Fedramp Incident Response Plan Template

Standard Operating Procedure: FedRAMP Incident Response Plan (IRP)

1. Document Control Block

2. Executive Summary & Purpose

This document establishes the mandated framework for detecting, analyzing, containing, eradicating, and recovering from security incidents within the Template Registry FedRAMP-authorized boundary. This IRP fulfills NIST SP 800-61 Rev. 2 and FedRAMP incident reporting requirements, ensuring compliance with OMB M-17-12.

3. Scope & Prerequisites

• Scope: All Information Systems (IS) within the FedRAMP boundary, including cloud service provider (CSP) infrastructure, interconnected endpoints, and personnel access.
• Required Tools: SIEM (Splunk/Sentinel), EDR (CrowdStrike/Defender for Endpoint), Forensic Imaging Tool, Out-of-band communication (Signal/Encrypted Slack), Incident Management System (Jira Service Management).
• Prerequisites: Validated system baseline, established connectivity to the CISA NCCIC/FedRAMP SOC, and current personnel security clearance levels for data handling.

4. Roles & Responsibilities (RACI)

5. Step-by-Step Procedure

Phase 1: Preparation

• Maintain updated asset inventory within the System Security Plan (SSP).
• Conduct quarterly tabletop exercises.
• Ensure all logging collectors (SIEM) are ingest-active.

Phase 2: Detection & Analysis

• Verify incident trigger via SIEM/EDR alert.
• Categorize impact level (Low/Moderate/High) per FIPS 199.
• Establish initial incident timeline in the master log.

Phase 3: Containment, Eradication, & Recovery

• Isolate compromised instances (Network isolation/Snapshot).
• Terminate malicious sessions and reset compromised credentials.
• Sanitize systems and verify integrity against known-good baselines.
• Restore operations from hardened, immutable backups.

Phase 4: Post-Incident Activity

• Complete "Lessons Learned" review within 72 hours of closure.
• Update IR procedure and security controls based on forensic findings.
• Submit formal incident report to the FedRAMP PMO (via the Incident Reporting Form).

6. Quality Assurance & Pro-Tips

• Metric Thresholds:
  • Time to Detection (TTD): < 1 hour for High-severity.
  • Reporting to FedRAMP/CISA: Per FedRAMP timelines (e.g., 1 hour for major incidents).
• Pro-Tips:
  • The "Out-of-Band" Rule: Never use internal email to discuss an active breach; if the environment is compromised, the attacker can monitor your communication.
  • Forensic Preservation: Always capture volatile memory (RAM) before power-cycling a compromised node.
  • Common Pitfall: Delaying reporting due to incomplete data. FedRAMP prefers an initial "estimated" report over a delayed "perfect" one.

7. Frequently Asked Questions

Q: At what point is an incident considered "reportable" to the FedRAMP PMO? A: Any incident involving PII, PHI, or a confirmed unauthorized access to the FedRAMP-authorized boundary requires mandatory reporting to the FedRAMP PMO and CISA within the defined timeframes (e.g., 1 hour for major incidents).

Q: If we identify a false positive during the triage phase, what is the required documentation? A: Record the incident ID, the trigger mechanism, and the specific evidence that confirmed it as a false positive. Archive the ticket with a "False Positive" classification; do not delete the telemetry, as it is required for audit trails.