rehearsal.
• Workforce training focused on secure operations and compliance responsibilities.

Agencies should request artifacts that prove these controls exist and operate, not just policy statements.

Case study 1: The logging gap

A finance agency adopts a SaaS analytics application hosted on an authorized platform. Infrastructure logs are collected, but the app only records authentication events—no admin actions, no configuration changes, no data export activity. During an audit, reviewers ask for evidence that access to sensitive dashboards is monitored and anomalous usage is detected. The vendor cannot provide correlated application tier logs. Result: a finding, a POA&M entry, and delayed rollout.

Resolution

The vendor must implement rich application logging (admin actions, permission changes, data exports), route logs to the agency SIEM, and set retention and alert rules. However, these changes alone are not sufficient for compliance. The fixes must be independently assessed by a 3PAO, documented in the System Security Plan (SSP), and included in continuous monitoring reports. The agency should review evidence of these controls and require ongoing verification, not just rely on vendor self-attestation.

Case study 2: Encryption ownership

A public health agency requires end-to-end encryption of patient identifiers with agency-controlled keys. The vendor relies on platform-managed keys and default rotation but lacks CMK support and clear certificate lifecycle procedures. A certificate expires unexpectedly, causing an outage and data availability risk.

Resolution

The vendor must enable CMK, document rotation schedules, automate certificate renewal, and create incident runbooks for key compromise scenarios. However, as with all compliance-related changes, these must be independently assessed by a 3PAO, documented in the SSP, and included in continuous monitoring. The agency should require evidence of these controls and ongoing verification, not just trust vendor claims.

Procurement workflow: Verifying compliance step‑by‑step

A structured workflow prevents surprises and accelerates time-to-value:

1. Pre‑solicitation: Confirm vendor listing on FedRAMP Marketplace or GovRAMP directory. Identify the targeted impact level and any existing ATOs.
2. RFP/RFI requirements: Require current authorization or a sponsored path; request artifacts (SSP, policies, test plans); specify monthly scan delivery and POA&M reporting cadence.
3. Evaluation: Review system boundary, data flows, and inherited vs. vendor controls. Ask who owns encryption keys, how logs are correlated, and how identity is governed.
4. ATO endorsement: Coordinate with the authorizing official to document conditions, constraints, and integration requirements (e.g., SIEM ingestion, SSO, incident playbooks).
5. Implementation & handoff: Capture configuration baselines, logging destinations, backup schedules, and incident escalation timelines. Establish change control hooks.
6. Continuous Monitoring: Track monthly scans and remediation SLAs; review annual assessments; require access recertifications and training attestations at agreed intervals.

Agency checklist

Use this checklist during procurement and oversight:

Marketplace and authorization

• Vendor appears on the FedRAMP/GovRAMP directory.
• Impact level matches data sensitivity (via FIPS‑199).
• SaaS product ATO status is documented and current.

Documentation and evidence

• SSP complete and current; boundary and data flows clearly drawn.
• Policies for AC, AU, CM, IA, IR, CP, SC, AT, PS approved.
• 3PAO results provided; open findings tracked in POA&M.

Technical controls

• MFA enforced for admin access; least privilege documented.
• Application logging configured; retention and SIEM correlation in place.
• Encryption end-to-end; certificates, keys, and secrets managed securely.
• Configuration baselines defined; change control procedures operational.

Operations and monitoring

• Monthly vulnerability scans shared; remediation within SLAs.
• Incident response plan tested; customer notification timelines documented.
• Backup and restoration tested; RPO/RTO defined; failover rehearsed.
• Training and awareness conducted; access recertification performed quarterly.

Common misconceptions (and corrections)

• Myth: Hosting equals compliance.
  Reality: Hosting covers infrastructure controls. Application controls, monitoring, and operations remain the vendor’s responsibility.
• Myth: Vendor marketing claims are sufficient.
  Reality: Independent verification via 3PAO and continuous monitoring artifacts is required.
• Myth: Authorization is a one-time event.
  Reality: Compliance must be maintained through scans, assessments, POA&M management, and operational discipline.

Corrective Action: Demand documented evidence, test results, and clear ownership of app‑tier controls.

Risks of non‑compliance

Non‑compliance has tangible consequences:

• Procurement delays that stall mission programs and force re‑planning.
• Audit findings that consume staff cycles, budget, and leadership attention.
• Security incidents that jeopardize citizen data and confidence.
• Reputational damage that affects eligibility for future contracts.
• Oversight escalation, corrective action plans, and higher assurance costs until gaps are remediated.

A precise understanding of shared responsibility—and early verification of vendor claims—reduces these risks.

FAQ

Is AWS GovCloud FedRAMP certified?
Yes, at the infrastructure level. SaaS applications require separate authorization.

Does hosting in Azure Government guarantee compliance?
No. Vendors must implement and obtain authorization for application‑level controls.

What is a 3PAO?
A Third‑Party Assessment Organization accredited to test and validate controls against NIST requirements.

How often is compliance checked?
Monthly scans with remediation tracking, annual assessments, and ongoing POA&M updates.

Can agencies inherit all controls from hosting?
No. Identity governance, application logging, encryption configuration, incident response, and backup testing remain vendor-owned.

