Episode 6 — Differentiate JAB and Agency
In Episode Six, titled “Differentiate J A B and Agency,” we make clean contrasts between the two official routes that lead to federal cloud authorization under the Federal Risk and Authorization Management Program, or FED RAMP. Teams often blur these paths because both end at an authorization decision, yet the forces that move them are not the same. What changes is who selects you, who sponsors you, how the evidence is reviewed, and how reuse unfolds across the government. You will hear recurring themes—demand, mission, cadence, and sponsorship—because those are the levers that actually shift outcomes and schedules. By putting the two routes side by side in plain language, we reduce second-guessing and help you articulate a choice that matches your product, your customers, and your timing.
The purpose here is simple: recognize that FED RAMP offers two routes to authorization so you can choose deliberately rather than by habit or hearsay. One is through the Joint Authorization Board, or J A B after first use, which can grant a Provisional Authorization to Operate, written as P A T O. The other is through an individual federal agency that issues an Authorization to Operate, or A T O, for its own use. Both require the same discipline in control implementation and documentation, but they differ in how you are admitted to the queue, how your evidence is examined, and how subsequent agencies can leverage the result. Treating them as interchangeable produces frustration; treating them as distinct tools lets you match the tool to the job in front of you.
The J A B pathway prioritizes services with broad, government-wide demand through a risk-based selection process. Selection capacity is finite, so entry favors offerings that many agencies are likely to use and that demonstrate documentation maturity from day one. The evaluation posture is intentionally exacting: reviewers assume the package may become a foundation for reuse, so they press on clarity, inheritance mapping, and continuous monitoring plans with uncommon rigor. For a product that squarely addresses cross-cutting missions—identity, collaboration at scale, data platforms, or protective services—the upside is leverage. A P A T O functions as a high-confidence starting point for many agencies, which can shorten later reviews and widen your potential customer base without repeating the full assessment at each turn.
By contrast, the Agency route begins with a sponsoring agency’s mission need and the willingness of its Authorizing Official to evaluate and accept risk for that specific environment. Here the emphasis is on fit: does the service solve a defined problem for that agency within its time constraints and operational reality? Sponsorship creates momentum; a committed customer can coordinate reviews, clarify interpretation questions, and guide the provider through local processes that culminate in an A T O. The scope of decision is local by design, which makes this route attractive when a clear early adopter exists. Because the decision is specific, later reuse by other agencies remains possible but will depend on how well the package communicates applicability beyond the original sponsor’s context.
Concrete examples clarify the divide. A collaboration suite with broad applicability across departments—email, chat, document sharing, meeting services—often fits the J A B route because demand is demonstrably wide and many agencies will ask for it. The J A B’s investment in deep scrutiny pays off as dozens of customers evaluate the same foundational package. Meanwhile, a niche workflow tool that supports a particular regulatory process or a specialized mission function will struggle to show cross-government demand but may have an enthusiastic sponsor ready to adopt it. That product is a strong candidate for the Agency path, where the sponsor’s mission benefit justifies the effort and the initial A T O becomes evidence for future agencies that face the same niche requirement.
Evidence cadence diverges meaningfully between the routes. Under J A B oversight, scrutiny is centralized and documentation must withstand examination by a board that anticipates wide reuse; this centralization pushes providers to produce a highly structured System Security Plan and to sustain a rigorous continuous monitoring rhythm from the outset. Under the Agency route, oversight localizes to the sponsor’s processes and boards, which means document organization, briefing styles, and meeting tempos adapt to that agency’s expectations. Neither cadence is easier in absolute terms; they simply emphasize different audiences. If your team thrives under standardized templates and highly formal checkpoints, J A B may feel natural. If your team prefers direct engagement with a single customer’s reviewers and faster iteration around context, Agency may feel smoother.
Timelines are driven by different forces as well. The J A B route lives inside an intake and prioritization queue, so your schedule depends on selection windows and the board’s capacity to review packages in depth. Even with a polished package, queue placement and resource contention can elongate the calendar. The Agency route hinges on sponsor readiness: the availability of reviewers, the speed of internal risk boards, and the agency’s appetite to move. If the sponsor can commit time and attention, initial authorization can arrive sooner than a J A B selection cycle would permit. If the sponsor’s capacity is thin or competing priorities interrupt reviews, the calendar can stretch. Recognizing which set of drivers you face prevents magical thinking and sets stakeholder expectations honestly.
