FedRAMP High, the highest impact level, is relevant for cloud service providers (CSPs) that manage highly sensitive federal data (related to national security, public health, and other sensitive government functions). This level of certification requires CSPs to implement and maintain rigorous security measures to protect data that, if compromised, could severely impact organizational operations, assets, or individuals.
The stringent security requirements for FedRAMP High ensure that CSPs adopt strong controls across various aspects, including data encryption, access controls, and continuous monitoring. These measures are designed to counteract sophisticated threats and ensure the integrity, confidentiality, and availability of critical federal data.
CSPs seeking FedRAMP High authorization must undergo extensive security assessments and continuous evaluations to maintain compliance with federal standards.
In this article:
- How FedRAMP High Compares to Other Levels
- How to Determine Your Impact Level for FedRAMP
- Key Requirements for FedRAMP High
How FedRAMP High Compares to Other Levels
FedRAMP Low
FedRAMP Low is suitable for cloud services where a loss of confidentiality, integrity, or availability would have limited adverse effects on an agency’s operations, assets, or individuals. The security controls for this level are less stringent compared to higher levels, making it suitable for less sensitive data.
For Low Impact systems, FedRAMP offers two baselines: LI-SaaS Baseline and Low Baseline. The LI-SaaS Baseline applies to low-impact Software-as-a-Service applications that handle minimal personally identifiable information (PII), typically just login credentials like username, password, and email address. The required security documentation and controls are simplified for these applications.
FedRAMP Moderate
FedRAMP Moderate covers cloud services where the impact of data compromise could result in serious adverse effects on an agency’s operations, assets, or individuals. According to data shared by FedRAMP, this impact level accounts for about 80% of CSP applications receiving FedRAMP authorization.
Moderate Impact systems require robust security controls to prevent significant operational damage, financial loss, or harm to individuals that does not involve loss of life or physical harm. The security controls are more comprehensive than those for Low Impact systems.
How to Determine Your Impact Level for FedRAMP
Determining the appropriate FedRAMP impact level for a cloud service involves assessing the potential consequences of data breaches on federal operations. The key steps include:
- Data sensitivity assessment: Identify the types of data your cloud service will handle. Consider the potential impact on national security, public health, and safety if this data were compromised. High-impact data typically includes information crucial to these areas.
- Risk analysis: Evaluate the risk associated with the loss of confidentiality, integrity, and availability of the data. Determine the severity of adverse effects, ranging from limited (Low) to catastrophic (High).
- Consultation with stakeholders: Engage with relevant federal stakeholders, including information security officers and compliance teams, to understand their security requirements and expectations.
- Alignment with FedRAMP categories: Match your findings with the FedRAMP impact levels—Low, Moderate, and High. Each level corresponds to specific security control baselines and the required rigor in managing and protecting data.
- Documentation and justification: Document your assessment process and justification for selecting the impact level. This documentation is crucial for the authorization process and must demonstrate a clear understanding of the data’s sensitivity and the associated risks.
Key Requirements for FedRAMP High
To achieve FedRAMP High certification, cloud service providers must implement the following measures.
1. System Security Plan (SSP)
A System Security Plan (SSP) details the security measures in place for a cloud system, helping to demonstrate compliance with FedRAMP requirements. The SSP must be thorough, covering all aspects of security management, from data handling and user authorization to incident response protocols.
Articulating the security architecture clearly in the SSP is essential for passing the rigorous evaluations for high impact level certification. The document should be continually updated to reflect changes in the system or threat landscape, ensuring compliance is maintained throughout the lifecycle of the cloud service.
2. Security Controls
FedRAMP High mandates a set of strong security controls that exceed the requirements of lower impact levels. These controls address a range of security concerns, including advanced threat protection, data encryption, and network security, ensuring resilient defense mechanisms against potential breaches.
Implementing these controls involves careful planning to meet the specific security requirements of high impact systems. Cloud service providers must rigorously test and validate these controls to ensure they function correctly and provide the necessary level of protection.
Cloud systems must undergo a rigorous third-party assessment to validate the security measures in place. This evaluation is conducted by an accredited Third-Party Assessment Organization (3PAO), which ensures that all security controls meet FedRAMP’s stringent standards.
This assessment includes comprehensive testing and verification of the cloud service’s security posture, aiming to spot any vulnerabilities or compliance gaps.
3. Encryption Standards
Encryption standards for FedRAMP High are significantly more stringent compared to lower levels. Data must be encrypted both at rest and in transit using approved cryptographic methods to ensure the highest level of security for sensitive information.
Cloud providers must implement strong encryption protocols and manage cryptographic keys securely to prevent unauthorized data access. Regular audits and updates to the encryption measures are necessary to counter emerging threats and maintain compliance with FedRAMP.
4. Incident Response
Providers must have detailed incident response plans that outline procedures for quickly detecting, responding to, and recovering from security incidents to minimize any impact on data and services.
These plans need to be tested regularly through drills and real incident handling, ensuring the readiness and effectiveness of response strategies. FedRAMP High also demands rapid reporting of incidents to the appropriate authorities.
5. Personnel Security
All staff involved in managing the high-impact cloud service must undergo thorough background checks to ensure they are trustworthy and capable of handling sensitive government data securely.
Training programs on security awareness and procedures are mandatory, ensuring that personnel are aware of the protocols and practices necessary to maintain the integrity and security of the system. Ongoing assessments and reinforcing of personnel security measures help maintain a secure operating environment.
6. Physical Security
Physical security measures for FedRAMP High must be stringent, with controlled access to data centers, 24/7 surveillance, and protection against unauthorized access or environmental hazards. Security controls should include multiple layers of physical defenses to protect hardware and infrastructure critical to the cloud service.
Regular audits and compliance checks ensure the physical security components are adequate to block breaches or infrastructural failures.
7. Risk Management and Continuous Monitoring
Providers must identify, assess, and mitigate risks continuously, ensuring adaptive responses to changes in the threat landscape. They must be able to demonstrate their implementation of a risk management strategy.
Continuous monitoring involves real-time surveillance of systems and networks, detecting anomalies and potential security breaches as they occur. This allows for immediate action, reducing the risk of major impacts from security incidents.
8. Governance and Compliance
Governance and compliance frameworks ensure that policies and procedures align with FedRAMP High requirements. This includes regular reviews and updates of governance practices to stay compliant with federal regulations and adopting best practices in cloud security management. Documentation and reporting demonstrate adherence to all applicable standards.
