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Continuous monitoring strategy

The team conducts ongoing security monitoring and assessment of, based on the continuous monitoring process described in NIST SP 800-137 Information Security Continuous Monitoring for Federal Information Systems and Organizations. This is part of ensuring that we meet FedRAMP requirements.

This page documents policies and procedures related to continuous monitoring. It’s adapted from the Continuous Monitoring Strategy Guide available from FedRAMP.


Within the FedRAMP Security Assessment Framework, once an authorization has been granted,’s security posture is monitored according to the assessment and authorization process. Monitoring security controls is part of the overall risk management framework for information security and is a requirement for to maintain a security authorization that meets the FedRAMP requirements.

Traditionally, this process has been referred to as “Continuous Monitoring” as noted in NIST SP 800-137 Information Security Continuous Monitoring for Federal Information Systems and Organizations. Other NIST documents such as NIST SP 800-37, Revision 1 refer to “ongoing assessment of security controls”. It is important to note that both the terms “Continuous Monitoring” and “Ongoing Security Assessments” mean essentially the same thing and should be interpreted as such.

Performing ongoing security assessments determines whether the set of deployed security controls in a cloud information system remains effective in light of new exploits and attacks, and planned and unplanned changes that occur in the system and its environment over time. To maintain an authorization that meets the FedRAMP requirements, must monitor their security controls, assess them on a regular basis, and demonstrate that the security posture of their service offering is continuously acceptable.

Ongoing assessment of security controls results in greater control over the security posture of the system and enables timely risk-management decisions. Security-related information collected through continuous monitoring is used to make recurring updates to the security assessment package. Ongoing due diligence and review of security controls enables the security authorization package to remain current which allows agencies to make informed risk management decisions as they use cloud services.


The FedRAMP continuous monitoring program is based on the continuous monitoring process described in NIST SP 800-137, Information Security Continuous Monitoring for Federal Information Systems and Organization. The goal is to provide: (i) operational visibility; (ii) managed change control; (iii) and attendance to incident response duties. For more information on incident response, review the FedRAMP Incident Communications Procedure.

The effectiveness of’s continuous monitoring capability supports ongoing authorization and reauthorization decisions. Security-related information collected during continuous monitoring is used to make updates to the security authorization package. Updated documents provide evidence that FedRAMP baseline security controls continue to safeguard the system as originally planned.

As defined by the National Institute of Standards and Technology (NIST), the process for continuous monitoring includes the following initiatives:

  • Define a continuous monitoring strategy based on risk tolerance that maintains clear visibility into assets and awareness of vulnerabilities and utilizes up-to-date threat information.
  • Establish measures, metrics, and status monitoring and control assessments frequencies that make known organizational security status and detect changes to information system infrastructure and environments of operation, and status of security control effectiveness in a manner that supports continued operation within acceptable risk tolerances.
  • Implement a continuous monitoring program to collect the data required for the defined measures and report on findings; automate collection, analysis and reporting of data where possible.
  • Analyze the data gathered and Report findings accompanied by recommendations. It may become necessary to collect additional information to clarify or supplement existing monitoring data.
  • Respond to assessment findings by making decisions to either mitigate technical, management and operational vulnerabilities; or accept the risk; or transfer it to another authority.
  • Review and Update the monitoring program, revising the continuous monitoring strategy and maturing measurement capabilities to increase visibility into assets and awareness of vulnerabilities; further enhance data driven control of the security of an organization’s information infrastructure; and increase organizational flexibility.

Security control assessments performed periodically validate whether stated security controls are implemented correctly, operating as intended, and meet FedRAMP baseline security controls. Security status reporting provides federal officials with information necessary to make risk-based decisions and provides assurance to existing customer agencies regarding the security posture of the system.

