Federal contractors pursuing FedRAMP authorization or CMMC compliance face a specific technical testing requirement: a penetration test conducted against a defined authorization boundary, following NIST SP 800-115 methodology, with findings formatted for POA&M input. We deliver that, not a generic web application assessment rebranded as federal compliance.
What adversaries target in contractor environments.
Government contractors are high-value targets. The objective is rarely the contractor itself. It is access to DoD networks, CUI, or federal system data that flows through contractor infrastructure.
Authorization boundary exposure
FedRAMP requires an explicit authorization boundary documented in the System Security Plan. Misconfigured cloud services, external APIs, or CI/CD pipelines that cross boundary definitions create unmanaged attack surface. Boundary creep is one of the most common CA-8 findings.
CUI data flows
Controlled Unclassified Information can flow through email, collaboration tools, document management systems, and development environments, each a CMMC testing target. CUI co-mingled with non-CUI systems violates network separation requirements (NIST SP 800-171 control 3.13.2).
Network segmentation failures
NIST SP 800-171 requires separation of CUI systems from non-CUI systems. Internal network penetration testing validates whether segmentation actually holds under adversarial conditions, not just whether firewall rules exist on paper.
Cloud misconfiguration
AWS GovCloud, Azure Government, and GCP FedRAMP-authorized offerings have complex shared responsibility models. Customer-responsible controls (IAM policies, storage bucket permissions, encryption configuration, logging) are frequently misconfigured and fall inside the authorization boundary.
Authentication and access control
NIST SP 800-171 requires MFA for all privileged and remote access. Missing or bypassable MFA, insecure password reset flows, weak session management, and privilege escalation paths from standard user to administrative access are recurring findings in contractor assessments.
Supply chain and third-party access
DoD contractors are targeted as a stepping stone to primes or to federal networks. Third-party vendor access, software build pipelines, and external integrations that touch CUI systems are in scope, not just the core application.
02. authorization process
How we handle federal authorization requirements.
Federal penetration tests require more pre-engagement coordination than commercial assessments. FedRAMP CA-8 mandates documented authorization before testing begins. We manage that process.
Authorization boundary reviewBefore any testing, your System Security Plan authorization boundary is reviewed. Testing scope is defined against what is documented inside the boundary, not your public perimeter. If your SSP boundary definition is unclear or outdated, we flag it before testing starts.
Rules of Engagement documentFedRAMP CA-8 requires documented authorization for penetration testing. We draft an ROE document that satisfies this requirement and protects you if testing triggers automated security alerts. The ROE references specific IP ranges, test windows, and approved techniques.
Government-side coordinationFor FedRAMP-authorized systems, the Cloud Service Provider must notify the Authorizing Official and FedRAMP PMO before testing. We assist with the notification documentation and timing requirements. For CMMC assessments, coordination is with your prime or DCSA schedule.
NIST SP 800-115 methodologyTesting follows NIST SP 800-115, the federal standard for technical information security testing. External network, internal network, and application testing are conducted per the methodology's planning, discovery, attack, and reporting phases. FedRAMP pentest details →
POA&M-ready outputFindings are formatted for direct input into your Plan of Action and Milestones table. Each finding includes NIST SP 800-53 control reference, risk rating, recommended remediation, and estimated effort. Your 3PAO and AO reference findings by ID during the authorization process.
03. scope
What we test in a government contractor pentest.
Scope tracks your authorization boundary documentation. If it is inside your SSP, it is in scope for testing.
External perimeter
All internet-facing assets within the authorization boundary. NIST SP 800-115 requires external testing conducted from outside the boundary. Includes web applications, APIs, VPN endpoints, and public cloud infrastructure.
Internal CUI network
Network segmentation validation, lateral movement paths, and privilege escalation from standard workstation to CUI data stores. NIST SP 800-171 control 3.13.2 network separation is tested under adversarial conditions.
Cloud infrastructure
Customer-responsible controls in AWS GovCloud, Azure Government, or GCP FedRAMP-authorized environments. IAM role boundaries, storage access policies, logging gaps, and encryption configuration are validated against FedRAMP High/Moderate/Low baseline requirements.
Web and API applications
Applications processing CUI within the authorization boundary. Authentication, authorization, session management, input validation, and API access control, scoped to boundary-resident systems, not public marketing sites.
