Achieve FedRAMP Moderate or High Equivalency with Lazarus Alliance’s A2LA-accredited FedRAMP audit and 3PAO support services. Fast 6–12 week timelines, full SSP/POA&M development, and Cybervisor™ automation. Call 888-896-7580.

FedRAMP Moderate Equivalency (also called FedRAMP Moderate Equivalent) is a DoD-defined alternative compliance pathway for cloud service offerings (CSOs) used by Defense Industrial Base (DIB) contractors to store, process, or transmit Covered Defense Information (CDI) or Controlled Unclassified Information (CUI). It stems directly from DFARS clause 252.204-7012 and was clarified in a December 21, 2023, DoD CIO memorandum.

Why It Exists and Its Role in CMMC

DFARS 252.204-7012 requires that any external cloud service provider (CSP) handling CDI/CUI must meet security requirements equivalent to the FedRAMP Moderate baseline (plus DFARS cyber incident reporting rules in paragraphs (c)–(g)). The CMMC program (especially Levels 2 and 3, which protect CUI) incorporates this requirement: if your organization uses a CSP for CUI, that CSP must be either FedRAMP Moderate Authorized (listed on the FedRAMP Marketplace) or FedRAMP Moderate Equivalent.

During a CMMC assessment, the C3PAO (for Level 2) or DIBCAC (for higher levels) will review the CSP’s Body of Evidence (BoE) to confirm the equivalency claim. This is part of validating your overall CMMC compliance.

Lazarus Alliance, an accredited FedRAMP Third-Party Assessment Organization (3PAO), will coordinate directly with your organization to prepare for and schedule your official FedRAMP Moderate Equivalency assessment. Upon successful completion of the independent 3PAO assessment, Lazarus Alliance will provide a complete Body of Evidence (BoE).

Federal Risk and Authorization Management Program (FedRAMP)

FedRAMP is a U.S. government-wide program that provides a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services used by federal agencies.

Established in 2011 and mandated by the Office of Management and Budget (OMB), FedRAMP eliminates duplicative security testing by creating a “do once, use many times” framework so that once a cloud service is authorized under FedRAMP, any federal agency can reuse that authorization package instead of conducting its own full assessment.

What “Equivalent” Actually Means

The 2023 memo closed earlier loopholes and set a high bar. A CSO qualifies as FedRAMP Moderate Equivalent only if it meets all of the following:

  • Achieves 100% compliance (zero control-related findings) with the latest FedRAMP Moderate security control baseline (NIST SP 800-53 Rev. 5 Moderate, ~325 controls).
  • Is assessed by a FedRAMP-recognized and accredited Third-Party Assessment Organization (3PAO) using FedRAMP templates.
  • Provides a complete Body of Evidence (BoE) to the contractor, which typically includes:
    • System Security Plan (SSP)
    • Security Assessment Plan (SAP)
    • Security Assessment Report (SAR) performed by the 3PAO
    • Plan of Action and Milestones (POA&M) — note: continuing operational POA&Ms are allowed after the assessment, but the initial 3PAO assessment must show full compliance with no open control findings.

The CSP must also comply with DFARS 252.204-7012 incident reporting, malicious software handling, media protection, forensic access, and damage assessment requirements.

Achieve FedRAMP Moderate or High Equivalency with Lazarus Alliance’s A2LA-accredited FedRAMP audit and 3PAO support services. Fast 6–12 week timelines, full SSP/POA&M development, and Cybervisor™ automation. Call 888-896-7580.

FedRAMP Moderate Equivalency Audit Timeline: What to Expect with Lazarus Alliance

Below are the real-world average timelines seen in 2024–2026 with experienced 3PAOs like Lazarus Alliance:

Detailed FedRAMP Moderate Equivalency Audit Timeline

Lazarus Alliance follows this structured 6-phase process to help Cloud Service Providers (CSPs) with an existing FedRAMP Moderate authorization efficiently achieve Moderate Equivalency (Agency ATO reuse, DoD IL4/IL5 mapping, StateRAMP, or other equivalency pathways) using A2LA-accredited rigor and automation.

