Difference between FedRAMP Moderate Certified and FedRAMP Moderate Equivalency

In the context of the Federal Risk and Authorization Management Program (FedRAMP), both “FedRAMP Moderate Certified” and “FedRAMP Moderate Equivalency” refer to security compliance levels for cloud service providers (CSPs) who offer services to U.S. federal agencies. However, there are distinctions between the two:

FedRAMP Moderate Certified: This indicates that a cloud service provider has undergone the full FedRAMP authorization process and has been officially certified as meeting the FedRAMP Moderate security baseline. This process involves rigorous assessment, documentation, and testing of the CSP’s systems, processes, and security controls to ensure they meet the standards set by FedRAMP.

FedRAMP certification is issued by the Joint Authorization Board (JAB). The JAB is a key component of the Federal Risk and Authorization Management Program (FedRAMP) responsible for providing provisional authorizations to cloud service providers (CSPs). These provisional authorizations are issued based on the JAB’s assessment of a CSP’s security posture and compliance with the FedRAMP security requirements.

Cloud service providers seeking FedRAMP certification can undergo a JAB authorization process in addition to or instead of pursuing agency-specific authorizations. The JAB consists of representatives from the Department of Defense (DoD), the Department of Homeland Security (DHS), and the General Services Administration (GSA).

Once a CSP receives a provisional authorization from the JAB, federal agencies can leverage that authorization to use the CSP’s cloud services without having to conduct their own separate security assessments. However, it’s important to note that the JAB’s provisional authorization does not automatically grant full FedRAMP certification. CSPs must still undergo additional steps, including continuous monitoring and reporting, to achieve full FedRAMP certification.

FedRAMP Moderate Equivalency: This term refers to an alternative path for federal agencies to adopt cloud services that have not undergone the formal FedRAMP certification process but can demonstrate an equivalent level of security controls and compliance. This can be achieved through an agency-specific risk assessment (SAR) or through other means that demonstrate compliance with the FedRAMP Moderate baseline. Essentially, it means that while the CSP may not have the official FedRAMP certification, their security measures are deemed equivalent to those required for FedRAMP Moderate certification.

The National Institute of Standards and Technology (NIST) oversees the Federal Risk and Authorization Management Program (FedRAMP). When it comes to issuing a FedRAMP moderate equivalency, it would typically be managed by the FedRAMP Program Management Office (PMO) within NIST. This equivalency may be granted under certain circumstances where a cloud service provider (CSP) has undergone a security assessment and meets security requirements that are equivalent to the FedRAMP moderate baseline,

The role of a Third Party Assessment Organization (3PAO) is to conduct security assessments on behalf of cloud service providers (CSPs) seeking FedRAMP certification. Once the assessment is completed, the 3PAO submits their findings and recommendations to the FedRAMP Program Management Office (PMO). The PMO then reviews the assessment report and makes the final determination regarding the CSP’s compliance with FedRAMP standards.

In the context of the Cybersecurity Maturity Model Certification (CMMC), achieving FedRAMP Moderate equivalency is a significant requirement for Cloud Service Offerings (CSOs) handling sensitive information for the Department of Defense (DoD). To be considered FedRAMP Moderate equivalent, CSOs must achieve 100 percent compliance with the latest FedRAMP moderate security control baseline, and maintain a continuous monitoring program to assure compliance with FedRAMP security standards.

In summary, “FedRAMP Moderate Certified” indicates formal certification through the FedRAMP program, while “FedRAMP Moderate Equivalency” suggests that a cloud service provider’s security measures are considered equivalent to the FedRAMP Moderate standards, even if they haven’t undergone the full certification process.  It should noted that Federal Information Systems must use FedRAMP Moderate Certified CSP.  Contractors that support DOD contracts can use FedRAMP Moderate Equivalency CSP.

Read the detailed FedRAMP report.