Steelhead Technologies
FedRAMP Moderate Equivalency — Program Progress
Updated weekly · Last update: June 26, 2026
Program Start
Q1 2026
Program kickoff
Target Authorization
Q4 2026
Authorization target
Controls Scope
325
NIST 800-53 Moderate
Platform Readiness
40%
Compliance platform coverage
Controls Mapped
~200
of 325 controls mapped so far
Active Phases
1 · 2 · 4 · 5
Policy, SSP, Env., Evidence — parallel
Overall Program Progress (5 of 7 phases active or complete)
54%
Program Phases
Phase 1
Policy & Documentation
Q1 – Q2 2026
Progress
90%
- Comprehensive information security policy library developed and reviewed
- All required policies uploaded to compliance platform with control mappings
- All 5 FedRAMP program roles formally acknowledged (ISSO, System Owner, AO, SAOP, ISSM)
- Program compliance framework configured with control ownership assigned
- System architecture and access boundary documented and reviewed
- Rules of Behavior program established for all boundary personnel
- Final policy approvals in progress; full library sign-off targeted this quarter
- Full compliance platform control coverage at 100% of 325 controls
Phase 2
System Security Plan (SSP) Development
Q1 – Q2 2026
Progress
92%
- System Security Plan structure established
- Security control documentation complete across all 18 NIST control families
- Third-party interconnection security agreements documented for all external services
- Risk assessment and threat modeling complete; risk register established
- Supply chain risk management plan drafted
- Full SSP package generated — control narratives, appendices, and policy library compiled
- SSP quality review underway; Steelhead-specific content being validated
- Independent advisory document review package being finalized for submission
- Plan of Action & Milestones (POA&M) initialized
Phase 3
3PAO Selection & Engagement
Q1 – Q2 2026
Progress
100%
- Competitive third-party assessor evaluation complete; all proposals received and evaluated
- Peer benchmarking with industry counterparts complete
- 3PAO selected for formal assessment; pre-assessment advisor engaged
- Final vendor meetings held
- Assessor contract executed — Q3 assessment slot formally locked
- Assessment scope and statement of work finalized
- Assessor-led penetration testing engagement scheduled
Phase 4
FedRAMP-Compliant Environment Buildout
Q2 2026
Progress
75%
- Cloud environment architecture and security controls designed
- Identity and access management architecture confirmed
- CI/CD pipeline architecture finalized; build and deployment security controls integrated
- SIEM and EDR platforms selected
- FedRAMP-authorized cloud environment provisioned and live with logging and threat detection enabled
- Centralized security monitoring integrated — log aggregation, threat detection, and vulnerability scanning active
- Virtual desktop environment configuration and security agent enrollment
- Architecture validated against documented security baseline
Phase 5
Evidence Collection & Security Testing
Q2 – Q3 2026
Progress
22%
- Mandatory continuous monitoring period formally opened
- Continuous monitoring evidence collection across all 325 controls
- Authenticated vulnerability scanning active across boundary components
- Assessor-led penetration testing
- Business continuity and disaster recovery testing
- Findings remediation and risk acceptance documentation
Phase 6
3PAO Formal Security Assessment
Q3 – Q4 2026
Progress
0%
- Third-party assessor document review
- Security control testing and validation
- Staff interviews and process verification
- Security Assessment Report received and reviewed
- Assessment findings remediated
Phase 7
ATO Package & Authorization
Q4 2026
Progress
0%
- Final authorization package compiled
- Internal Authorizing Official review
- Authorization to Operate signed — target Q4 2026
Risk Posture
Assessment partnership secured
Active
Pre-assessment advisory engagement active
Active
Continuous monitoring program active across the live environment
Active
Full SSP package ready for independent advisory review
Active
Parallel workstreams active
Active
Penetration testing scoped and confirmed — assessor-led
Locked
Internal AO engagement — pending assessment outcomes
Locked
Ongoing Compliance Commitments
Monthly risk reviews
Executive + program cadence
Annual reassessment
Full program refresh cycle
Continuous control monitoring
Automated + manual attestations
Dedicated program ownership
Named control owners
Evidence retention
7-year artifact policy
POA&M management
Tracked remediation SLAs
Continuous monitoring cadence
Monthly CM reporting