What happens if a vendor lacks an ATO?
Procurement delays, increased audit risk, and potential re-competition if authorization cannot be achieved within timelines.

Can an agency sponsor authorization?
Yes. Sponsorship is common but requires engagement to review artifacts, monitor remediation, and accept defined risks temporarily.

Do multi‑tenant SaaS offerings complicate authorization?
They can—vendors must document tenant isolation, data residency, and key management clearly and prove effectiveness.

Is single tenant‑SaaS automatically safer?
Not necessarily. Control design and operational maturity matter more than tenancy model alone.

How should we assess encryption claims?
Ask: Who manages keys? What rotation interval is enforced? Which cipher suites are permitted? How are certificates renewed and revoked?

Glossary of terms

• ATO (Authorization to Operate)
  • Formal authorization from an agency to operate a system within defined risk parameters.
• ATO Letter
  • The official document issued by an agency granting an ATO for a specific system.
• 3PAO (Third‑Party Assessment Organization)
  • An accredited independent assessor authorized to test and validate controls for FedRAMP or GovRAMP.
• API (Application Programming Interface)
  • A defined method for software components to communicate with each other, often requiring authentication and security controls.
• Boundary (Authorization Boundary)
  • The defined scope of components, services, and interfaces included in an authorization.
• CMK (Customer‑Managed Keys)
  • Encryption keys controlled by the customer rather than the cloud provider, often required for sensitive workloads.
• CSP (Cloud Service Provider)
  • An organization offering cloud services such as SaaS, PaaS, or IaaS.
• CSO (Cloud Service Offering)
  • The specific cloud product or service undergoing FedRAMP or GovRAMP authorization.
• Continuous Monitoring
  • Ongoing activities that verify control effectiveness, including scans, assessments, and POA&M updates.
• Drift Detection
  • Processes that identify when system configurations deviate from approved baselines.
• FIPS199 (Federal Information Processing Standard 199)
  • The standard used to categorize information systems by impact level (Low, Moderate, High).
• FedRAMP Ready
  • An optional designation indicating a CSP has undergone a Readiness Assessment and meets baseline expectations for pursuing authorization.
• FedRAMP Marketplace
  • The official directory listing cloud services that are In Process, Ready, or Authorized.
• IAM (Identity and Access Management)
  • Tools and processes that govern user identities, roles, and access privileges.
• Impact Level (Low, Moderate, High)
  • The categorization of a system based on potential impact to confidentiality, integrity, and availability.
• Incident Response
  • Processes and playbooks for detecting, responding to, and recovering from security incidents.
• IPR (In Process Request)
  • A formal request submitted to FedRAMP to document an agency partnership and begin the authorization process.
• POA&M (Plan of Actions and Milestones)
  • A documented plan outlining how findings from assessments will be remediated.
• RPO (Recovery Point Objective)
  • The maximum acceptable amount of data loss measured in time.
• RTO (Recovery Time Objective)
  • The maximum acceptable time to restore service after a disruption.
• SAP (Security Assessment Plan)
  • A document outlining the testing approach and methodology used by a 3PAO.
• SAR (Security Assessment Report)
  • A report produced by a 3PAO detailing assessment results and findings.
• SIEM (Security Information and Event Management)
  • A system that aggregates, correlates, and analyzes logs for monitoring and alerting.
• SIEM Correlation
  • The process of linking events from multiple log sources to detect patterns or anomalies.
• Single Sign‑On (SSO)
  • An authentication method allowing users to access multiple systems with one set of credentials.
• SSP (System Security Plan)
  • The primary document describing system characteristics, control implementation, and security responsibilities.
• TLS (Transport Layer Security)
  • A protocol that encrypts data in transit between systems.
• Tenant Isolation
  • Mechanisms ensuring that data and processes of one customer are segregated from others in a multitenant environment.
• WBS (Work Breakdown Structure)
  • A structured project plan outlining tasks, milestones, and responsibilities for the authorization process.

Key takeaways

• Hosting in an authorized environment such as AWS GovCloud or Azure Government is necessary, but it alone is not sufficient for FedRAMP/GovRAMP compliance.
• SaaS vendors must obtain an ATO for their product at the appropriate impact level and demonstrate application‑tier controls and continuous monitoring.
• Agencies should verify claims through artifacts: SSP, 3PAO results, monthly scans, POA&M, logging evidence, encryption key ownership, incident playbooks, backup tests, and access reviews.
• A structured procurement and monitoring workflow reduces risk, accelerates adoption, and protects citizens’ data and trust.

Next steps

If your agency is evaluating a cloud service, begin by distinguishing clearly between platform authorization and application authorization. Require evidence for both, map responsibilities explicitly, and set monitoring cadences up front. The right questions, documents, and operational hooks will turn compliance from a barrier into a dependable foundation for modernization. Or simply visit the FedRAMP Marketplace and the GovRAMP Authorized Product List. If the vendor is not listed, their product is not Authorized. It’s that simple.

• FedRAMP Marketplace
• Authorized Product List - GovRAMP

Visit the TeamMate US Public Sector page to see how TeamMate+ supports U.S. government agencies be more effective and efficient. Also note that TeamMate is authorized at the hosting and product level by both FedRAMP and GovRAMP.