Mar 10, 2025
FedRAMP Impact Levels Low, Moderate, and High. What's the Difference?
Becoming certified under the Federal Risk and Authorization Management Program (FedRAMP) is a costly and resource intensive undertaking. Obtaining certification and continually staying in compliance can make a major impact on your business as a Cloud Service Provider (CSP).
To lessen the costly and time-consuming process, FedRAMP utilizes a "do once, use many times" Security Assessment Framework (SAF). This approach helps reduce redundancies when conducting security assessments and process monitoring reports.
As part of FedRAMP's effort to streamline compliance, their SAF is standardized into four process areas: Document, Assess, Authorize, and Monitor. Within the Document process area, FedRAMP asks CSPs to determine what types of data they are managing and complete a FIPS PUB 199 worksheet. This step is crucial for categorizing your systems and assessing the impact level of your information.
To aid in this process, CSPs can consult several key resources. The FIPS 199 publication is essential, as it provides guidelines for categorizing types of information and information systems according to security impact levels. Additionally, the NIST SP 800-60 offers a comprehensive guide to mapping information types to security categories. These documents, though extensive, are foundational for understanding and implementing security standards.
Given the complexity and volume of these government publications, they can be daunting. For a more streamlined approach, consider leveraging platforms designed to assist with compliance across various frameworks like FedRAMP, NIST SP 800-171, CMMC, HIPAA, and ISO 27001. Such platforms can help you determine necessary security controls, identify potential redundancies, and simplify your path to certification.
By integrating these resources and tools, CSPs can efficiently navigate the requirements and ensure they accurately assess their impact levels, ultimately facilitating their journey toward achieving compliance.
What is FIPS 199 Worksheet?
FedRAMP didn't create these categorization levels. Instead it borrows from the Federal Information Processing Standard (FIPS) which was developed by the National Institute of Standards and Technology (NIST). Here they've defined three ways of securing data according to Confidentiality, Availability, and Integrity.
To better understand these levels, consider how FIPS 199 defines the three levels of impact for cloud service providers:
Security Objective | Potential Impact | ||
|---|---|---|---|
LOW | MODERATE | HIGH | |
Confidentiality Integrity Guarding against | The unauthorized | The unauthorized | The unauthorized |
Integrity Guarding against improper | The unauthorized | The unauthorized | The unauthorized |
Availability Ensuring timely and reliable | The disruption of access to | The disruption of access to | The disruption of access to |
As you can see in the above chart, there are three FedRAMP impact levels: Low, Moderate, and High. Deciding which set of control requirements to follow depends on the kinds of data you are managing and the different modes of securing and protecting that data. Each subsequent impact level requires additional controls to ensure that your data is adequately protected.
To fully understand how these impact levels are determined, consider the three axes of impact:
Confidentiality: This axis focuses on preserving restrictions on sensitive information access and disclosure. It aims to protect personal and proprietary information, ensuring privacy is maintained.
Integrity: This involves maintaining information accuracy within the system, guarding against unauthorized access, destruction, or modification. It also includes verifying the authenticity of information, ensuring it remains trustworthy and reliable.
Availability: While often overlooked, availability is crucial. It ensures that information can be accessed and used reasonably and timely, only by authorized personnel. Imagine storing all information in a secure but inaccessible black box—it would be safe but useless when needed.
The impact level on each axis dictates the minimum security controls required. If a cloud service provider has a high impact level in any of these areas, it sets the minimum required standard across all axes. This ensures that the provider meets rigorous security demands, safeguarding data from potential threats.
Understanding how these axes interact and influence FedRAMP certification is vital for any cloud service provider seeking compliance. It highlights the importance of not only securing data but also making it accessible to those who need it while maintaining integrity and confidentiality.
Is your Data Low, Moderate, or High Security Impact?
Figuring out which FedRAMP impact levels your Cloud Service Offering (CSO) should follow is critical to the compliance process.
Low Impact Security Level
A low impact level involves data that, if compromised, would cause minimal harm. For example, information such as your name, phone number, or email address falls into this category. While a breach might lead to more spam or robocalls, the overall risk remains low because this information is widely available through other channels.