Roles and responsibilities

Authorizing Official

Authorizing Officials and their teams (“AOs”) serve as the focal point for coordination of continuous monitoring activities for must coordinate with their AOs to send security control artifacts at various points in time. The AOs monitor both the Plan of Action & Milestones (POA&M) and any major significant changes and reporting artifacts (such as vulnerability scan reports) associated with the service offering. AOs use this information so that risk-based decisions can be made about ongoing authorization. Agency customers must perform the following tasks in support of continuous monitoring:

  • Notify if the agency becomes aware of an incident that has not yet reported.
  • Provide a primary and secondary POC for and US-CERT as described in agency and Incident Response Plans.
  • Notify US-CERT when reports an incident.
  • Work with to resolve incidents; provide coordination with US-CERT if necessary.
  • Notify FedRAMP ISSO of incident activity.
  • Monitor security controls that are agency responsibilities. During incident response, both and leveraging agencies are responsible for coordinating incident handling activities together, and with US-CERT. The team-based approach to incident handling ensures that all parties are informed and enables incidents to be closed as quickly as possible.


The FedRAMP Program Management Office (PMO) acts as the liaison for the Joint Authorization Board for ensuring that CSPs with a JAB P-ATO strictly adhere to their established Continuous Monitoring Plan. The JAB and FedRAMP PMO only perform Continuous Monitoring activities for those CSPs that have a JAB P-ATO.

Department of Homeland Security (DHS)

The FedRAMP Policy Memo released by OMB defines the DHS FedRAMP responsibilities to include:

  • Assisting government-wide and agency-specific efforts to provide adequate, risk-based and cost-effective cybersecurity.
  • Coordinating cybersecurity operations and incident response and providing appropriate assistance.
  • Developing continuous monitoring standards for ongoing cybersecurity of Federal information systems to include real-time monitoring and continuously verified operating configurations.
  • Developing guidance on agency implementation of the Trusted Internet Connection (TIC) program for cloud services.

The FedRAMP PMO works with DHS to incorporate DHS’s guidance into the FedRAMP program guidance and documents.

Third Party Assessment Organization (3PAO)

Third Party Assessment Organizations (3PAO) are responsible for independently verifying and validating the control implementation and test results for in the continuous monitoring phase of the FedRAMP process. Specifically, 3PAOs are responsible for:

  • Assessing a defined subset of the security controls annually.
  • Submitting the assessment report to the ISSO one year after’s authorization date and each year thereafter.
  • Performing announced penetration testing.
  • Perform annual scans of web applications, databases, and operating systems.
  • Assessing changed controls on an ad hoc basis as requested by the AOs for any changes made to the system by the

In order to be effective in this role, 3PAOs are responsible for ensuring that the chain of custody is maintained for any 3PAO authored documentation. 3PAOs must also be able to vouch for the veracity and integrity of data provided by the for inclusion in 3PAO authored documentation. As an example:

  • If scans are performed by, the 3PAO must either be on site and observe performing the scans or be able to monitor or verify the results of the scans through other means documented and approved by the AO.
  • Documentation provided to must be placed in a format that either cannot alter or that allows the 3PAO to verify the integrity of the document. team

Team responsibilities

The team is responsible for implementing, verifying, and validating the continuous monitoring strategy.

The Program Manager coordinates the tasks needed for the continuous monitoring strategy. They guide the team in assigning necessary tasks to team members in an agile way, including individuals on the Cloud Operations sub-team.

The team achieves its continuous monitoring strategy primarily by implementing and maintaining a suite of automated components, with some manual tasks to assist with documenting and reporting to people outside the core team.

