Feedback From the Front Lines: Where 'FedRAMP Equivalent' Falls Short

The following insights represent real-world feedback I heard from a recognized expert in CMMC compliance who works directly with Defense Industrial Base (DIB) contractors. 

In a discussion about FedRAMP Authorized vs. FedRAMP Equivalent vendors, he asserts that there is a massive difference between the two. As organizations prepare for CMMC 2.0 implementation and face increasing scrutiny regarding their cybersecurity practices, understanding these distinctions has never been more important for risk management and compliance.

With a FedRAMP Equivalent Vendor, Breach Responsibility Is On You. 

Anyone who’s experienced a breach knows that the first few hours are a frenzy, with teams identifying the cause and scrambling to assess the damage. When a breach involves CUI, there are time-sensitive actions that need to be taken, including alerting the DoD. 

If you choose a FedRAMP Equivalent vendor (instead of a FedRAMP Authorized vendor), you are assuming a lot of responsibility in the event of a breach. Simply stated, if your company is doing business with a FedRAMP Equivalent provider like PreVeil and operating under DFARS 252.204-7012(c)-(g), and their service suffers a breach, then you and your company:

• Bear primary responsibility for breaches and cannot shift blame to your cloud service provider
• Are responsible for reporting cloud-related incidents to the DoD, not your provider
• Must provide forensic evidence to the DoD in case of an attack – evidence that you'll need to obtain from your provider

This places an enormous burden on your organization, requiring additional resources, expertise, and a clear strategy to manage these responsibilities effectively.

With a FedRAMP Authorized Vendor, Breach Responsibility Is On Them.

If, however, you are doing business with a FedRAMP Authorized vendor like Virtru, the responsibility for reporting any potential breach shifts significantly:

• The FedRAMP Authorized vendor is responsible for meeting and maintaining security standards (Virtru is FedRAMP Authorized at the Moderate Level).
• In the event of a breach, while there may be some investigation of your company's potential fault, ultimate responsibility for security standards adherence falls on the FedRAMP Authorized vendor.
• If there are fines or charges associated with the breach, they fall squarely on the vendor, barring potential wrongdoing on the part of the customer.

While you would still need to report incidents as required by DFARS, the burden of proof regarding security compliance rests with Virtru as the FedRAMP Authorized vendor.  

This is an important distinction between "authorized" and “equivalent” – and alleviates significant cost and complexity that your organization would otherwise have to manage if you were doing business with a FedRAMP equivalent vendor.

Virtru Is the Only FedRAMP Authorized Key Manager for Google Workspace CSE

One additional fact shared by the CMMC expert is this: When it comes to Client-Side Encryption (CSE) for Google Workspace, Virtru stands alone as the only FedRAMP Authorized vendor in this critical space.

While several providers offer CSE key management solutions for Google Workspace, including FlowCrypt, Fortanix, FutureX, Stormshield, and Thales, only Virtru combines this capability with FedRAMP Authorization. This unique position offers DIB contractors an unparalleled advantage:

• Simplified compliance with both FedRAMP and CMMC requirements
• Reduced risk through a fully authorized key management solution, Virtru Private Keystore
• Streamlined reporting obligations in the event of a security incident
• Enhanced protection for sensitive controlled unclassified information (CUI)
  
  

By choosing Virtru for CSE Key Management, DIB contractors gain the dual benefits of robust encryption technology and the compliance assurance that comes with FedRAMP Authorization.

Choosing FedRAMP Authorized Software Over FedRAMP Equivalency 

The distinction between FedRAMP Equivalent and FedRAMP Authorized vendors is clear: DIB contractors can streamline their risk management responsibility by opting for an authorized vendor who has been thoroughly vetted. 

With FedRAMP Equivalent providers like PreVeil, the customer shoulders the burden of ensuring compliance and reporting incidents. With FedRAMP Authorized providers like Virtru, the software vendor bears responsibility for reporting and maintaining FedRAMP standards.

As the only FedRAMP Authorized CSE Key Management solution for Google Workspace, Virtru offers DIB contractors a unique combination of security, compliance, and peace of mind. In today's heightened cybersecurity environment, partnering with a FedRAMP Authorized vendor isn't just a smart choice, it's a strategic necessity for protecting your organization's data and reputation. 

Want to hear more about how Virtru can complement your CMMC strategy with fast-to-deploy, easy-to-use FedRAMP Authorized data security solutions for email and file sharing? Get in touch with our team — we’d love to show you how Virtru can make a difference for your cybersecurity posture.