Active Directory and identity
Domain privilege escalation paths, Kerberoasting, LDAP enumeration, and trust relationship abuse. AD compromise inside a contractor environment is the primary lateral movement path to CUI data stores.
Third-party integrations
External vendor access paths, software supply chain touchpoints, and subcontractor connections that reach CUI systems. DFARS 252.204-7012 flows down security requirements to subcontractors. We validate those connection points.
04. deliverables
What you walk away with.
Formatted for the authorization process. Not just readable, but directly usable in your SSP, POA&M, and ATO package.
NIST SP 800-115 methodology report
Full report documenting the planning, discovery, attack, and reporting phases per the federal testing standard. External and internal testing results reported separately, as required for FedRAMP CA-8 boundary documentation.
POA&M-ready finding format
Each finding includes finding ID, system component, NIST SP 800-53 control reference, CVSS 4.0 risk rating, recommended remediation, and estimated effort. Formatted for direct import into your SSP's Plan of Action and Milestones table.
Authorization letter
States the authorization boundary reference, NIST SP 800-115 methodology, engagement dates, named engineer, and retest outcome. Signed by the named engineer. Designed to satisfy FedRAMP CA-8 evidence requirements and CMMC SSP documentation.
Retest within 30 days
Post-remediation re-validation from the same engineer. Each finding marked resolved, partially resolved, or accepted with documented rationale. Retest results update the authorization letter and POA&M inputs.
Attestation letter
Separate from the authorization letter. States that testing was conducted, methodology used, and scope covered, for your internal compliance record and any prime contractor or government customer request.
Working PoCs
Every finding with a reproducible exploit or step-by-step walkthrough. Your engineering team verifies the finding before triage. Your 3PAO reviewer can confirm the issue is real. No unsubstantiated severity ratings.
05. faq
Questions before the call.
Are you a qualified 3PAO for FedRAMP assessments?
No. We are not a 3PAO. For a full FedRAMP assessment you need a Third Party Assessment Organization on the FedRAMP marketplace. What we provide is the penetration test component under FedRAMP CA-8: the technical testing that feeds into your 3PAO's broader assessment. Many 3PAOs subcontract the penetration test to a specialist; we deliver that component with NIST SP 800-115 methodology and POA&M-ready output.
What's the difference between CMMC Level 2 and Level 3 penetration testing requirements?
CMMC Level 2 covers 110 NIST SP 800-171 controls and requires a triennial third-party assessment. It does not explicitly mandate a penetration test, but DCSA assessors and many primes expect documented technical testing as SSP evidence. CMMC Level 3 covers NIST SP 800-172 practices on top of Level 2, requires government-led assessments, and explicitly includes penetration testing requirements. We deliver NIST SP 800-115 methodology testing against your CUI authorization boundary for both levels.
Can you test AWS GovCloud or Azure Government environments?
Yes. We test applications and infrastructure in AWS GovCloud (US), Azure Government, and GCP's FedRAMP-authorized offerings. Cloud architecture inside a FedRAMP boundary must have its customer-responsible controls tested: IAM policies, storage access, logging, encryption. We scope to those controls and document the shared responsibility boundary so your 3PAO can clearly distinguish what is cloud provider responsibility versus yours.
What does the authorization letter include?
The authorization letter states: engagement scope, authorization boundary reference, NIST SP 800-115 methodology, testing dates, named engineer, and retest outcome. It is signed by the named engineer, not generic firm letterhead. The format is designed to satisfy the FedRAMP CA-8 evidence requirement and to appear in your SSP's control implementation statement for CA-8.
How do your findings map to a POA&M?
Each finding in our report includes: finding ID, affected system component, NIST SP 800-53 control reference, risk rating (CVSS 4.0), recommended remediation action, and estimated remediation effort. This maps directly to the POA&M column structure used in FedRAMP SSP documentation. Your 3PAO or authorizing official can reference findings by ID during the authorization process without reformatting.
FedRAMP and CMMC gap mapping against your current controls. Remediation roadmap before the formal assessment.
Ready to scope a government contractor pentest?
30-minute scoping call covers your authorization boundary, your compliance framework (FedRAMP, CMMC, or both), and your timeline. Free. No NDA required for the first call.
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