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Overview

In a perfect world, everybody might be adept at producing and consuming OSCAL. In reality, human-readable documentation is still a necessity and each vendor represents their content differently. Consequently, it can be challenging to fit existing documentation into the OSCAL model while still maintaining consistent outputs.

This FAQ will help you navigate common questions and issues related to specific documents.

FedRAMP Rev 5

SSP

Table of Contents

How can I get the table of contents to print?

To avoid unexpected behavior, DOCX documents must be opened with Microsoft Word. Also, when opening a document the first time, please click "Yes" when prompted to update the fields in the document.

General System Description

Where does the General System Description come from?

Your General System Description comes from the "System Function or Purpose" located in a project's Project Overview.

Section #6, #7

How can I populate "Data Types" in Leveraged Authorizations and Interconnections tables?

This field is populated by specifying the "Information Types Received" field in both FedRAMP System and Interconnection components.

How do I populate "Nature of Agreement" found in Leveraged Authorizations and Interconnections tables?
  1. Create an Agreement Component and specify the Nature of Agreement field.
  2. In the FedRAMP System or Interconnection component, set Agreement field to the newly created Agreement.
  3. In project overview, ensure that Leveraged Authorizations and System Interconnections have the desired selections. (either automatic or manual)
  4. The Nature of Agreement should be populated the with the appropriate value.

ATO Package Documents

Which FedRAMP Rev 5 ATO Package documents are automated by Paramify today?

Paramify's goal is to generate all feasible SSP ATO Package documents for the user. The table below outlines the current progress.

For the documents indicated in the column titled Requiremed FedRAMP Template Available, the FedRAMP template is available for downloaded within the Paramify platform in the relevant Attachment page.

DocumentParamify GeneratedRequired FedRAMP Template AvailableManual/Custom
Confidentiality Agreement
Interconnection Agreement
Non-Disclosure Agreement
System Security Plan
SSP Appendix A: FedRAMP Security Controls
SSP Appendix B: Related Acronyms✅ - Part of SSP
SSP Appendix C: Security Policies and Procedures
SSP Appendix D: User Guide
SSP Appendix E: Digital Identity Worksheet✅ - Part of SSP
SSP Appendix F: Rules of Behavior
SSP Appendix G: Information System Contingency Plan (ISCP)
SSP Appendix H: Configuration Management Plan (CPM)
SSP Appendix I: Incident Response Plan (IRP)
SSP Appendix J: CIS and CRM Workbook
SSP Appendix K: FIPS 199 Worksheet✅ - Part of SSP
SSP Appendix L: CSO-Specific Required Laws and Regulations✅ - Part of SSP
SSP Appendix M: Integrated Inventory Workbook✅ - significant inputs required
SSP Appendix N: Continuous Monitoring Plan
SSP Appendix O: Plan of Action and Milestones (POA&M)
SSP Appendix P: Supply Chain Risk Management Plan (SCRMP)
SSP Appendix Q: Cryptographic Modules Table
SSP Appendix R: Separation of Duties Matrix*
SSP Appendix S: User Summary Table*
Security Assessment Plan✅ - 3PAO
Security Assessment Report✅ - 3PAO
FedRAMP ATO Letter (required for agency packages only)

* Paramify added Appendices to simplify responses to Access Controls around least privilege and separation of duties.

Refer to FedRAMP Initial Authorization Package Checklist from FedRAMP.gov to confirm package requirements.

Appendix A

How do I model a "Hybrid" or "Shared" control origination?

Risk Solutions are single origination by design. Multi-responsibiliy Risk Solutions should be broken up for best results.

If you are converting legacy documentation into custom control responses, you can use a combination of originations to model a hybrid or shared control.

Hybrid is simply System Provider Specific AND System Provider Corporate.

Shared is a combination of system provider and customer originations.

  • Example: System Provider Specific AND Customer Provided
  • Example: System Provider Corporate AND Customer Configured

Appendix R

Is there a FedRAMP Template for Appendix R: Separation of Duties Matrix?

Last check on the Fedramp Documents & Templates page, FedRAMP does NOT have a template for Separation of Duties Matrix. Here is an example for your reference:

Example: Separation of Duties Matrix

The following table outlines the separation of duties for user roles within the FedRAMP System Name cloud environment.  The table is categorized by a user’s role, whether he/she is an internal employee or external entity such as a contractor, the user’s functions, and the level of access granted to the system.

