CA-2 (01)—Control Assessments | Independent Assessors
>Control Description
>FedRAMP Baseline Requirements
No FedRAMP-specific parameter values or requirements for this baseline.
>Discussion
Independent assessors or assessment teams are individuals or groups who conduct impartial assessments of systems. Impartiality means that assessors are free from any perceived or actual conflicts of interest regarding the development, operation, sustainment, or management of the systems under assessment or the determination of control effectiveness. To achieve impartiality, assessors do not create a mutual or conflicting interest with the organizations where the assessments are being conducted, assess their own work, act as management or employees of the organizations they are serving, or place themselves in positions of advocacy for the organizations acquiring their services.
Independent assessments can be obtained from elements within organizations or be contracted to public or private sector entities outside of organizations. Authorizing officials determine the required level of independence based on the security categories of systems and/or the risk to organizational operations, organizational assets, or individuals. Authorizing officials also determine if the level of assessor independence provides sufficient assurance that the results are sound and can be used to make credible, risk-based decisions.
Assessor independence determination includes whether contracted assessment services have sufficient independence, such as when system owners are not directly involved in contracting processes or cannot influence the impartiality of the assessors conducting the assessments. During the system design and development phase, having independent assessors is analogous to having independent SMEs involved in design reviews. When organizations that own the systems are small or the structures of the organizations require that assessments be conducted by individuals that are in the developmental, operational, or management chain of the system owners, independence in assessment processes can be achieved by ensuring that assessment results are carefully reviewed and analyzed by independent teams of experts to validate the completeness, accuracy, integrity, and reliability of the results.
Assessments performed for purposes other than to support authorization decisions are more likely to be useable for such decisions when performed by assessors with sufficient independence, thereby reducing the need to repeat assessments.
>Assessment Interview Topics
Questions assessors commonly ask
Process & Governance:
- •What formal policies and procedures govern the implementation of CA-2(1) (Independent Assessors)?
- •Who are the designated roles responsible for implementing, maintaining, and monitoring CA-2(1)?
- •How frequently is the CA-2(1) policy reviewed and updated, and what triggers policy changes?
- •What training or awareness programs ensure personnel understand their responsibilities related to CA-2(1)?
Technical Implementation:
- •Describe the specific technical mechanisms or controls used to enforce CA-2(1) requirements.
- •What automated tools, systems, or technologies are deployed to implement CA-2(1)?
- •How is CA-2(1) integrated into your system architecture and overall security posture?
- •What configuration settings, parameters, or technical specifications enforce CA-2(1) requirements?
Evidence & Documentation:
- •What documentation demonstrates the complete implementation of CA-2(1)?
- •What audit logs, records, reports, or monitoring data validate CA-2(1) compliance?
- •Can you provide evidence of periodic reviews, assessments, or testing of CA-2(1) effectiveness?
- •What artifacts would you present during a FedRAMP assessment to demonstrate CA-2(1) compliance?
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