Best Path Forward for a Class C to move to Class D

[csearcy46and2]

Hello,

We have a CSP with a Class C cert wanting to move towards getting a Class D certification and asked if our agency would sponsor them ( I do NOT know why they want to do this as I'm not directly involved in those conversations). I would like to find out 1. Is this even possible to do right now 2. What would be the best path for them to take moving forward (Rev5 Class D or 20X Class D) 3. Has FedRAMP started accepting pilot cases for their Class D certification and could the be a potential candidate for the pilot program? TIA

[paulagosta]

Hello

Before we jump into answers, a need for an uplift shouldn't be triggered by a CSP desire. It should be triggered by planned Agency needs. An agency performing ATO functions for a level it doesnt need seems to be a waste of resources. Apologies if I am reading into this wrong.

1. Class C to D uplift under Rev 5 is still possible, but the timeline for submission is very narrow. We will not accept an uplift or new Rev 5 package past 11 June 2027, which must come with all required materials (to include uplift ATO).

2. Is the CSP postured for a Class D assessment? Have they had a Class D assessment completed by a 3PAO? What is the normal timeline for ATO at the agency (some agencies are 2 months, a few are greater than a year)? Answers to those three questions will really drive feasibility since the timeline for submission closes 11 Jun 2027.

3. Not yet, but stay tuned...
   Paul

[csearcy46and2]

Thanks Paul and regarding your first comment about the reasoning for the uplift - I agree. I'm working on my end to get the answer as to the "why" they want this and what's driving them down this path. For #2 - I will get those answers along with the reasoning driving the uplift and get back to you.

Hypothetically, lets say they are postured for Class D assessment and they get assessed by a 3PAO and they submit everything and get certified by FedRAMP with flying colors - how long will that Class D cert last before being forced to move over to the 20x format? Also, will a Class D cert require Agency Sponsor? I believe the answer is yes but wanted to confirm (I'm aware that Class B and Class C do not require Agency sponsorship for 20x Certs). thanks again