RoleInternal or ExternalFunctions PerformedDevelopment Environment AccessProduction Environment AccessNetwork Log AccessSecurity Log Access
Admin UserInternalFull administrative access (root)YesYesYesYes
DeveloperInternalDevelopmentYesNoNoNo
Non-Admin UserInternalRead-Only Access to DashboardsNoNoNoNo
Customer AdminExternalApplication Administrator on Customer InstanceNoNoYesYes
Non-Admin Customer UserExternalSet by Customer AdminNoNoNoNo

Note: The focus is typically on privileged and not-privileged access so, for the purpose of the example above, no logical access roles are not included.

Leveraging my existing SSP

How can I leverage my existing SSP with Paramify?

Paramify's Recommendation

Your organization likely spent a boatload of money already creating an SSP. This is why some Paramify users who already have ATO packages hesitate to adopt our Risk Solutions platform.

And yes, Paramify will still improve and simplify your organization’s SSP creation and management processes without Risk Solutions. But, you’ll get the most accurate OSCAL SSPs and reduce your daily headache significantly when you adopt Risk Solutions.

Your previous efforts are not a sunk cost when you adopt Risk Solutions. We can use your existing SSP to create custom Risk Solutions to meet your specific control requirements. With Risk Solutions, your SSP becomes more accurate, your GRC org can work more efficiently and your teams can collaborate better.

Why Adopt Risk Solutions:

  1. Accuracy: Manually written SSPs are riddled with errors that slow down audits and authorizations. Our OSCAL-based Risk Solutions platform automatically maintains and updates to prevent human error.
  2. Efficiency: Your security requirements grow with your organization. Responding one by one to individual requirements is tedious and inefficient. A Risk solution can map to multiple controls across any security catalog – allowing you to be flexible and agile as your security objectives increase.
  3. Collaboration: Risk Solutions provide a platform to drive shared risk adoption across the organization. Security becomes a collective organizational effort that’s not owned only by the GRC team

Three ways to respond to control requirements:

ApproachParamify Intake OnlyLeveraging Existing SSPIntake + Existing SSP
Adopting Risk SolutionsAfter you complete the intake process, review your Risk Solutions with existing SSP in hand to add or modify context to those Risk Solutions that are specific to your environmentPopulate Risk Solutions via intake and custom responses via ingestion or copy/paste then review in Paramify to evaluate best use of content as Custom Responses (project specific) or Risk Solutions (global).
Using Just Custom ResponsesUpload your existing SSP or copy and paste your own control implementation statements into Custom Responses for each control requirement

Risk Solution Guiding Principles

What is a Risk Solution:

  1. Describe a security capability that addresses the who, what, how, and when
  2. Standardized language that is catalog-agnostic to fulfill multi-catalog set of requirements
  3. Flexible and agile to lift and replace the who, what, and when elements as the business evolves
  4. Defines shared risk ownership across the organization and leveraged third party providers

Steps to Convert Custom / Existing Responses to Risk Solutions Architecture

  1. Initial Intake based on Existing SSP

    • Perform self-served intake / SSP ingestion to define elements and Risk Solutions inventory from existing SSP
    • Import all elements and Risk Solutions inventory based on existing SSP into client's workspace
    • Apply suggested Risk Solutions produced from step #1 to list of all security objective catalog requirements
  2. Defining Foundation for Security Capabilities

    • Assess what is necessary vs. superfluous in existing custom response to meet associated control requirement
    • Consolidate multi-component capability existing custom responses to a generic main component capability
    • Define the security capability key elements from existing custom response:
      • Who - primary responsible owner of the capability
        • Multiple Who scenarios:
          • Partially inherited from a third party provider + Shared internal organizational ownership
          • Customer responsibility + Shared internal organizational ownership
      • What - main component driving the capability (ideally this is owned by the Who party)
      • How - procedures for implementing the capability (driven from the What element potentially in conjunction with other components)
      • When - frequency with which the capability is performed
  3. Content Merge to Risk Solutions Architecture (see proposed template to complete this phase here)

    • Refine suggested Risk Solutions created from the intake process based on outputs of phase #2 (custom responses and Risk Solutions can be viewed together in the controls implementation view as well as the Document Robot eMass deliverable)
    • Associate additional Risk Solutions not mapped to the requirement based on context from custom response not addressed in suggested Risk Solutions

