FedRAMP CSP Authorization Playbook, Version 4.2, Dated 11/17/2025 Comment

[ChanceofClouds]

Hello,

I know the most recently published versions of the FedRAMP CSP Authorization Playbook, Agency Authorization Playbook, and Continuous Monitoring Playbook but thought FedRAMP might appreciate feedback on those and if so through a Github thread opposed to one off emails. Initial thought, in the Continuous Monitoring Playbook, FedRAMP states the following:
"With approval by the agency AO, CSPs may choose to use an independent assessment organization that is not recognized by FedRAMP, such as an agency’s Independent Verification and Validation (IV&V) team. When using an agency’s IV&V team or other third-party assessor that is not a FedRAMP recognized 3PAO, the agency AO must attest to the independence of the assessment organization. In addition, the assessor must comply with FedRAMP requirements and guidance, and use FedRAMP provided templates" and it also points out the following, in the CSP Authorization Playbook: "Per the A2LA R311: Specific Requirements - FedRAMP, 3PAOs contracted to provide advisory services cannot provide assessment services for the same CSO for a period of two years", my question: Does FedRAMP have intentions on making a similar requirement as that for CSPs that utilize non-3PAO organizations so that a CSP could not use the same organization to advise and assess the CSO or will that need to be in an agency contract?

[pete-gov]

Does FedRAMP have intentions on making a similar requirement as that for CSPs that utilize non-3PAO organizations so that a CSP could not use the same organization to advise and assess the CSO or will that need to be in an agency contract?

If an agency authorizing official has a compelling reason to accept the risk of using the same organization that advises a CSO then FedRAMP will not block that - I find this highly unlikely in general, however.

I think a few folks might have over-indexed on this statement as a way to avoid using a FedRAMP recognized 3PAO but agencies have only been interested in doing this in very rare situations when it would be more effective for the agency to use it's own IV&V team to accelerate an assessment for high-need services.