Ingress/Case Studies/Federal Cloud Migration

Federal cloud migration and FedRAMP High, delivered on deadline.

A large civilian agency needed to exit two aging data centers and achieve FedRAMP High authorization under a Congressional deadline. 340+ workloads. 18 months. No schedule slippage.

Federal Government Cloud Transformation FedRAMP High 18-month engagement
Authorization level
FedRAMP High
AWS GovCloud boundary
Contract vehicle
GSA MAS
#47QTCA26D000K
18mo
Time to FedRAMP High ATO
340+
Workloads Migrated
42%
Infra Cost Reduction
Engagement Overview

The situation going in.

A civilian agency operating under a Congressional IT modernization mandate was running 340+ production workloads across two on-premises data centers with hardware contracts expiring inside 24 months. Two prior cloud migration attempts had stalled before completing the FedRAMP authorization process, leaving the agency no closer to compliance and burning program budget.

The agency engaged Ingress via GSA MAS IT-70 with one hard constraint: FedRAMP High ATO and full data-center exit within 18 months, or face Congressional reporting consequences.

Engagement snapshot
Client typeLarge civilian agency
Contract vehicleGSA MAS #47QTCA26D000K
Duration18 months
Primary cloudAWS GovCloud (US)
Compliance targetFedRAMP High
FrameworksNIST 800-53, M-22-09, M-23-22
The Challenge

Two failed ATOs, one hard deadline.

The agency's prior migration attempts failed for the same reason: compliance was treated as a downstream activity rather than a parallel workstream. Each time, the team reached the SSP authoring stage, found control gaps that required infrastructure rework, and collapsed the timeline. The institutional memory of two failures made internal stakeholders skeptical that a third attempt would succeed.

The workload environment compounded the problem. 340+ applications ranged from simple web portals to latency-sensitive backend systems with undocumented cross-dependencies. Migrating them in the wrong order would cascade failures. And the deadline was statutory, not a preference that could be renegotiated.

  • 340+ mixed workloads with undocumented dependencies, ranging from low-complexity portals to latency-sensitive production systems.
  • Two prior failed ATOs caused by compliance-last sequencing that left control gaps too late to close without full timeline collapse.
  • Expiring hardware contracts within 24 months eliminated staying on-prem as a fallback.
  • Congressional mandate with statutory reporting consequences for schedule slippage, not just internal accountability.
The Work

Compliance parallel, not sequential.

The decisive architectural choice was treating FedRAMP package authoring as a concurrent workstream from day one. Every infrastructure decision had a control reference. Every code commit was potential evidence. No surprises at assessment time.

01.
Workload discovery and wave planning
A 30-day discovery sprint classified all 340+ workloads by sensitivity tier, dependency chain, and migration complexity. Output was a sequenced wave plan with clear rationale and a risk-ranked backlog so every stakeholder could see the order of operations and why.
Dependency mappingRisk classification
โ†’
02.
Landing zone and control baseline
AWS GovCloud landing zone built to NIST 800-53 Rev. 5 High baseline. Identity via Microsoft Entra ID integrated with the agency's existing CAC infrastructure. All infrastructure authored in Terraform with SSP control references in code, so the compliance evidence was generated automatically as infrastructure was deployed.
AWS GovCloudTerraform IaCZero Trust
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03.
Migration factory wave execution
Wave-based migration starting with lowest-complexity workloads to establish landing zone patterns and validate runbooks before high-risk systems moved. AWS Application Migration Service for lift-and-shift; targeted re-architecture for 40+ priority systems where cloud-native patterns offered material operational improvement.
AWS MGNRe-architecture
โ†’
04.
FedRAMP package and 3PAO coordination
SSP, SAR, and POA&M authored in parallel to migration waves. The 3PAO assessors were engaged at wave 2 rather than after completion, giving them a live environment to test against. Control gaps were identified and closed in-flight, not discovered at assessment time when fixing them would collapse the schedule.
SSP ยท SAR ยท POA&M3PAOConMon
โ†’
Results

All 340+ workloads. On schedule.

Every workload migrated within the 18-month window. FedRAMP High ATO was issued on schedule, with the 3PAO citing the SSP documentation quality as among the highest reviewed in a recent civilian agency engagement. The parallel authoring approach meant there were no control gaps discovered at assessment time that required infrastructure rework.

Year-over-year infrastructure costs dropped 42% following data center exit, driven by right-sizing, reserved instance commitments, and elimination of two facility leases. Zero security incidents occurred during the full 18-month migration period, including the parallel-operation window when workloads were split across environments. The agency's internal cloud operations team was trained, documented, and running independently before Ingress rolled off.

FedRAMP High ATO issued on schedule

18-month authorization milestone met. Congressional mandate satisfied without requiring schedule relief or scope reduction.

42% infrastructure cost reduction

Year-over-year savings driven by data center exit, instance right-sizing, and reserved capacity commitments negotiated as part of the migration plan.

Zero security incidents during migration

No incidents across 18 months of parallel operation, including the period with workloads split across on-prem and GovCloud environments.

Independent operations at program close

Agency cloud operations team trained and running independently. Documented runbooks for every operational procedure before Ingress rolled off.

Stack and Frameworks

What we built with.

Cloud

AWS GovCloud.

GovCloud (US-East, US-West), Control Tower, AWS Landing Zone Accelerator, Transit Gateway, Direct Connect for hybrid operation during migration windows.

AWS GovCloudControl TowerDirect Connect
IaC and observability

Terraform and compliance tooling.

All infrastructure in Terraform with SSP control mapping. AWS Config, Security Hub, CloudTrail, and GuardDuty for continuous compliance evidence collection and threat detection.

TerraformAWS ConfigSecurity HubGuardDuty
Compliance

FedRAMP High package.

NIST 800-53 Rev. 5 High control baseline. SSP, SAR, POA&M authored in-flight. Zero-trust per M-22-09 and M-23-22. CAC-integrated identity via Microsoft Entra ID.

NIST 800-53 Rev.5Zero TrustEntra IDCAC
Related

More from this practice.

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// 30 minutes to a written brief.

Bring the compliance requirement or migration timeline. We return with a written scope, wave plan, and honest cost range. FedRAMP-authorized delivery via GSA MAS #47QTCA26D000K.

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GSA MAS#47QTCA26D000K
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