FedRAMP Continuous Monitoring After ATO: Monthly, Quarterly, and Annual Checklist

Q: What do I have to do after a FedRAMP ATO to maintain authorization through continuous monitoring (ConMon)?

TL;DR: After ATO, FedRAMP becomes a monthly operating rhythm: keep your POA&M and inventory current, run required vulnerability scans, upload ConMon deliverables on a consistent cadence, and complete an independent annual assessment. The CSP’s goal is simple: prove security controls stay effective as the system changes—without turning ConMon into a monthly fire drill.

admin@fedrampgpt.com • December 14, 2025 • 14 min read • 133 views

Frequently Asked Questions

What are the main FedRAMP ConMon deliverables each month?

Most CSPs maintain a consistent monthly package: an updated POA&M, an updated inventory, and vulnerability scanning outputs and summaries (as required by customer agreements). Many CSPs also include a short ConMon summary that highlights what changed, what was fixed, and what’s at risk.

Do I have to submit raw vulnerability scan files every month?

Often yes, but it can depend on your customer agreement and repository expectations. The safe approach: be prepared to provide the raw outputs plus a clear summary, and make sure findings map cleanly into your POA&M.

What’s the fastest way to get overwhelmed by ConMon?

Treating ConMon like a monthly scramble. If your inventory, scanning, and POA&M updates aren’t automated and owned by specific roles, you’ll rebuild the same package every month under pressure.

What’s the difference between ConMon and the annual assessment?

ConMon is the ongoing, monthly rhythm that shows your security posture stays healthy. The annual assessment is an independent validation that your control set still works and your system hasn’t drifted away from what was authorized.

What usually triggers extra scrutiny after ATO?

Unexplained changes, messy inventories, repeated overdue POA&M items, missing scan coverage, and “hand-wavy” narratives that don’t match the evidence. Clear traceability from scan → finding → POA&M → remediation evidence is the game.

Tags:

#Annual Assessment #ATO #CA-2 #Cloud Security #Compliance #ConMon #Continuous Monitoring #FedRAMP #Inventory #POA&M #RA-5 #Vulnerability Scanning

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