52.239-2 — Access to FedRAMP Security Assessment Framework
Researched by the BidStride Research Team
What This Clause Requires
Cloud services must be FedRAMP authorized at the appropriate impact level (Low, Moderate, or High) prior to operation.
Official Regulation Text
See 48 CFR 52.239-2 for the full regulatory text. This clause requires that cloud computing services used in contract performance be authorized under the Federal Risk and Authorization Management Program (FedRAMP) at the appropriate impact level before processing government data.
Compliance Checklist
- Obtain FedRAMP authorization before processing government data
- Maintain FedRAMP continuous monitoring requirements
- Impact level must match data sensitivity (Low/Moderate/High)
Flow-Down to Subcontractors
No flow-down required
This clause applies only to the prime contract and does not need to be flowed down to subcontractors.
Related Clauses
Frequently Asked Questions
The impact level depends on the sensitivity of the data processed. Low for publicly available information, Moderate for most government data, and High for law enforcement, financial, or health information. The contract will specify the required level.
Agency ATO (Authority to Operate) can take 6-12 months for a new authorization. The FedRAMP Marketplace lists pre-authorized services that can be used immediately. Reusing an existing authorized offering is much faster.
Yes. If you host your solution on an already-authorized platform (like AWS GovCloud or Azure Government), the underlying infrastructure authorization carries over. You still need a separate ATO for your application layer.
After authorization, you must perform monthly automated scans, submit monthly reports to your authorizing agency, conduct annual security assessments, and report significant changes within 30 days. Failure to comply can result in revocation of your ATO.
This summary is for informational purposes only and reflects the BidStride Research Team's plain-English interpretation of the regulation. It is not legal advice and does not constitute an attorney-client relationship. Always consult the official Federal Acquisition Regulation (FAR) or Defense Federal Acquisition Regulation Supplement (DFARS) text and qualified legal counsel for compliance decisions.