Phase Activities Duration Deliverables
Phase 0 – Pre-Engagement & Decision Risk-free consultation, review existing FedRAMP Moderate package, determine target equivalency path (Agency, DoD IL4/IL5, StateRAMP, etc.), boundary confirmation, and gap scoping. 1 week Signed engagement agreement, equivalency roadmap, updated boundary diagram, and path confirmation.
Phase 1 – Scoping & Readiness Assessment Inheritance analysis of existing Moderate controls, identification of additional equivalency requirements, SSP tailoring, and documentation review. 1–2 weeks Inheritance mapping report, readiness gap analysis, tailored SSP outline for equivalency.
Phase 2 – Gap Assessment & Remediation Planning Full delta analysis of additional controls, policy/procedure updates, POA&M refinement, and evidence strategy using Cybervisor™ automation. 2–3 weeks Detailed equivalency gap report, prioritized remediation plan, updated POA&M, evidence collection roadmap.
Phase 3 – Evidence Collection & Testing Verification of inherited + new controls, automated + manual testing, penetration testing support, and evidence repository build for equivalency. 3–4 weeks Comprehensive evidence package, test results, updated POA&M, ready-to-submit control statements.
Phase 4 – Reporting & Submission Package Final SSP/SAR updates for equivalency, package assembly, agency coordination, and submission support. 1–2 weeks Complete equivalency authorization package (updated SSP, SAR, POA&M), submission-ready artifacts.
Phase 5 – Authorization & Continuous Monitoring Agency support, equivalency acceptance coordination, Continuous Monitoring (ConMon) program alignment, ongoing automation with Continuum GRC and Cybervisor™. 2–3 weeks initial setup (then ongoing) Equivalency acceptance confirmation, approved ConMon plan, automated reporting dashboards, and a long-term compliance maintenance program.

Why clients finish faster with Lazarus Alliance: Our A2LA-accredited assessors (ISO/IEC 17020 #3822.01), Cybervisor™ automation platform, Continuum GRC technology, and Proactive Cyber Security® methodology reduce typical FedRAMP Moderate Equivalency timelines by 40–50% while delivering superior evidence quality and faster agency acceptance.

Lazarus Alliance, an accredited FedRAMP Third-Party Assessment Organization (3PAO), is historically about 46% faster than traditional 3PAO firms meaning that your FedRAMP Moderate Equivalency can be achieved in 3–6 months - Michael Peters, CEO & Founder

FedRAMP Moderate: Authorized vs. Moderate Equivalent

FedRAMP Moderate Authorized vs. Moderate Equivalency Comparison

Lazarus Alliance helps Defense Industrial Base (DIB) contractors and Cloud Service Providers clearly understand the key differences between full FedRAMP Moderate Authorization and FedRAMP Moderate Equivalency for meeting DFARS 252.204-7012 and CMMC compliance requirements.

Aspect FedRAMP Moderate Authorized FedRAMP Moderate Equivalent
FedRAMP Marketplace Listing / ATO Yes (Full Authorization) No
Requires Federal Agency Sponsor Yes No
Security Controls & 3PAO Assessment 100% compliance with FedRAMP Moderate baseline 100% compliance with FedRAMP Moderate baseline
Assessed By FedRAMP-recognized 3PAO FedRAMP-recognized 3PAO
Acceptable for CMMC / DFARS 252.204-7012 Fully compliant Fully compliant
Ongoing Monitoring & Oversight FedRAMP PMO + Continuous Monitoring Contractor + C3PAO/DIBCAC review of Body of Evidence (BoE)
Best For Organizations seeking maximum marketplace recognition CSPs serving DoD contractors without pursuing a full FedRAMP ATO

Key Takeaway with Lazarus Alliance: Both pathways deliver identical security control rigor for CUI/CDI protection, but Moderate Equivalency gives CSPs a faster, sponsor-free route while our A2LA-accredited team and Cybervisor™ automation ensure seamless CMMC readiness and agency acceptance.

Equivalency gives CSPs (especially those not pursuing full FedRAMP) a viable path to serve DoD contractors without obtaining a federal Authority to Operate (ATO). However, it does not make the CSP “FedRAMP Authorized.”

Achieve FedRAMP Moderate or High Equivalency with Lazarus Alliance’s A2LA-accredited FedRAMP audit and 3PAO support services. Fast 6–12 week timelines, full SSP/POA&M development, and Cybervisor™ automation. Call 888-896-7580.

Frequently Asked Questions

CSPs targeting DoD contracts (IL4/IL5), StateRAMP compliance, or rapid agency adoption benefit most. If you already have FedRAMP Moderate and want to expand into defense, state government, or additional federal agencies, Moderate Equivalency is the fastest route to new authorizations.

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Standard FedRAMP Moderate is a full baseline authorization (325 controls). Moderate Equivalency reuses your existing Moderate package and only requires delta-gap analysis for additional controls required by the new pathway (DoD, StateRAMP, etc.), dramatically shortening the timeline.