Confidentiality: Unauthorized disclosure of this data is expected to have a limited adverse effect on organizational operations, assets, or individuals.
Integrity: Any unauthorized changes or destruction of information would similarly have minimal adverse effects.
Availability: Disruptions in accessing or using this information are also expected to have a limited impact.
Understanding Li-SaaS
Li-SaaS, or Low Impact Software as a Service, is a specialized control set designed for systems that handle limited data. Specifically, these systems only manage minimal Personally Identifiable Information (PII) necessary for login purposes and nothing more. This focused approach means that even if a system breach occurs, the impact remains minimal.
Connection to Low Impact Services
The concept of Li-SaaS is tailored to cloud services with lower data sensitivity and operational impact. This unique framework offers two primary advantages:
Streamlined Authorization: For services with a low baseline of data sensitivity, Li-SaaS facilitates a more rapid authorization process. This fast-tracked approach saves time while maintaining essential security standards.
Selective Security Validation: Unlike higher impact services, which undergo extensive evaluations, Li-SaaS allows agencies to concentrate on validating the most critical security controls. Instead of a full-scale audit, a targeted review ensures that core protections are in place, enhancing efficiency without compromising security.
In essence, Li-SaaS provides a pragmatic pathway for cloud service providers operating at a lower risk level, ensuring they meet appropriate security measures without unnecessary complexity.
Moderate Impact Security Level
The moderate security level baseline is required if your data includes personally identifiable information (PII). If this information system is compromised, it would have a serious impact.
Moderate impact cloud services are crucial for organizations that work with sensitive information, often involving government-related data that is not publicly available. This data may not be classified, but its compromise could significantly affect the organization and its personnel.
Confidentiality: Unauthorized disclosure could seriously affect operations, assets, or individuals.
Integrity: Unauthorized modification or destruction could also have serious adverse effects.
Availability: Disruption of access or use could lead to significant operational impacts.
The moderate impact level is the most common category because it covers a wide range of services. From small-scale data access to managing vast amounts of important data, this category encompasses nearly 80% of cloud service providers that receive federal authorization. Although a compromise might lead to injuries, it does not result in loss of life, underscoring its critical but non-lethal level of impact.
High Impact Security Level
High impact encompasses critical personal data such as your social security number or passport details. A breach at this level could result in severe identity theft, with cascading effects that can severely disrupt lives. In a governmental context, this might involve accessing critical operations, posing a threat to national security.
Confidentiality: Unauthorized disclosure could cause severe or catastrophic effects, threatening national security or critical infrastructure.
Integrity: Unauthorized modifications could result in catastrophic consequences, affecting national operations and individual safety.
Availability: The inability to access or use this information could lead to severe disruptions, impacting essential services and possibly resulting in loss of life.
From Low to High: Increasing Number of Controls
Higher security levels require additional security controls, such as higher levels of authentication for people to enter, access, and gain control of these systems. This means more, and increasingly secure ways of determining if the person with access is who they claim to be. This also means ensuring upgraded procedures of validating this information as well as determining what they can have access to and what they can do with this data.
High-Impact Systems
For high-impact systems, some key aspects recommended by FedRAMP include the reduction of human error as much as possible, often done by the means of automation. FedRAMP also suggests guaranteeing that the entire scope of authorization already encompasses the full spectrum of services.
Low-Level Systems
Low-level systems have exactly 125 controls, moderate level systems have 325 controls, while high-level systems are required to comply with 421 controls. With the three levels in place, any federal agency can now store highly sensitive data on any provider of cloud services as long as they are FedRAMP compliant.
To effectively adhere to these security controls, cloud service providers must first determine their impact level. This involves a thorough understanding of their systems, the purpose of their engagement with government entities, and the type of information they will handle. The impact level dictates the necessary security measures, making it crucial to categorize information accurately.
Providers can reference FIPS 199 and NIST SP 800-60, which are essential guides for mapping information and systems to security categories. While these documents are comprehensive, they can be overwhelming due to their extensive standards and definitions.
