Continuous monitoring

The FedRAMP continuous monitoring requirement means you must run monthly or otherwise periodic security monitoring and vulnerability reporting for your authorized cloud system, then publish the results (including POA&M updates) as auditable evidence. Operationally, you need a defined cadence, assigned owners, tooling-backed data, a repeatable reporting package, and disciplined remediation tracking.

Key takeaways:

• Continuous monitoring is an operational process, not a one-time authorization deliverable ¹.
• Your primary outputs are monthly/periodic vulnerability reporting and updated POA&M entries you can defend in an audit ¹.
• Most failures are evidence failures: missing scan coverage, unclear scope, weak remediation proof, or inconsistent reporting packages ¹.

Continuous monitoring is where many FedRAMP programs succeed or fail after the initial authorization. The requirement is simple to state but demanding to run: keep security monitoring operating on a defined cadence, report vulnerabilities, and maintain a living POA&M that reflects reality ¹. For a CCO or GRC lead, the goal is to convert that statement into a stable operating rhythm that produces reliable artifacts every period, even when engineering teams change, tooling gets swapped, or the environment scales.

This page focuses on requirement-level execution. It tells you who must comply, what to implement, and what evidence you should retain so your authorization does not drift. It also calls out the most common audit hangups: incomplete asset inventory feeding scans, unclear responsibility for triage, “POA&M as a spreadsheet” with no linkage to tickets, and reporting packages that vary month to month.

If you are building this from scratch, treat continuous monitoring as a production process with inputs, controls, outputs, and quality checks. If you already have parts of it, your fastest path is standardizing scope, cadence, and evidence so your monitoring is provable, repeatable, and review-ready.

Continuous monitoring requirement (FedRAMP): plain-English meaning

You must continuously operate security monitoring and vulnerability reporting on a monthly/periodic cadence for your FedRAMP-authorized system, and you must be able to show the results and remediation tracking. The program expectation is not “we scan sometimes,” but “we run monitoring as an ongoing control and can produce period-by-period reports and POA&M updates” ¹.

“Monthly/periodic” is deliberately broad in the excerpt, so your job is to:

1. define the cadence for each monitoring activity (monthly where required by your program plan),
2. execute it consistently, and
3. retain evidence that ties findings to remediation actions ¹.

Regulatory text

Excerpt (FedRAMP): “Operate monthly/periodic continuous monitoring and vulnerability reporting.” ¹

Operator interpretation: what you must do

• Operate: Monitoring must be running as a standard operating procedure, not as an ad hoc effort ¹.
• Monthly/periodic: You need a documented schedule and you must meet it, or document exceptions and compensating actions ¹.
• Continuous monitoring and vulnerability reporting: You must generate vulnerability outputs (scans, findings, trends, exceptions) and report them in the format your FedRAMP stakeholders expect, along with POA&M updates ¹.

For control mapping and program structure, align your approach to NIST SP 800-53 Rev. 5 continuous monitoring concepts and assessment/authorization operations ².

Who it applies to (entity and operational context)

In scope entities

• Cloud Service Providers (CSPs) operating systems seeking or maintaining FedRAMP authorization ¹.

In scope operations (what “counts” as the system)

• The authorized boundary (your defined system scope for FedRAMP) and all components that store, process, or transmit federal information within that boundary. Your monitoring scope must match your boundary or explicitly document and justify gaps ¹.

Teams typically involved

• Security engineering (scanning, detection, response)
• Infrastructure/platform engineering (agents, patching, config)
• Application engineering (dependency remediation)
• GRC/compliance (reporting package, POA&M governance)
• Third parties (managed detection, scanner provider, 3PAO inputs where applicable)

What you actually need to do (step-by-step)

Step 1: Define the continuous monitoring operating model (paper first)

Create or update a Continuous Monitoring Plan aligned to FedRAMP templates and expectations ¹. Your plan should specify:

• Authorized system boundary and asset categories
• Monitoring activities (vulnerability scanning, configuration checks, log review, etc.)
• Cadence for each activity (monthly/periodic as defined in your program plan) ¹
• Roles and responsibilities (RACI)
• Ticketing and remediation workflow
• Reporting package contents and due dates

Practical tip: write down what triggers an “out-of-cycle” report (e.g., major vulnerability, major change) so exceptions don’t become a negotiation.

