Authorization to Operate (ATO) Support for AWS | Federal NIST RMF

Federal civilian agencies operating under FISMA must apply the NIST Risk Management Framework (RMF) to systems deployed on AWS while accounting for FedRAMP-authorized cloud service provider (CSP) controls, agency common controls, and hybrid enterprise architectures. Achieving an Authorization to Operate (ATO) is a complex process requiring not only technical alignment of security controls, but also thoughtful coordination across people, processes, and technologies within the agency’s existing governance and IT ecosystem.

Triple Point Security Authorization to Operate (ATO) Support for AWS applies a human-centered, risk-informed approach to each step of the RMF, tailored to the agency’s mission, security maturity, and risk tolerance. We possess proven experience working collaboratively across federal ISSOs, CISOs, system owners, and engineering teams to ensure the authorization process reflects how the system is actually designed, operated, and sustained. Our support can be scoped to new and existing systems, as well as initial ATO applications, updates due to significant boundary or architecture changes, and reauthorization.

RMF Step 0: Prepare

We begin by aligning stakeholders on scope, decision-making, and expectations. This includes clarifying authorization goals (i.e. initial ATO vs. reauthorization vs. significant change), identifying applicable policies and common controls, and establishing a practical plan for evidence collection that fits the agency’s preferred governance, risk, and compliance (GRC) tooling and documentation norms. We also identify high-risk areas early, such as identity federation, boundary complexity, data flows, and shared responsibility assumptions, so teams can prioritize mitigations with the greatest impact on authorization outcomes.

RMF Step 1: Categorize the System

We support agencies in defining system boundaries, information types, and impact levels in a way that reflects real operational use, not theoretical architectures. This includes accounting for hybrid environments that integrate AWS-native services with on-premises identity providers, enterprise services, and shared general support systems (GSS), as well as understanding how agency risk appetite and mission context influence categorization decisions.

RMF Step 2: Select Security Controls

We assist with selecting and tailoring controls based on the system categorization, leveraging FedRAMP-authorized AWS services, agency-defined baselines, and common control providers. Our approach emphasizes control inheritance wherever possible to reduce duplication, while ensuring system-specific responsibilities are clearly understood by engineering and security teams and adequately documented.

RMF Step 3: Implement Security Controls

We work alongside technical teams to align control implementations with AWS-native architectures and operational realities. This includes integrating identity federation, logging, monitoring, and configuration management across AWS and enterprise environments. Documentation is developed to accurately reflect implementations, using agency-approved templates, parameters, and existing policy artifacts.

RMF Step 4: Assess Security Controls

We support readiness for assessment by helping teams validate that control implementations are testable, defensible, and consistent across technical and documentation layers. This includes coordinating with assessors, preparing evidence, and resolving gaps in a manner aligned with agency risk tolerance and authorization expectations.

RMF Step 5: Authorize the System

We assist agencies in navigating the authorization decision process by ensuring risk is clearly articulated, understood, and contextualized for authorizing officials (AOs). Our focus is on supporting informed risk decisions rather than forcing artificial compliance, helping leadership understand residual risk in operational terms and make effective determinations concerning risk acceptance and mitigation as part of the authorization decision.

RMF Step 6: Monitor Security Controls

While this offering is focused on achieving an initial or updated ATO, our approach establishes a strong foundation for continuous monitoring. We help agencies position themselves for data calls and audits, future system changes, pilot-to-production transitions, and sustained operations by aligning continuous monitoring requirements with AWS capabilities, cloud-native and hybrid services, and agency processes.

This service supports systems hosted on AWS and AWS GovCloud (US) and relates directly to AWS services commonly used in federal environments, including identity and access management (IAM), logging and monitoring, configuration management, and security services. We are tool-agnostic and operate within an agency’s existing governance ecosystem, including using existing agency GRC platforms, inheritance matrices, and other documentation.