With Lazarus Alliance’s A2LA-accredited 3PAO team and Cybervisor™ automation, most clients complete FedRAMP Moderate Equivalency in 3–6 months — 40–50% faster than traditional 3PAO firms.

Our proprietary Cybervisor™ automation platform, Continuum GRC technology, and Proactive Cyber Security® methodology reduce manual evidence collection and testing by up to 50%, while our A2LA ISO/IEC 17020 accreditation (#3822.01) ensures immediate agency acceptance.

Benefits include 40–50% faster time-to-market, significantly lower costs, reuse of existing evidence, stronger positioning for DoD and state contracts, and a quicker path to additional revenue from government customers.

Costs vary based on scope and existing maturity, but Lazarus Alliance’s streamlined delta approach typically saves clients 40–50% compared to a full new authorization. Contact us at 888-896-7580 for a risk-free consultation and customized quote.

Simply call 888-896-7580 or complete our short FedRAMP Equivalency questionnaire. Our team will review your existing Moderate package and deliver a no-obligation roadmap within 48 hours.

Achieve FedRAMP Moderate or High Equivalency with Lazarus Alliance’s A2LA-accredited FedRAMP audit and 3PAO support services. Fast 6–12 week timelines, full SSP/POA&M development, and Cybervisor™ automation. Call 888-896-7580.

Lazarus Alliance, as a FedRAMP 3PAO, provides FedRAMP, FISMA, and NIST audit, advisory, and assessment services for public, private, community, and hybrid cloud service offerings, including Software as a Service (SaaS), Platform as a Service (PaaS), and Infrastructure as a Service (IaaS).

At Lazarus Alliance, proactive isn't just our trademark—it's our promise to protect your future before threats even emerge. — Michael Peters, CEO & Founder

Leveraging the Continuum GRC IT Audit Machine, Security Trifecta methodology, and the Policy Machine, Lazarus Alliance provides international standards that are recognized as “Best Practices” for developing organizational security standards and controls that support Federal Risk and Authorization Management Program-based compliance audit certifications and assessments.

Credentials You Can Count On

American Association for Laboratory Accreditation (A2LA) ISO/IEC 17020 accredited certification number 3822.01

Talk with one of our experts

Our Lazarus Alliance Cybervisor™ teams have experience performing thousands of assessments for organisations providing services to clients around the world.

We're here to answer any questions you may have.

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Achieve FedRAMP Moderate or High Equivalency with Lazarus Alliance’s A2LA-accredited FedRAMP audit and 3PAO support services. Fast 6–12 week timelines, full SSP/POA&M development, and Cybervisor™ automation. Call 888-896-7580.

Benefits of FedRAMP Moderate Equivalency

  1. No Federal Agency Sponsor Required
    • For Cloud Service Providers (CSPs): Skip the lengthy sponsorship process and FedRAMP PMO reviews — get to market faster.
    • For Defense Contractors (DIB): Access a wider selection of innovative CSPs that don’t serve federal agencies directly.
  2. Faster Time-to-Revenue & Deployment
    • For Cloud Service Providers (CSPs): Reach 300,000+ DIB contractors in weeks instead of months.
    • For Defense Contractors (DIB): Onboard compliant cloud services faster without waiting for a full FedRAMP ATO.
  3. Lower Cost Than Full FedRAMP Authorization
    • For Cloud Service Providers (CSPs): Avoid ongoing FedRAMP Marketplace fees, sponsor coordination, and PMO oversight.
    • For Defense Contractors (DIB): Choose cost-effective CSP solutions tailored for DoD without premium FedRAMP pricing.
  4. Identical Security Rigor (100% FedRAMP Moderate Baseline)
    • For Cloud Service Providers (CSPs): Deliver enterprise-grade NIST 800-53 Rev. 5 Moderate controls validated by a FedRAMP-recognized 3PAO.
    • For Defense Contractors (DIB): Meet DFARS & CMMC requirements with full confidence — same controls, no compromise.
  5. New Revenue & Market Access
    • For Cloud Service Providers (CSPs): Open doors to the entire Defense Industrial Base without pursuing full federal ATO.
    • For Defense Contractors (DIB): Gain more CSP choices and competitive options for CUI-handling cloud services.
  6. Competitive Edge & CMMC Readiness
    • For Cloud Service Providers (CSPs): Differentiate your platform with proven DoD-compliant security and streamlined customer assessments.
    • For Defense Contractors (DIB): Simplify your CMMC Level 2/3 assessment with a ready-to-use Body of Evidence (BoE).

We want to be your partner and FedRAMP 3PAO compliance audit assessor of choice! For additional information, please call +1 (888) 896-7580.

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