For a more streamlined approach, providers can leverage comprehensive platforms that assist in categorizing systems, determining necessary controls, and minimizing redundancies. This not only aids in accurately assessing impact levels but also enhances the efficiency of achieving FedRAMP compliance.
Takeaway
Understanding these levels is crucial for cloud service providers tasked with safeguarding data. The standards they follow must match the potential impact of a breach. A service managing only contact details differs significantly from one handling sensitive operations for federal agencies. This delineation underscores the need for tailored security measures aligned with the impact level to protect both individuals and broader governmental functions.
Why is Availability Crucial in Determining Impact Levels?
When considering impact levels in information security, availability plays a pivotal role. Imagine storing all your data in a vault that's virtually impregnable—safe from prying eyes and unauthorized access. This setup seems ideal until you realize that if nobody, not even authorized users, can access this information when needed, it's utterly useless.
The Importance of Availability:
Usability of Information: Information that cannot be accessed effectively serves no purpose. Availability ensures that data and resources are accessible to the right people at the right time, allowing for informed decision-making and efficient operations.
Balancing Security and Accessibility: While it's essential to maintain robust security measures, they shouldn't hinder legitimate access. Availability strikes the balance, ensuring that security protocols don’t become obstacles for those who genuinely need the information.
Support for Critical Operations: Many industries, such as healthcare and finance, depend on the timely access to data. Unavailability can lead to substantial operational bottlenecks or even critical failures, affecting everything from patient care to financial transactions.
Business Continuity: In the event of a crisis or disaster, the ability to access information promptly determines how quickly a company can recover. Availability ensures that systems stay operable, supporting continuous service delivery.
Availability is the backbone supporting the functionality and efficiency of information systems. It allows businesses to operate smoothly and effectively, bolstering overall security by ensuring the rightful flow of information where it's needed most.
Breakdown of FedRAMP Control Types
Why Is Navigating Federal Cybersecurity Standards Important for Government Contracts?
Navigating federal cybersecurity standards is essential for securing government contracts for several reasons. Primarily, these standards ensure that sensitive data is adequately protected, reducing the risk of breaches that could compromise national security.
Classifying Risks: The Framework
Federal cybersecurity guidelines classify cloud services into three distinct impact levels—Low, Moderate, and High—based on the potential risks associated with data exposure.
Low Impact: Involves the management of non-sensitive public information.
Moderate Impact: Encompasses sensitive data that, while unclassified, still requires stringent protection.
High Impact: Involves the handling of operations that are critical to national security.
By understanding this classification, providers can tailor their security measures to aligned risk levels, ensuring they meet federal standards effectively.
Compliance and Competitive Edge
For organizations, adherence to these standards isn't just a matter of compliance; it's a way to gain a competitive edge. Companies that align with federal requirements demonstrate their commitment to data security, which can enhance their reputability. It also signifies preparedness to protect critical data, offering a pivotal advantage in securing government contracts. Failure to comply, on the other hand, can result in disqualification from lucrative bidding opportunities. Learn more about what FedRAMP certification could mean for you company.
Ensuring Proper Security Protocols
Compliance necessitates a comprehensive assessment of systems to identify gaps and implement necessary security controls. Organizations might need to adjust their operations to meet the required standards, implementing specific measures to align with lower impact thresholds, if necessary.
Conclusion
In essence, mastering federal cybersecurity standards is not just a bureaucratic hurdle; it is a foundational requirement for any enterprise aiming to enter or maintain a presence in the government contracting space. It ensures the security and integrity of significant operations and data, safeguarding against potential threats and maintaining national security.
In the end, this will redound to benefits to your organization regarding savings in resources, time, and cost, enhancement of real-time security, improved re-utilization of current security assessment across organizations, enhance transparency, ensure uniformity in approaches to risk-based management, and enrich the authorization process of federal security.
By knowing exactly the kind of data your organization is handling and the kind of protection these data need, you can best determine whether you will require complying to FedRAMP's low, moderate, or high-security base lines.
