Steelhead Technologies
FedRAMP Moderate Equivalency — Program Progress
Updated weekly · Last update: August 21, 2026
Program Start
Q1 2026
Program kickoff
Target Authorization
Q1 2027
Authorization target
Controls Scope
323
NIST 800-53 Moderate
Active Phases
1 · 2 · 4 · 5
Policy, SSP, Env., Evidence — parallel
Overall Program Progress (5 of 7 phases active or complete)
62%
Program Phases
Phase 1
Policy & Documentation
Q1 – Q2 2026
Progress
92%
- 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
- Responsible AI use policy established governing external AI tool usage
- Final policy approvals in progress; full library sign-off targeted this quarter
- Full compliance platform control coverage at 100% of 323 controls
Phase 2
System Security Plan (SSP) Development
Q1 – Q2 2026
Progress
96%
- 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
- Plan of Action & Milestones (POA&M) initialized and populated
- Full SSP quality review underway; content accuracy validation across all appendices
- Independent advisory document review underway
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
80%
- 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
65%
- Mandatory continuous monitoring period formally opened
- Automated finding-to-remediation tracking pipeline established
- Continuous monitoring evidence collection across all 323 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 – Q1 2027
Progress
0%
- Final authorization package compiled
- Internal Authorizing Official review
- Authorization to Operate signed — target Q1 2027
Risk Posture
Assessment partnership secured
Active
Pre-assessment advisory engagement active
Active
Continuous monitoring program active across the live environment
Active
SSP package under independent advisory document review
Active
Assessor-led penetration testing underway
Active
Contingency and incident response tabletop exercises completed
Active
Parallel workstreams active
Active
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