Navigating FedRAMP High Authorization is a critical process for CSPs seeking to offer services to federal agencies. This authorization ensures that a cloud offering meets stringent security requirements to handle the most sensitive federal information. It demonstrates a high level of security that can lend itself to other federal government applications.

This article will delve into FedRAMP High’s technical intricacies, essential requirements, and strategies for achieving and maintaining compliance.

What Is FedRAMP High Authorization?

FedRAMP High Authorization is the highest requirement under FedRAMP and is typically applied to federal contexts.

The “High” classification comes from FIPS 199, which defines “impact levels” based on the data involved and how the loss of confidentiality, integrity, or availability will affect constituents:

Low Impact: The loss of confidentiality, integrity, or availability would have a limited adverse effect on organizational operations, assets, or individuals. This level is often used for systems that handle less sensitive information, usually, that’s already public if not immediately available.
Moderate Impact: The loss of confidentiality, integrity, or availability would have a serious adverse effect. Moderate-level systems handle data where breaches could lead to financial loss, reputational damage, or other significant but not catastrophic impacts.
High Impact: The loss of confidentiality, integrity, or availability would have a severe or catastrophic adverse effect on organizational operations, assets, or individuals. FedRAMP High is assigned to systems that handle susceptible information, such as law enforcement data, emergency services, and healthcare information.

To achieve FedRAMP High, CSPs must meet 421 controls derived from NIST SP 800-53, a robust catalog of security and privacy controls tailored for information systems.

Key Requirements for FedRAMP High

The backbone of FedRAMP’s compliance framework is NIST Special Publication 800-53. FedRAMP High’s controls are stricter than those at the Low and Moderate levels, covering a broad array of security domains, including:

Access Control (AC): Only authorized users can access sensitive data. This includes implementing multi-factor authentication (MFA), strong password policies, and detailed access logging. Given the sensitivity of the data, granular access controls are critical.
Configuration Management (CM): A well-documented and robust configuration management plan ensures that all software, systems, and networks are configured securely, adhering to a baseline that minimizes vulnerabilities. Automated tools for continuous configuration checks are essential here.
Incident Response (IR): CSPs must have detailed, tested, and regularly updated incident response plans. These plans must include procedures for identifying, containing, and recovering from security incidents and communicating these incidents to affected agencies.
Continuous Monitoring (CM): Monitoring is a hallmark of FedRAMP compliance. It requires real-time monitoring of systems for security threats and vulnerabilities. Continuous monitoring also involves automated tools that report compliance status and alert administrators to issues needing immediate attention.
Encryption and Key Management (SC): Strong encryption protocols are mandatory for protecting data at rest and in transit. Key management policies must be detailed, with strict controls over who can access and manage encryption keys.

System Security Plan (SSP)

A System Security Plan is fundamental to FedRAMP authorization. The SSP outlines how the required controls are implemented within the CSP’s infrastructure. This document must be comprehensive, detailing everything from encryption methods to data backup policies. The SSP forms the core of the compliance package submitted to the Joint Authorization Board (JAB) or an Agency Authorizing Official (AO) for review.

Steps to Achieve FedRAMP High Authorization

FedRAMP Authorization is an involved process no matter the impact level–but the fact that high impact is so involved means that organizations may have to rethink their approach to security completely.

Some of the foundational steps you should take when preparing for your first high-impact Authorization include:

Conduct a Gap Analysis

Before beginning the FedRAMP Authorization journey, CSPs should perform a comprehensive gap analysis. This involves mapping current security practices against the requirements of FedRAMP High to identify deficiencies. Tools offering control cross-references, such as Continuum GRC’s automapping capabilities, can simplify this process by highlighting overlapping controls with frameworks like NIST SP 800-171, ISO 27001, and HIPAA.

Implement Robust Secure Configuration Management (SCM)

Secure Configuration Management (SCM) ensures that all systems and applications are securely configured from the start and remain so throughout their lifecycle. Automated SCM tools, such as Chef, Ansible, or Puppet, can help enforce security baselines and quickly detect configuration drifts and deviations from approved configurations that could introduce vulnerabilities. Regular audits and automated compliance checks are vital for maintaining a secure state, especially in a high-risk environment.

Establish Continuous Monitoring and Incident Response

Automated continuous monitoring solutions, such as Security Information and Event Management (SIEM) systems, are essential for maintaining a high-security posture. These systems aggregate and analyze data from multiple sources, enabling quick detection and response to anomalies and potential security incidents. Additionally, integrating Endpoint Detection and Response (EDR) tools can provide real-time threat intelligence and facilitate swift remediation measures.

Best Practices for Maintaining FedRAMP High Compliance

Alongside your foundational efforts towards a new security posture, you’ll also want to maintain some significant operational and cultural practices to ensure that you always meet high-impact requirements.

Resource Allocation: FedRAMP High’s rigorous requirements can be resource-intensive. CSPs must allocate adequate resources, including budget, personnel, and time, to effectively implement and maintain all controls. Smaller organizations might face significant challenges here but can consider Managed Security Service Providers (MSSPs) to help bridge the gap.
Addressing Configuration Drift: Configuration drift can lead to non-compliance and security vulnerabilities. Automating SCM helps mitigate this risk by providing consistency across all deployed systems. Regular audits ensure that systems remain compliant with the established security baseline.
Ensuring Consistency Across Multi-Framework Environments: For CSPs navigating multiple compliance frameworks, such as StateRAMP, CJIS, or CMMC, aligning these frameworks with FedRAMP requirements can streamline efforts. Automapping tools can help identify overlapping controls across frameworks, reducing the need to implement separate compliance measures for each. This integrated approach saves time and resources while ensuring a robust security posture.
Regularly Update Security Policies: As cybersecurity threats evolve, so should your security protocols. Regular policy reviews and updates are crucial for maintaining compliance.
Continuous Training and Awareness Programs: Regularly training employees on cybersecurity best practices helps mitigate human error, which remains one of the most significant security threats.
Periodic Security Assessments: Regular internal and third-party security assessments can help identify potential weaknesses before they are exploited. These assessments should be incorporated into a broader continuous monitoring program.
Leverage Automated Tools: AI and automated tools can streamline tasks such as monitoring, reporting, and compliance checks. These tools can track deviations in real-time, significantly reducing IT teams’ workload and helping maintain compliance across different standards.

Never Fall Behind FedRAMP High Authorization with Continuum GRC

Continuum GRC is a cloud platform that stays ahead of the curve, including support for all certifications (along with our sister company and assessors, Lazarus Alliance).

We are the only FedRAMP and StateRAMP-authorized compliance and risk management solution worldwide.

Continuum GRC is a proactive cyber security® and the only FedRAMP and StateRAMP-authorized cybersecurity audit platform worldwide. Call 1-888-896-6207 to discuss your organization’s cybersecurity needs and learn how we can help protect its systems and ensure compliance.

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Navigating FedRAMP High Authorization: A Guide for Enterprises