Preparing for FedRAMP OSCAL-Based Assessments

FedRAMP has become the gold standard for securing cloud services used by U.S. federal agencies. With the introduction of the Open Security Controls Assessment Language (OSCAL), FedRAMP assessments are transforming toward automation, consistency, and scalability. 

OSCAL-based mastering evaluations are critical for organizations pursuing FedRAMP authorization. They streamline compliance efforts and reduce time to market. This article provides a detailed roadmap for experts preparing for OSCAL-driven FedRAMP assessments, covering technical workflows, tooling, and strategic considerations.

What Is OSCAL?

OSCAL is a standardized, machine-readable framework developed by the National Institute of Standards and Technology (NIST) to modernize and automate cybersecurity compliance workflows. It is a universal "language" for defining, implementing, and assessing security controls across frameworks like CMMC, FedRAMP, and NIST SP 800-53.

Understanding OSCAL’s Role in FedRAMP

OSCAL, developed by NIST, is a machine-readable language designed to represent compliance documentation in formats like XML, JSON, and YAML. For FedRAMP, OSCAL standardizes how CSPs and 3PAOs document and exchange security control implementations, assessment plans, and results.

OSCAL supports this standardization with: 

Automated Compliance Reporting

• Traditional FedRAMP assessments involve extensive documentation in Word and Excel.
• OSCAL transforms this into structured XML, JSON, or YAML files, making it easier to validate security controls programmatically.

Standardized Security Artifacts

• CSPs submit security authorization packages in OSCAL format.
• Includes System Security Plans (SSPs), Security Assessment Plans (SAPs), and Security Assessment Reports (SARs) in a structured, machine-readable form.

Streamlined Authorization Process

• Reduces manual effort in control validation and risk assessment.
• Enables automated compliance checks and quicker Authority to Operate (ATO) decisions.

Interoperability with NIST 800-53 & FedRAMP Controls

• Maps directly to NIST 800-53 security controls and FedRAMP baselines.
• Ensures consistency across different cloud providers and agencies.

Enhances Security & Transparency

• Reduces human errors in assessment documentation.
• Facilitates continuous monitoring by automating control validation. 

By transitioning from static PDFs to OSCAL’s data-centric approach, CSPs enable real-time validation, automated gap analysis, and seamless collaboration with assessors.

OSCAL Integration into the FedRAMP Authorization Process

FedRAMP’s security assessment and authorization process involves multiple stages, requiring extensive documentation and verification. OSCAL automates these stages, enhancing efficiency and accuracy. Below is a breakdown of how OSCAL enhances each phase.

Preparing the OSCAL Security Authorization Package

CSPs seeking FedRAMP compliance must prepare a security authorization package, which includes the following:

• System Security Plan (SSP): Outlines security controls and implementation details.
• Security Assessment Plan (SAP): Defines the methodology for testing security controls.
• Security Assessment Report (SAR): Documents assessment results, findings, and risk levels.
• Plan of Action & Milestones (POA&M): Identifies and tracks remediation steps for vulnerabilities.

Previously, CSPs compiled these documents manually using Word and Excel spreadsheets, requiring extensive formatting and human review. With OSCAL, CSPs generate these documents in structured JSON, XML, or YAML formats. 

The benefits of this approach include:

• Standardized data that can be easily parsed and validated by compliance tools.
• Automation of security control mapping to FedRAMP baselines and NIST 800-53.
• Elimination of manual errors caused by formatting inconsistencies.

3PAO Assessment and Validation

To achieve FedRAMP authorization, CSPs must undergo an independent security assessment conducted by a Third-Party Assessment Organization. The 3PAO validates that security controls are correctly implemented and meet FedRAMP requirements.

Traditionally,  3PAOs manually review Word and Excel documents. Security control validation often involves time-consuming cross-referencing between multiple files. Finally, the assessment process is prone to inconsistencies and human error.

With the OSCAL process, 3PAOs can instantly use automated tools to validate OSCAL documents. Security controls are checked programmatically, reducing assessment time. Automated mapping to FedRAMP baselines ensures compliance without manual intervention.

FedRAMP PMO and Authorizing Official Review

Once the 3PAO completes its assessment, the FedRAMP Program Management Office (PMO) and Authorizing Officials (AOs) review the CSP’s security package to determine if an Authority to Operate (ATO) can be granted.

The FedRAMP PMO and AOs typically manually review hundreds of pages of security documentation. Inconsistencies or missing details often require back-and-forth revisions, which can delay approvals.

OSCAL changes this: FedRAMP reviewers can instantly use automated validation tools to check compliance. Predefined schemas ensure all required security details are present before submission. Machine-readable data enables quick comparisons across multiple CSP assessments.

Continuous Monitoring with OSCAL

FedRAMP requires CSPs to continuously monitor their security posture, submit updates, and respond to vulnerabilities as they arise.

Under older FedRAMP approaches, CSPs update security control documentation manually in spreadsheets. Periodic audits invariably involve reviewing large sets of static documents, so slow documentation updates may prevent efficient security incident resolution.

With OSCAL, CSPs can automate continuous monitoring with real-time security updates. Security control changes are updated in machine-readable formats for quick processing. Integrations with SIEM tools, vulnerability scanners, and compliance platforms allow for automated risk tracking.

Stay on Top of FedRAMP Automation with Continuum GRC

OSCAL represents a paradigm shift in FedRAMP compliance, replacing manual processes with structured, automatable workflows. For experts, success hinges on the early adoption of OSCAL tooling, collaboration with 3PAOs, and compliance integration into DevOps pipelines.

Continuum GRC is a cloud platform that stays ahead of the curve, including support for all certifications (along with our sister company and assessors, Lazarus Alliance). 

• FedRAMP
• StateRAMP
• NIST 800-53
• FARS NIST 800-171 & 172
• CMMC
• SOC 1 & SOC 2
• HIPAA
• PCI DSS 4.0
• IRS 1075 & 4812
• COSO SOX
• ISO 27001 + other ISO standards
• NIAP Common Criteria
• And dozens more!

We are the only FedRAMP and StateRAMP-authorized compliance and risk management solution worldwide.

Continuum GRC is a proactive cyber security® and the only FedRAMP and StateRAMP-authorized cybersecurity audit platform worldwide. Call 1-888-896-6207 to discuss your organization's cybersecurity needs and learn how we can help protect its systems and ensure compliance.