Decoding FedRAMP Baselines: Get to Know Low, Moderate, and High Impact Levels for Compliance

Understanding FedRAMP is crucial for cloud service providers (also known as CSPs) looking to work with the U.S. government. FedRAMP stands for Federal Risk and Authorization Management Program, and it plays a pivotal role in securing cloud services utilized by federal agencies.

Key Takeaways

  • FedRAMP is an assurance framework that ensures the security of cloud services used by the U.S. federal government by categorizing information systems into Low, Moderate, and High impact levels based on the severity of potential data breaches. (FIPS-199 is based on Confidentiality, Integrity, and Availability. A data breach would affect Confidentiality, but there are other factors for what impact level data is classified at as well).
  • “Information system” also refers to a cloud service offering (CSO).
  • CSPs must adhere to stringent security controls, including the implementation of 421 controls (410 for revision 5) at the High Impact Level, to comply with the baseline and safeguard sensitive unclassified government data against significant threats.
  • Beyond initial authorization, the program requires continuous monitoring and maintenance of compliance to ensure cloud services remain secure against emerging threats.
  • Achieving and maintaining authorization enhances the CSO’s marketability and competitive edge within federal markets.

Learn more: FedRAMP’s Real Security Value Is In The Sound Baselines It Provides

FedRAMP is The Path to Secure Federal Cloud Adoption

FedRAMP, or Federal Risk and Authorization Management Program, is the U.S. federal government’s strategic approach to ensuring the security of cloud services used by its agencies. Think of it like a security guard that ensures only secure and compliant cloud services can enter.

Cloud Service Providers (CSPs) play a significant role in this security program. They are the ones providing the cloud services and must therefore ensure they meet FedRAMP’s stringent security controls. This guarantees federal agencies can adopt secure cloud solutions, and CSPs can offer their cloud service offerings to a wider federal audience.

Learn how you can achieve FedRAMP authorization for your cloud service offerings.

Program Foundations: Security Categorization

The cornerstone of the program’s strength lies in its security categorization, grounded in the Federal Information Processing Standard 199 (FIPS 199). This standard categorizes federal information and information systems into three impact levels: Low, Moderate, and High. Picture these levels as the three locks on a safe, each offering a different level of security based on the potential impact a breach could have on the organization.

CSPs must comprehend the FIPS 199 classification to effectively participate. It’s like having the blueprint to the safe, allowing them to tailor their security controls to meet the requirements of the FedRAMP authorization process, ensuring their cloud services are ready for US federal government use.

The FedRAMP Compliance Landscape: You’re Not Alone

CSPs have a central part in achieving Authority to Operate (ATO). They are like the jewelers crafting the gems (cloud services), ensuring they meet the strict quality standards set by FedRAMP. This means adhering to the Low, Moderate, or High impact level requirements, depending on the type of data their cloud services deal with.

This process, however, is complex, to say the least.

The good news is that CSPs are not alone on the journey to FedRAMP compliance. Organizations like 38North Security act as guides, helping CSPs transition from non-authorized to authorized, and even moving up from Low to Moderate or Moderate to High FedRAMP authorization.

Learn about your unique path to FedRAMP authorization. Speak to a security expert today.

The Spectrum of Impact Levels: Low, Moderate, and High

FedRAMP categorizes systems into three impact levels: Low, Moderate, and High. Each level represents the potential impact a breach could have on the confidentiality, integrity, and availability of the information system. This is similar to categorizing flood levels based on the potential damage they could cause.

Each level requires adherence to a varying number of security controls, which escalate with the impact level. To oversimplify, this is akin to increasing the number of guards as the value of the asset they are protecting increases.

Low Impact Level

The Low Impact Level has two baselines: Low and LI-SaaS. These are similar to the security measures you would take for everyday valuables. FedRAMP considers this level appropriate for CSOs where “the loss of confidentiality, integrity, and availability would result in limited adverse effect on an agency’s operations, assets, or individuals.”

Low Baseline

This is the baseline security standard for CSOs intended for public use and generally low risk. In other words, this is a situation where a potential breach would not have a substantially adverse effect on an organization’s operations.

The Low Baseline is composed of 125 controls (156 for revision 5), consolidates security documentation, and has a shorter timeline to ATO (compared to Moderate and High).

FedRAMP Tailored Li-SaaS Baseline

In 2017, the federal government launched FedRAMP Tailored Li-SaaS to make entry easier for low-risk cloud products. It simplifies the process by requiring fewer security controls, being a subset of Low’s 125. The process is also lower-cost.

The LI-SaaS Baseline is designed for Low-Impact SaaS applications that do not store any personal identifiable information (PII) beyond the bare essentials needed for login. Examples of this information include username, password, and email address.

In order to qualify for Tailored, your CSO must answer “yes” to each of these questions:

  1. Does the service operate in a cloud environment?
  2. Is the cloud service fully operational?
  3. Is the cloud service a Software as a Service (SaaS), as defined by NIST SP 800-145, The NIST Definition of Cloud Computing?
  4. Does the cloud service contain no personally identifiable information (PII), except as needed to provide a login capability (username, password and email address)?*
  5. Is the cloud service low-security-impact, as defined by FIPS PUB 199, Standards for Security Categorization of Federal Information and Information Systems?
  6. Is the cloud service hosted within a FedRAMP-authorized Platform as a Service (PaaS) or Infrastructure as a Service (IaaS), or is the CSP providing the underlying cloud infrastructure?

*Agencies have the responsibility of managing users and agency data to ensure that the LI-SaaS CSP services are utilized in accordance with Federal mandates and agency policies and procedures.