Step 2: Make scan scope match reality (asset inventory is the control)

Continuous monitoring fails fast when the scanner only sees a slice of production. Build a scan coverage register:

• Asset inventory feed (CMDB, cloud inventory, IaC state)
• What must be scanned (hosts, containers, images, endpoints, databases, network devices)
• Exclusions with explicit risk acceptance and compensating monitoring
• Proof of agent deployment or network reachability checks

Quality check: require an owner to attest each period that “inventory reconciled to scans” happened, and retain the attestation.

Step 3: Run vulnerability scanning and normalize the output

Operationalize recurring vulnerability scanning and ensure outputs are:

• Timestamped
• Attributed to in-scope assets
• Preserved in immutable storage or exportable audit format

Then normalize findings into a single workflow:

• Deduplicate and enrich (asset criticality, exploitability context)
• Assign ownership (team/service owner)
• Create remediation tickets
• Set target remediation dates consistent with your risk policy

Step 4: Triage and update the POA&M (the auditable control record)

Your POA&M is where continuous monitoring becomes an authorization-sustaining practice. Each reporting period:

• Add new items from validated findings
• Update status for existing items (open/in progress/complete)
• Link each POA&M line to evidence: scan finding ID, ticket ID, change request, patch report, or test evidence ¹

Minimum expectation to keep yourself safe in reviews: every “closed” POA&M item should have closure evidence and a closure date, plus proof the fix was verified (scan rerun, config check, or test artifact).

Step 5: Publish the monthly/periodic reporting package

Produce a consistent package each period that includes:

• Summary of monitoring performed and dates executed
• Vulnerability reporting output (executive summary plus technical appendices)
• POA&M updates (additions, closures, aging commentary) ¹

FedRAMP provides documents and templates you should follow for formatting and completeness ¹.

Step 6: Add a governance loop (so the process survives)

Set a standing continuous monitoring review meeting with a fixed agenda:

• Coverage exceptions and drift (inventory vs scans)
• New critical findings and remediation blockers
• POA&M aging and stale items
• Required deliverables produced and stored
• Corrective actions for process defects (missed scans, missing evidence)

If you want this to run without heroics, automate the evidence collection. In practice, teams use a GRC workflow tool (for example, Daydream) to schedule control tasks, collect artifacts, and keep POA&M entries linked to underlying tickets and scan results in one place.

Required evidence and artifacts to retain

Keep artifacts in a system that preserves timestamps and authorship. Expect an assessor or authorizing stakeholder to ask for “show me what you did this month, prove it happened, and show me what you changed.”

Core artifacts

• Continuous Monitoring Plan and schedule ¹
• Monthly/periodic vulnerability scan outputs (raw exports + summarized reports)
• Asset inventory snapshots and scan coverage reconciliation
• POA&M (current version + change history) ¹
• Remediation tickets and change records linked to findings
• Exception records: accepted risk, compensating controls, approvals
• Evidence of validation (rescans, configuration validation outputs)

Nice-to-have artifacts (reduce review friction)

• Metrics dashboard (trend lines, backlog aging) without inventing or overstating claims
• Meeting minutes for the monthly review with actions and owners
• QA checklist showing required sections of the report package were completed

Common exam/audit questions and hangups

Auditors and FedRAMP reviewers tend to press on consistency, scope, and traceability ¹.

Common questions:

• “Show the last reporting period package and the prior one. Is the scope consistent?”
• “How do you know your scanner covered the whole authorized boundary?”
• “Pick three POA&M items. Walk me from scan finding → ticket → remediation → validation.”
• “Where is the evidence that monitoring happened on the defined cadence?”
• “What happens when a scan fails, an agent drops, or a segment becomes unreachable?”