Automated components

The team has implemented a suite of automated components to provide continuous monitoring of the system:

  • Metric types and system components that automatically monitor these metrics: The system has automated components that continuously monitor system metrics:
    • Performance metrics:
      • Grafana/Prometheus: Cloudfoundry performance and health metrics are shipped to Grafana and Prometheus, which has alerts configured for defined rules
    • Job / program health:
      • BOSH Health Monitor (health-monitor)
    • Malicious code detection:
      • ClamAV: detects trojans, viruses, malware, and other malicious threats. This runs continuously; files are scanned when they are written/accessed.
    • Network intrusion detection:
      • Snort: continuously monitors network traffic, signatures, and behaviors, and raises alerts based on defined rules.
    • Intruder detection / file integrity:
      • AIDE: Performs file alteration checks on all virtual machines on initial deploy and an hourly basis thereafter. Violations are shipped to our central alert system.
    • Patch / vulnerability scanning:
      • Nessus: runs nightly to scan for OS and database vulnerabilities.
      • OWASP ZAP: runs monthly to scan for web application vulnerabilities.
  • Monitoring of the monitoring components: The team uses BOSH as an automated way to continuously monitor the six monitoring components. (BOSH is an open source tool for release engineering, deployment, lifecycle management, and monitoring of distributed systems. BOSH allows individual developers and teams to easily version, package and deploy software in a reproducible manner.)
  • Continuous deployment of the monitoring components: The team uses Concourse to provide automated continuous deployment of the components, to ensure the components stay up to date. In addition, one component, Nessus, has self-updating capabilities.
  • Static code analysis: The team uses the following code scanning tools:
    • Terraform: terraform validate

Manual components

The continuous monitoring strategy also includes manual tasks that are accomplished by team members, including:

  • The team updates our POA&M document in an access-controlled GSA Google Drive document.
    • All system components are running on Amazon Web Services and tracked with BOSH or Terraform, so we generate the system inventory using those resources. Then we manually add the inventory to the POA&M document.
  • The team submits deliverables to FedRAMP on time.

Process areas

Operational visibility

In order to maintain operational visibility, the continuous monitoring program provides reports to the AOs at least monthly. These deliverables include:

  • Condition of previous findings
  • Weaknesses identified since the last assessment
  • Known or suspected testing/continuous monitoring failures
  • Newly discovered vulnerabilities, zero-day attacks, or exploits

Change control is a dynamic system in a constant state of change. Configuration management and change control processes help maintain the secure baseline configuration of the architecture. Routine day-to-day changes are managed through the change management process described in the configuration management plan. notifies the AO with a minimum of 30 days before implementing any planned major significant changes, including an analysis of the potential security impact.

See the significant change rubric for how we determine whether a change is routine or significant.

Incident response

All incident response must be handled according to the incident response guide.

Monthly reporting summary

As described in the FedRAMP requirements, must provide monthly reports of all vulnerability scanning to authorizing officials for review and tracking these vulnerabilities within the POA&Ms. These deliverables are really a subset of the evidence required at time of authorization. In this vein, the analysis of these scan results should be performed in the same manner they were for time of authorization. In particular, this means:

  • All scan findings must be documented (including low findings)
  • Each unique vulnerability is tracked as an individual POA&M item
  • Deviation requests must be submitted for any requested changes to scan findings (e.g. risk adjustments, false positives, and operational requirements)

We use our Continuous Monitoring Checklist Template to help us deliver these monthly updates.

On a monthly basis, Authorizing Officials will be monitoring these deliverables to ensure that maintains an appropriate risk posture -– which typically means the risk posture stays at the level of authorization or improves. As a part of any authorization letter, is required to maintain a continuous monitoring program. This analysis on a monthly basis leads to a continuous authorization decision every month by Authorizing Officials.

Quarterly Security Policy and Account Review performs quarterly security policy and account reviews to satisty various AC, AU and CM controls. The purpose of these reviews is to confirm that all members of the cloud Operations team require their level of access, and that the team reviews the content on the publicly accessible information system for nonpublic information and removes such information if discovered. During the account review meetings, also reviews its continuous monitoring strategy and identifies areas for improvements.

Appendix: Significant change rubric

We follow this rubric for changes before they are deployed to production. This is part of the Security Impact Analysis step of our Feature Lifecycle. This rubric supports controls including CA-6 (c), CM-2 (1), and RA-3.