Moderate Impact Level

The Moderate Impact Level is the choice for systems where a breach could have serious consequences. It’s the equivalent of the security needed for a small vault of precious jewels, increasing the security measures to protect more sensitive data. This includes data that is not publicly available, considered controlled unclassified information. An example of this is PII.

This level requires the implementation of 325 security controls for revision 4, and 323 for revision 5. These enhanced controls require the automation of many management and risk detection functions.

A breach at this level could lead to significant adverse impacts on an agency’s organizational operations, organizational assets, or individuals, similar to a significant theft from a small business. It could lead to substantial operational impairment and financial loss, but not to the extent of causing a catastrophic adverse effect, such as loss of life.

High Impact Level

At the top of the spectrum is the High Impact Level, the Fort Knox of security. This level is designed for the most sensitive systems, such as law enforcement, financial systems, emergency services, and health systems, where a breach could have severe or catastrophic adverse impact. A breach at this level could lead to significant consequences, such as financial ruin or an economic crisis, greatly affecting government bodies and their operations.

To safeguard such sensitive data, a CSP must implement 421 security controls (410 for revision 5), ensuring the government’s most sensitive, unclassified data is protected against threats that could potentially impact life, cause financial devastation, or other catastrophic consequences.

New to the process? Read our FedRAMP Beginner’s Guide to Authorization.

From Authorization to Continuous Monitoring: The FedRAMP Lifecycle

Much like a security guard’s shift doesn’t end once the premises are locked, the FedRAMP process doesn’t stop at authorization. The cycle of securing the cloud involves authorization, continuous monitoring (also known as “ConMon”). This ensures that the security measures are not only implemented but also continuously updated and improved to meet emerging threats.

CSPs have a significant responsibility in this procedure. They must:

  • Regularly re-assess their security controls.
  • Engage with agencies for ongoing monitoring and reporting on risk posture.
  • Ensure that the security measures are effective and up-to-date.

This continuous vigilance ensures that FedRAMP requirements are upheld throughout the lifecycle of the cloud service.

Special Considerations for Sensitive Systems

Certain systems, due to the sensitive nature of the data they handle, require special considerations. This is where the Department of Defense (DoD) Impact Levels come into play, acting as an additional layer of protection for these systems. These levels classify information systems and the data they handle, ensuring they have the necessary security measures in place.

Sensitive systems that may necessitate these specific DoD Impact Levels include those dealing with national security systems (NSS), controlled unclassified information (CUI), and emergency services systems. These systems require a higher level of protection than what the standard FedRAMP baselines offer, ensuring the utmost protection for the most sensitive data.

Enhancing Security with FedRAMP Controls

FedRAMP controls, based on NIST SP 800-53, are like the building blocks used to construct the fortress of security for cloud services. CSPs can use these controls to enhance their security posture and address compliance with other cybersecurity programs beyond FedRAMP with similar requirements.

These controls ensure that CSPs implement the necessary security measures to safeguard federal data in cloud environments. In addition, they provide a standardized set of prerequisites for authorization and ConMon, ensuring a uniform approach to security. The implementation of these controls is monitored throughout the system lifecycle, ConMon requirements, ensuring the security measures remain effective and current.

FedRAMP’s Impact on Federal Cloud Strategies

FedRAMP has been a game-changer in shaping federal cloud strategies. It has:

  • Enhanced cybersecurity
  • Streamlined the assessment process
  • Improved the overall customer experience through its authorization and ConMon processes

This allows federal agencies, under the guidance of the federal government, to adopt modern cloud technologies with confidence, knowing their data is secure and they can store personal identifiable information safely.

When developing a federal cloud strategy, consider the elements of the applicable FedRAMP baseline, including security measures, procurement policies, and workforce capabilities. This ensures that the chosen cloud services meet the rigorous requirements for federal use, ensuring a secure and efficient cloud strategy.

The Benefits of FedRAMP Authorization for CSPs

FedRAMP authorization offers several benefits to cloud service providers (CSPs):

  • It demonstrates adherence to regulations and earns a badge of trust.
  • It enhances the CSP’s marketability and competitive edge.
  • It improves security and compliance, making the CSP stand out in the crowded cloud services market.

Moreover, FedRAMP authorization offers the following benefits:

  • Opens the doors to a substantial market of federal customers who require compliance with FedRAMP.
  • Can be used by any federal agency, expanding the CSP’s reach to a wider audience.
  • Streamlined authorization process and ConMon result in heightened confidence in security.

Frequently Asked Questions

What is “FedRAMP equivalent?”

FedRAMP equivalent refers to cloud providers meeting security requirements equivalent to the applicable FedRAMP baseline, as covered in the Defense Federal Acquisition Regulation Supplement (DFARS) 252.204-7012.

Is FedRAMP the same as NIST?

FedRAMP uses the framework provided by NIST to establish standardized security requirements for cloud services used by federal agencies. This enables U.S. government agencies to securely and efficiently use cloud services.

How much does FedRAMP cost?

The cost of FedRAMP accreditation can vary depending on the project model, nature of services purchased, and assistance required, typically ranging between $250,000 to $3 million.

What are the levels of data classification in FedRAMP?

Federal Risk and Authorization Management Program authorizations are divided into Low, Moderate, and High impact levels, each with increasing security controls, derived from NIST Special Publication 800-53. These baselines do not allow for tailoring of controls based on the confidentiality, integrity, and availability.

Learn more about cloud computing, security assessments, security objectives, potential catastrophic adverse effect to mission critical information, non controlled unclassified information, cloud service offerings csos, your role as a cloud service provider, and more. What are the effects of the loss of confidentiality integrity to a cloud platform? What are examples of severe or catastrophic adverse impacts to an information system? Talk to 38North Security to learn how FedRAMP grants authorizations and your organization’s unique path.