A common pitfall is pursuing the J A B path without market demand or sponsor interest to back it up. Teams sometimes equate the P A T O with prestige and assume it will unlock customers automatically. In practice, selection requires proof that many agencies want the service, and post-authorization adoption still benefits from active champions. Entering the J A B queue prematurely expends energy preparing for a central review that may not select you and diverts attention from cultivating the agency advocates you actually need. The waste is not just time; it is opportunity cost in engineering and documentation effort that might have secured a near-term Agency authorization and practical momentum.
The quick win, therefore, is to validate potential reuse and identify agency champions early, before you commit to a route. Talk with prospective customers about concrete missions your product advances, confirm whether similar agencies share that need, and ask how they would consume an authorization outcome—would they prefer to reuse a P A T O or to sponsor an A T O directly? Map a handful of named advocates who can attend briefings, review artifacts, and escalate decisions. If you can name three or four agencies that would likely leverage a P A T O, your J A B case strengthens. If one sponsor is eager and has calendar space to lead reviews, the Agency case becomes persuasive. Early validation does not lock you in; it illuminates the decision.
A useful mental rehearsal is to time your route choice after boundary definition and customer mapping. First, define the system boundary and inherited controls so you can state what exactly would be assessed; this avoids promising a route for a moving target. Next, sketch your customer map: who has the problem your service solves, how many share it, and who is willing to sponsor? With those two artifacts—the boundary and the customer map—you make the choice with fewer assumptions. Announcing a route too early invites rework when scope shifts or when expected customers evaporate. Announcing too late wastes cycles in indecision. Tying the decision to tangible maps gives you a rational middle ground.
A short phrase can anchor the whole comparison: demand drives J A B; mission drives Agency. When leadership asks for the one-liner, this is the line to repeat. If demand is cross-government and your documentation can withstand board-level scrutiny, J A B offers leverage. If a specific mission owner needs your capability now and will shepherd the package, Agency offers speed and focus. Neither route is universally better; each is better for a particular pattern of need and readiness. Using this phrase in meetings pulls the conversation out of abstraction and back to the observable facts you can verify.
A mini-review at this point keeps the contrasts crisp. Who selects? For the J A B route, selection flows from a central board prioritizing high-demand services; for the Agency route, a sponsor steps forward based on mission need. Who sponsors? The J A B serves as the central reviewer leading to a P A T O; the agency itself sponsors, evaluates, and, if satisfied, issues an A T O. How does reuse happen? A P A T O invites many agencies to leverage a common package with focused deltas; an A T O invites other agencies to review and reuse with attention to differences from the original sponsor’s environment. Saying these answers aloud helps teams internalize the logic and align their expectations.
Alignment is not just conceptual; it is operational, so treat resources as route-specific and match them to the rhythms you have chosen. The J A B route demands sustained documentation polish, formal checkpoints, and well-oiled continuous monitoring from the start. Staff accordingly with writers who keep the System Security Plan coherent, engineers who can produce precise inheritance mappings, and program leads who run structured briefings. The Agency route demands sponsor engagement, rapid clarifications, and flexibility in responding to local review boards. Staff with customer-facing leads who can translate control language into mission terms, product managers who juggle iterative requests, and security engineers who can turn around evidence updates quickly. Misaligned staffing is as damaging as a mischosen route.
To close, recap the decision factors that matter and write down your route rationale. Demand breadth, sponsor strength, documentation maturity, queue realities, and calendar drivers belong in that rationale because they explain both the choice and the expectations that follow. The next action is to draft a short statement—two or three paragraphs—that records why you chose the J A B or Agency path and what conditions would warrant revisiting the decision. Share it with leadership, your assessment partner, and any interested agencies. A written rationale prevents thrash when doubts surface later, and it gives new team members a stable starting point. The routes are different on purpose; choosing with eyes open gives you a smoother road whichever direction you take.
