When FedRAMP withdrew its proposed requirement for cloud service providers to report assessment costs, it didn't just kill RFC-0019. It clarified where the regulatory line stops and where your commercial relationships begin. However, this withdrawal doesn't eliminate your compliance obligations under 44 USC § 3609. It changes how FedRAMP will fulfill its duty to review assessment service costs.
This checklist helps you verify your assessment documentation practices still meet FedRAMP requirements after RFC-0019's withdrawal and prepares you for what oversight mechanisms FedRAMP might use instead.
Prerequisites
Before using this checklist, confirm:
- Your organization holds an active FedRAMP authorization or is pursuing one through the FedRAMP Connect process.
- You've engaged a FedRAMP-recognized Third-Party Assessment Organization.
- You maintain a commercial agreement with your assessment organization that defines scope, deliverables, and cost structure.
- You understand which assessment artifacts FedRAMP still requires in your authorization package per the FedRAMP Rev 5 baseline.
Assessment Documentation Requirements (Post-RFC-0019)
1. Verify Your Assessment Agreement Protects Proprietary Cost Information
Done when: Your contract with your Third-Party Assessment Organization treats pricing, rate cards, and total assessment costs as proprietary business information not subject to government disclosure.
What good looks like: Your agreement includes confidentiality clauses that prevent either party from disclosing commercial terms without written consent. Confirm with your legal team that no FedRAMP requirement compels disclosure of these specific cost figures.
2. Confirm Your Security Assessment Plan Documents Scope Without Cost Detail
Done when: Your Security Assessment Plan (SAP) defines assessment scope, control families tested, sampling methodology, and timeline, but contains no line items, hourly rates, or total cost projections.
What good looks like: A FedRAMP reviewer can understand exactly what your assessor will test and how, but cannot extract what you're paying. Your SAP meets NIST SP 800-53A Rev 5 assessment procedure requirements without becoming a cost proposal.
3. Document Your Assessment Organization Selection Process
Done when: You maintain internal records showing how you selected your Third-Party Assessment Organization, including evaluation criteria that demonstrate due diligence beyond cost alone.
What good looks like: Your procurement file shows you evaluated assessor qualifications, prior FedRAMP experience, technical depth in your service model, and timeline feasibility. If FedRAMP later questions assessment quality, you can demonstrate your selection was based on capability, not lowest bid.
4. Retain Evidence of Assessment Scope Negotiation
Done when: You have documentation showing how you and your assessor arrived at the final assessment scope, including any scope reductions, additions, or clarifications.
What good looks like: Email threads, meeting notes, or scope change logs that show both parties agreed on what controls require testing, what evidence satisfies each control, and where sampling applies. This protects you if FedRAMP later questions whether your assessment was comprehensive.
5. Verify Your Security Assessment Report Contains No Cost References
Done when: Your final Security Assessment Report (SAR) describes findings, risk ratings, and recommendations without mentioning assessment duration in billable hours, cost per finding, or total engagement value.
What good looks like: Your SAR focuses entirely on security posture. Any references to effort are framed as "assessment activities conducted over X weeks" rather than cost metrics.
6. Prepare for FedRAMP's Alternative Cost Oversight Methods
Done when: You understand that FedRAMP will now "rely on limited publicly available information to review the cost of assessment services" and you've identified what public information about your authorization might be visible.
What good looks like: You know whether your company publicly discloses government contract values, whether your assessor markets typical engagement costs, and whether industry surveys or analyst reports might reference your authorization timeline. You're not surprised if FedRAMP references these sources in future policy discussions.
7. Track Your Own Assessment Cost Metrics Internally
Done when: You maintain internal financial records that let you compare assessment costs across your FedRAMP baseline (Low/Moderate/High), track cost-per-control trends, and evaluate assessor efficiency over time.
What good looks like: When your CFO asks whether your FedRAMP assessment was cost-effective, you have data. When you pursue your next authorization or annual assessment, you can negotiate from a position of knowledge. You're using the cost visibility FedRAMP chose not to mandate.
8. Review Your Continuous Monitoring Cost Structure
Done when: Your ongoing assessment costs under Continuous Authorization are documented separately from initial authorization costs, with clear attribution to monthly continuous monitoring activities versus annual assessment updates.
What good looks like: You can explain to leadership exactly what continuous monitoring costs annually and why, without conflating it with initial authorization expenses. Your finance team understands the recurring nature of FedRAMP compliance.
Common Mistakes
Assuming RFC-0019's withdrawal means FedRAMP won't scrutinize assessment quality. FedRAMP's duty under 44 USC § 3609(a)(10)(A) to review assessment costs hasn't changed. The withdrawal means they won't collect cost data directly from you, but they'll still evaluate whether assessment services deliver value.
Treating all assessment documentation as confidential. Your Security Assessment Plan and Security Assessment Report are required FedRAMP deliverables. Only the commercial terms of your assessor agreement are proprietary. Don't withhold technical assessment documentation under a misguided belief that RFC-0019's withdrawal expanded confidentiality protections.
Failing to document why your assessment scope differs from similar providers. RFC-0019 commenters noted that assessment costs vary widely based on scope and complexity. If your assessment took significantly longer or cost substantially more than peers, document the technical reasons. FedRAMP may not collect your costs, but they will notice if your authorization timeline is an outlier.
Ignoring the 30 commenters who shaped this decision. The withdrawal came after 48 comments from 30 distinct parties. FedRAMP listened. If future RFCs propose requirements you consider unreasonable, the comment process works. Use it.
Next Steps
Audit your current assessment documentation against items 1-5 above within the next 30 days. If cost details appear in any FedRAMP-submitted artifact, work with your assessor to remove them in your next update cycle.
Establish internal cost tracking per item 7 if you don't already maintain it. You need this data for your own financial planning even if FedRAMP doesn't require it.
Monitor FedRAMP's future approach to fulfilling its statutory cost review obligation. The withdrawal notice explicitly states FedRAMP "will only be able to rely on limited publicly available information." Watch for guidance on what that means in practice.
Preserve your RFC-0019 comment if you submitted one. It's now part of the public record showing industry concerns about proprietary business information in regulatory oversight. Reference it if similar proposals emerge.
Prepare for the possibility of reconsideration. The notice states "this determination may be reconsidered in the future, however a new public comment period would be required." Don't assume RFC-0019 is permanently dead. Keep your rationale for protecting cost information current.
The line between regulatory oversight and commercial relationships isn't always obvious. RFC-0019's withdrawal clarifies that your assessment costs fall on the commercial side. Your job is to ensure everything else FedRAMP actually needs remains clearly documented and accessible.