Hangups that stall reviews:

• POA&M items with no linkage to a source finding
• “Closed” items without validation evidence
• Exclusions that are undocumented or approved informally
• Reporting that changes format each period, forcing reviewers to re-learn your package

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	Fix
Treating continuous monitoring as a monthly scramble	Missed cadence, inconsistent evidence	Put monitoring tasks on a calendar with owners; add a QA checklist for each deliverable 1
Scanner coverage gaps due to weak inventory	Findings don’t represent reality	Reconcile inventory to scan targets every period and store the reconciliation evidence
POA&M becomes a static spreadsheet	No traceability, weak governance	Require ticket IDs, finding IDs, and validation evidence per item 1
No exception discipline	Silent scope reduction	Formalize exclusions with approvals, compensating monitoring, and revisit dates
Reporting lacks repeatability	Reviewers can’t compare periods	Use FedRAMP templates and keep a stable report structure 1

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement. Practically, the risk is authorization impact: if you cannot show continuous monitoring is operating and vulnerability reporting is current, reviewers can treat your security posture as unverified against the FedRAMP baseline expectations ¹. That translates into delays, additional scrutiny, and increased remediation burden.

Practical 30/60/90-day execution plan

This plan assumes you already have an authorized boundary and basic security tooling, but your reporting and evidence are inconsistent. Adjust sequencing if you are earlier-stage.

Days 0–30: Stabilize scope and cadence

• Name an owner for the continuous monitoring program and define RACI.
• Draft/update the Continuous Monitoring Plan and reporting calendar ¹.
• Define “system inventory source of truth” and produce the first inventory-to-scan reconciliation snapshot.
• Standardize POA&M fields: required linkage (finding ID, ticket ID), required closure evidence, approval workflow ¹.
• Produce a “minimum viable” monthly package from existing outputs, even if it’s imperfect. Then improve it.

Days 31–60: Make it repeatable and auditable

• Automate evidence capture (scan exports, inventory snapshots, ticket links) into a centralized repository.
• Implement QA checks: completeness, dates, scope, approvals, and artifact naming conventions.
• Run the monthly governance meeting with minutes and tracked action items.
• Start trend tracking (qualitative is fine) to spot backlog growth and recurring control failures.

Optional accelerator: configure Daydream to issue monthly tasks, collect artifacts, and keep POA&M entries tied to remediation workflows so the package assembles faster and with fewer evidence gaps.

Days 61–90: Harden controls and reduce drift

• Stress-test failure modes: scan failures, unreachable assets, tool outages. Document contingency steps.
• Add periodic internal spot checks: sample POA&M closures and validate evidence quality.
• Tune exception management: revisit dates, approval chain, compensating monitoring requirements.
• Produce two consecutive reporting packages in the same structure, stored with change history and clear ownership.

Frequently Asked Questions

What does “monthly/periodic” mean for the continuous monitoring requirement?

It means you must define a regular cadence for monitoring and vulnerability reporting and then meet it consistently ¹. If some activities run less frequently than monthly, document the rationale and keep the schedule and evidence aligned.

Do we have to publish continuous monitoring reports and POA&M updates?

Yes, publishing (producing and sharing with the appropriate FedRAMP stakeholders) continuous monitoring reports and POA&M updates is a common operational control expectation for proving the requirement is running ¹. Retain the submitted package and the underlying evidence.

What evidence is most likely to be challenged in a review?

Scope and traceability. Reviewers commonly challenge whether scans cover the authorized boundary and whether POA&M items tie back to real findings and verified remediation ¹.

How do we handle assets that can’t be scanned due to technical constraints?

Treat them as exceptions: document the exclusion, get an approval, define compensating monitoring, and set a revisit date. Also retain proof you attempted coverage and why it failed.

Can we rely on a third party MSSP or scanner provider for compliance?

You can outsource tasks, but you cannot outsource accountability. You still need to show the cadence was met, the outputs are complete, and remediation is tracked in your POA&M ¹.

How do we keep continuous monitoring from becoming a monthly fire drill?

Standardize the package, automate artifact collection, and run a fixed governance loop with owners and QA checks. Tools like Daydream help by turning each period into a controlled workflow with required evidence attached to each control task.

Related compliance topics

• 2025 SEC Marketing Rule Examination Focus Areas
• Access and identity controls
• Access Control (AC)
• Access control and identity discipline
• Access control management

Footnotes

1. FedRAMP Baseline Documentation

2. NIST SP 800-53 Rev. 5