FedRAMP’s draft Boundary Policy introduces a targeted approach to defining,  managing, and assessing authorization boundaries for cloud service offerings. By focusing on critical systems that “handle” federal information, the policy aims to reduce unnecessary burden on stakeholders while minimizing ambiguity and maintaining system security.

In this blog, we’ll break down the key takeaways, policy requirements, and impacts on CSPs and independent assessors (IAs/3PAOs).

Key Takeaways

1. Simplified Boundary Definition

The draft guidance limits the FedRAMP boundary to services and components that:

 - Handle federal information (e.g., create, process, store, transmit).

 - Directly impact the confidentiality, integrity, or availability (CIA) of federal data.

Ancillary services that pose negligible risk to federal systems, such as email or development environments, are excluded from the boundary, reducing unnecessary scope and complexity.

Key Definitions

 - Handling Federal Data: Activities such as creating, processing, storing, or transmitting federal information.

 - Ancillary Services: Services like email systems, development pipelines, and ticketing systems that pose negligible risk to federal systems.

2. Greater Flexibility for CSPs

The updated guidance simplifies boundary determination compared to older drafts, focusing on core services critical to federal information security. This shift allows:

 - More flexibility for CSPs to define boundaries.

 - Reduced ambiguity for assessors and stakeholders without sacrificing security.

3. Stronger Privacy and Data Ownership Protections

The policy introduces stricter rules to protect federal data from unauthorized access and sharing:

 - Data Sharing Restrictions: CSPs cannot reuse or share federal data (e.g., for training AI/ML models) without explicit government approval.

 - Access Controls: External systems are prohibited from directly accessing or modifying federal information within the boundary unless approved by federal information owners.

4. Operational Clarity for CSPs and Agencies

The policy clarifies the division of responsibilities between CSPs and agencies:

 - Customer-managed environments and leveraged services (e.g., IaaS/PaaS configurations) fall outside the FedRAMP boundary but may still require risk consideration.

 - Request for Standardization: Stakeholders have requested examples to improve clarity on how boundary inclusion criteria apply, particularly when leveraging external services.

Key Requirements from the Draft Policy

Boundary Documentation and Updates

 - CSPs must promptly update System Security Plans (SSPs) and continuous monitoring reports to reflect boundary changes (FRR205).

Data Sharing Restrictions

 - CSPs are prohibited from sharing federal data across tenants (e.g., for AI/ML purposes) without explicit opt-in from the government (FRR207).

Information Exchange Agreements

 - All external system interconnections must be documented through detailed agreements specifying encryption methods, protocols, and access levels (FRR209).

Inbound/Outbound Connections

 - No external system may directly access or modify federal data within the boundary without approval from the federal information owner (FRR211).

Independent Assessor Oversight

 - Third-party assessors (3PAOs) must validate data flows and ensure proper categorization of critical and ancillary services within the boundary (FRR217).

What This Means for CSPs

 - Maintain Accurate Documentation: CSPs must update boundary documentation regularly to reflect evolving architectures and data flows.

 - Clarify Ancillary Services: CSPs should ensure that ancillary services posing negligible risk are properly documented and excluded from the FedRAMP boundary.

 - Ensure Compliance with New Rules: CSPs must comply with requirements for data sharing, interconnection agreements, and access controls.

Key Considerations for Independent Assessors (3PAOs)

3PAOs play a critical role in ensuring compliance and proper boundary scoping. They must:

 - Validate Data Flows: Ensure that CSPs have correctly categorized ancillary services and included only critical components in the boundary.

 - Review CSP Documentation: Assess the accuracy of boundary documentation, interconnection agreements, and data flow categorization.

FedRAMP’s Goals with the Boundary Policy

 - Reduce unnecessary burden on CSPs by focusing on critical components that directly handle federal data.

 - Ensure privacy and data protection through stricter rules on data sharing and access controls.

 - Improve operational clarity by defining clear boundaries and responsibilities for CSPs and agencies.

Conclusion

The draft FedRAMP Boundary Policy reflects a significant shift toward a more targeted and manageable approach to authorization boundaries. By focusing on services that “handle” federal information, it reduces the burden on stakeholders while maintaining strong security standards centered around the confidentiality, integrity, and availability (CIA) of federal systems and data.

For full details, review the draft policy at FedRAMP RFC 0004.

Have questions or need guidance on implementing the new boundary requirements? Contact us at info@infusionpoints.com to get expert advice on navigating this policy update.