Custom Response vs Risk Solutions

Paramify FeatureRisk SolutionCustom ResponseComments
Response Mapping to Control RequirementGlobal capabilities that can be mapped to multiple projects and multiple control requirements to minimize input and maximize deliverable outputsProject and control requirement specific mapping
Collaborator functionality (Solution Owners)Capability or solution owner is given restricted access to view and/or edit their Risk Solutions as the approach or the people, places, and things change for the Risk Solution. The Review status is automatically updated to "Not reviewed" so the GRC Admin or ISSO can review the changes, make updates as needed, and mark the latest version of the Risk Solution as "Reviewed"N/A
Appendix A GenerationEach capability will have a distinct origination and implementation status. The overall control implementation status will be the least of all applicable Risk SolutionsEach custom response will have a distinct implementation status but can have multiple originations. The custom response should include all applicable originations or be comprehensive across custom responses. The overall control implementation status will be the least of all applicable custom responses
PoliciesN/AN/AControl Parameters are the only input - all other details are hardcoded
ProceduresCapability is describing how things are done so it can be leveraged to produce the procedure documentReads as a control response rather than how the capability is performed
CISEach capability will have a distinct origination and implementation status. The overall control implementation status will be the least of all applicable Risk SolutionsEach custom response will have a distinct implementation status but can have multiple originations. The custom response should include all applicable originations or be comprehensive across custom responses. The overall control implementation status will be the least of all applicable custom responses
CRMA single Risk Solution can be used but there must be two narratives, 1) Internal role responsibility and 2) Customer Managed role responsibility. Origination for the relevant custom response or Risk Solution should be Configured by Customer or Provided by CustomerNeed a distinct custom response to capture the customer responsibility or the response inclusive of multiple responsible parties will be captured in the CRM
Automatic Mode (Project Overview: User Summary Table, Interconnections, Systems Ports, Protocols, & Services, and Leveraged Authorizations)Not SpecificNot SpecificWhen an element is mentioned in the Risk Solution or custom response and automatic mode is enabled, then the Project Overview section will limit the elements documented in the SSP to those mentioned components.
Review: Custom Response vs Risk SolutionReviewed in the Risk Solution view. Overall Review progress for Risk Solutions is available in the Risk Solutions viewReviewed in the control implementation view. Review status is only available control by control. There is not an overall review status dashboard
Organization by Family & Subfamily or Control FamilyRisk Solutions can be organized by family and subfamily. The Risk Solution may be mapped to multiple control families.Custom responses are control requirement specific so they would only be assigned a family and subfamily upon conversion to a Risk Solution. The custom response will be specific to the control family for which the control requirements is relevant
FedRAMP Rev 4 to Rev 5 Automated TransiitonParamify's Risk Solutions broach both Rev 4 and Rev 5 control requirements enabling a Rev 4 project to be converted to a Rev 5 Project with the click of a button.Custom responses are specific to the control requirement for Rev 4 or Rev 5, not both.
CrosswalkCrosswalk is mapped by Risk Solution.Custom responses by design are specific to a control requirement within a framework.
MentionsNot SpecificNot SpecificLinks custom responses and Risk Solutions to the elements; Enable Automatic Mode deliverables

TX-RAMP Documents

Which TX-RAMP documents are automated by Paramify today?

Paramify's goal is to generate all feasible TX-RAMP documents for the user. The table below outlines the current progress.

For the documents indicated in the column titled Template Available, the template is available for downloaded within the Paramify platform in the relevant Attachment page.

DocumentParamify GeneratedTemplate AvailableManual/Custom
System Security Plan (SSP)
Boundary & Data Flow Diagram✅ - Part of SSP
Roles & Permissions Matrix✅ - Part of SSP
Security Policy - Access Control (AC)
Security Policy - Awareness and Training (AT)
Security Policy - Audit and Accountability (AU)
Security Policy - Security Assessment and Authorization (CA)
Security Policy - Configuration Management (CM)
Security Policy - Contingency Planning (CP)
Security Policy - Identification and Authentication (IA)
Security Policy - Incident Response (IR)
Security Policy - Maintenance (MA)
Security Policy - Media Protection (MP)
Security Policy - Physial and Environmental Protection (PE)
Security Policy - Planning (PL)
Security Policy - Personnel Security (PS)
Security Policy - Risk Assessment (RA)
Security Policy - System and Services Acquisition (SA)
Security Policy - System and Communications Protection (SC)
Security Policy - System and Information Integrity (SI)
SSP Attachment: Incident Response Plan
SSP Attachment: Information System Contingency Plan
SSP Attachment: Configuration Management Plan
SSP Attachment: Control Implementations✅ - Part of Controls Matrix
SSP Attachment: CIS Matrix✅ - Part of Controls Matrix
SSP Attachment: Inventory Workbook✅ - significant inputs required - Part of Controls Matrix
SSP Attachment: Laws & Regulations✅ - Part of Controls Matrix
SSP Attachment: Rules of Behavior
SSP Attachment: Separation of Duties Matrix*
SSP Attachment: Continuous Monitoring Plan*

* Paramify added Attachments to simplify responses to Access Controls around least privilege, separation of duties, and continuous monitoring.

Refer to TX-RAMP Overview and TX-RAMP Vendor Guide - Completing TX-RAMP Assessment Questionnaire from dir.texas.gov to confirm requirements.

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