FedRAMP authorization built on continuous evidence.
Not on periodic documentation.
Narrative documentation fails the 3PAO.
The FedRAMP authorization process requires a Cloud Service Provider to demonstrate, through an accredited Third Party Assessment Organization, that the system meets the FedRAMP security baseline. The Moderate baseline draws from NIST SP 800-53 Rev 5 and currently encompasses 325+ controls.
The 3PAO assesses using NIST SP 800-53A methods — examine, interview, and test. For each control, the assessment team needs documentary evidence, configuration artifacts, or system demonstrations to satisfy the assessment objective.
Authorization packages built primarily on narrative documentation fail in two ways. First, narrative is assertion. The assessor must determine independently whether the narrative accurately describes the system. Second, narrative goes stale. A CSP whose team changes, infrastructure evolves, or configuration drifts between the time the SSP was written and the time of assessment has a documentation problem and a credibility problem simultaneously.
FedRAMP 20x compounds this. RFC-0024 requires machine-readable OSCAL packages by September 30, 2026 for all FedRAMP providers. OSCAL is a structured data format — it cannot be produced by writing prose and converting it. It must be generated from structured assessment data. Providers without a pipeline to produce OSCAL from system facts will not meet the deadline.
RFC-0024 mandates OSCAL packages for all FedRAMP providers.
RFC-0024 mandates machine-readable OSCAL authorization packages for every FedRAMP provider — not only 20x participants. Providers who cannot produce OSCAL-formatted assessment packages by this date do not maintain FedRAMP authorization status. Static SSP narrative does not satisfy the requirement.
Source: RFC-0024, GSA FedRAMP automation
Continuous monitoring is a contract condition.
FedRAMP authorization is not a one-time certification. The authorization boundary is maintained through a continuous monitoring program defined at authorization and executed monthly. Deliverables include: updated POA&M, current vulnerability scan results, system change reporting, and updated inventory.
Missing a monthly ConMon deliverable is a compliance deficiency that the sponsoring agency must report to the FedRAMP PMO. Sustained ConMon failures can result in authorization revocation.
NIST SP 800-137 defines continuous monitoring as maintaining ongoing awareness of information security to support organizational risk management decisions. The FedRAMP ConMon program operationalizes this definition with specific deliverable formats and frequencies.
REAEGIS generates ConMon packages on schedule: updated POA&M from live tracking, current scan results from the evaluation record, change reports from the CCB audit trail, and inventory from the SBOM. The package is assembled, signed, and ready for delivery without manual compilation.
Authorization is not a destination.
It is a system property.
REAEGIS is the infrastructure that maintains it — converting every commit, scan, and approval into evidence your Authorizing Official can act on.