When no discussion or SCR (Significant Change Request) is needed for a change

No timeline required.

The change:

  • Fits our existing SSP control descriptions, diagrams, and attachments, as well as our policies and procedures (including our configuration management plan). No updates to the SSP would be necessary to reflect the change.

This includes:

  • Integrating routine updates to existing upstream open source system components, including updates that resolve CVEs, fix bugs, add new features, and/or update the operating system.
  • Routine updates to existing open source components that we maintain, such as fixing bugs and improving security and reliability.
  • Improvements to the configuration of services and system components.
  • Improving our implementations in excess of the minimum requirements described in our SSP control descriptions.
  • Using a new feature of an approved external service that we already use (where the feature doesn’t change our SSP or risk posture).


  • BOSH stemcell update that fixes CVEs
  • Buildpack updates that don’t change security model
  • User documentation updates
  • Most dashboard updates (not major changes that may have security impact)
  • Configuring platform alerts to be more specific or precise
  • Adding platform alerts
  • Adding automated tests to any component
  • Adjusting configuration or number of platform “virtual machine” components, such as disk size (not major changes to configuration that may have security impact, such as a whole different operating system)
  • An upstream open source component integrates a new dependency

When a change should be discussed with our JAB TRs (Technical Representatives)

Start the discussion when we identify that we want to make this kind of change. Must be discussed at least one week ahead of planned change.

The change fits one or more of the following criteria:

  • Requires minor clarifications to SSP control descriptions, diagrams, or attachments - not changing the substance of implementation of a requirement.
  • Relaxes requirements in our policies and procedures.
  • Adds or removes a point of contact for our system (a named person in our SSP, such as a new System Owner).

This includes:

  • Changes to some aspect of our external system boundary, such as ports, that don’t change the risk posture.
  • Removing use of an external service.
  • Minor updates (that don’t have security impact) to roles and authorized privileges listed in the Types of Users table.
  • Removing internal dependencies. (In other words, simplifying a diagram.)
  • Exposing a new brokered service or service plan for customers.


  • Changing a substantial aspect of our logging that isn’t required by our SSP.
  • Using an additional aspect of an existing protocol that we already use.
  • Changing a substantial aspect of how we manage free trial (sandboxes) spaces.
  • Adding an additional service plan to an AWS service that we already broker.
  • Adding a high-availability plan to a service that operates.

When a change requires an approved SCR but not 3PAO testing

SCR must be submitted at least 30 days ahead of planned change.

The change:

  • Would require changing the SSP in a non-trivial way (such as updating the control descriptions, diagrams, tables, or attachments to reflect the new or changed functionality), but it primarily uses existing 3PAO-tested features in AWS or to implement the change.

This includes:

  • Integrating a new external service that has a FedRAMP Moderate or higher authorization, using an existing integration system.
  • Adding a new component to the system inside the authorization boundary that doesn’t substantially change the risk posture.
  • Integrating a new open source codebase that we’ve reviewed according to our procedures.


  • Integrating a new service that is FedRAMP Authorized in AWS GovCloud.

When a change requires both an approved SCR and 3PAO testing

SCR must be submitted at least 30 days ahead of planned change.

The change fits one or more of the following criteria:

  • Changes the system boundary by adding a new component that substantially changes the risk posture.
  • Changes our risk posture in a major way not reflected in our SSP.

This includes:

  • Integrating a new external service that does not have a FedRAMP Moderate or higher authorization.
  • Integrating a new external service using a new integration system.
  • Adding new brokered services that we operate.
  • Exposing new services on new domains or IP ranges.
  • Modifications to cryptographic modules or services.


  • Adding a built-in Continuous Integration / Continuous Deployment service (such as providing brokered Concourse to tenant applications).
  • Giving customer agencies a way to restrict network requests from agency staff to a specific set of IP origins, to support their TIC compliance.

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