What is FedRAMP Moderate Equivalency?

FedRAMP Moderate Equivalency denotes a critical standard for cloud service providers aiming to ensure the security and confidentiality of federal information that resides in cloud environments. This pivotal benchmark is part of the broader Federal Risk and Authorization Management Program (FedRAMP) compliance process, which establishes a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services.

Understanding FedRAMP Moderate Equivalency is essential for cloud service providers who must meet specific requirements to achieve this level of compliance. Achieving FedRAMP Moderate Equivalency signifies that a cloud service has implemented the necessary security controls to safeguard federal data against potential threats, making it a crucial milestone for providers looking to serve federal agencies effectively.

In this article, we’ll take a close look at FedRAMP Moderate Equivalency, what it means, how it helps cloud service providers and defense contractors, and how it differentiates from FedRAMP Moderate Authorized. This distinction will help defense contractors make an informed decision when shopping for a cloud–based file sharing solution as part of the CMMC certification process. Defense contractors must understand the difference as one is compliant with CMMC, the other is not.

The CMMC certification process is arduous but our CMMC 2.0 compliance roadmap can help.

FedRAMP Basics: A Prelude to Moderate Equivalency

Before delving into the specifics of FedRAMP Moderate Equivalency, it is essential to understand the foundational aspects of FedRAMP. FedRAMP is a government–wide program that promotes the adoption of secure cloud services across the Federal Government by providing a standardized approach to security assessment, authorization, and continuous monitoring for cloud products and services. This framework ensures that all cloud service providers (CSPs) meet a baseline set of standards that protect government data.

The program categorizes cloud services into low, moderate, and high impact levels, based on the sensitivity of the information that will be stored and processed. The vast majority of federal data falls into the moderate impact level, making the FedRAMP Moderate Authorization particularly significant for CSPs looking to service federal agencies. Achieving this authorization is a rigorous process, requiring CSPs to meet over 300 security controls. However, it is a critical step that signifies a CSP’s commitment to maintaining the highest standards of data security and integrity.

Understanding FedRAMP Moderate Equivalency

FedRAMP Moderate Equivalency is a designation that indicates a CSP’s cloud service offering has undergone a security assessment that is equivalent to, but not the same as, the FedRAMP Moderate Authorized baseline. This assessment may have been conducted by the DoD itself or another federal agency with the authority to grant security authorizations that meet or exceed FedRAMP standards. However, it is crucial to note that FedRAMP Moderate Equivalency does not equate to FedRAMP Moderate Authorization.

The distinction lies in the formal recognition and accreditation by the FedRAMP Program Management Office (PMO). While a cloud service with a FedRAMP Moderate Equivalency might meet or even exceed the security controls of the FedRAMP Moderate baseline, it has not been formally authorized by the FedRAMP PMO. This difference is of significant importance to DoD contractors and subcontractors when selecting cloud services, as reliance on a service with only a Moderate Equivalency could risk non–compliance with DoD–specific requirements, particularly the Cybersecurity Maturity Model Certification (CMMC).

The DoD recently addressed the distinction between the two certifications to ensure defense contractors understood the difference. The DoD memo stems from confusion in the marketplace, exacerbated by concerns that some CSPs aren’t clarifying the difference with their DoD contractor customers. Defense contractors who are misinformed or misled to believe they are CMMC compliant by using a FedRMAP Moderate Equivalent cloud storage solution, rather than a FedRAMP Moderate Authorized solution, are mistaken. It begs repeating: FedRAMP Moderate Equivalency does not equate to FedRAMP Moderate Authorization.

FedRAMP Moderate Equivalency Requirements

For a CSP to achieve FedRAMP Moderate Equivalency, it must undergo a thorough security assessment that demonstrates its services’ alignment with over 300 security controls specified in the FedRAMP Moderate baseline. These controls cover a wide range of security domains, including access control, incident response, and risk management, among others. CSPs must show not only adherence to these controls but also the ability to continuously monitor and update their security practices in response to emerging threats.

However, attaining FedRAMP Moderate Equivalency does not end the journey for CSPs aiming to serve DoD entities. Due to the lack of formal authorization by the FedRAMP PMO, CSPs with only equivalency status may find themselves ineligible for certain DoD contracts that require FedRAMP Moderate Authorization. This distinction underscores the importance of understanding and navigating the FedRAMP compliance process effectively, to not only achieve equivalency but to progress towards full authorization.

FedRAMP Moderate Authorized: The Gold Standard

FedRAMP Moderate Authorization represents the gold standard for CSPs, indicating full compliance with the comprehensive set of FedRAMP security controls. This authorization is granted directly by the FedRAMP PMO and signifies that a CSP’s cloud service offering has been rigorously assessed and authorized for use by any federal agency, including the DoD. Achieving FedRAMP Moderate Authorization is a significant accomplishment for CSPs, underscoring their dedication to upholding the highest levels of security and data protection.

For DoD contractors and subcontractors, selecting a CSP with FedRAMP Moderate Authorization alleviates concerns about the adequacy of cloud service security controls. It ensures compliance with the DoD’s stringent requirements and aligns with the mandates of the CMMC. This direct authorization serves as a clear indication that the chosen cloud service is fully vetted and approved for handling sensitive federal information, thereby reducing the risk of non–compliance and potential security vulnerabilities.

The Risk of Confusing FedRAMP Moderate Equivalency with FedRAMP Moderate Authorization

DoD subcontractors face significant risks when they confuse FedRAMP Moderate Equivalency with FedRAMP Moderate Authorization. The assumption that equivalency is sufficient for compliance with DoD requirements can lead to the adoption of cloud services that, while secure, may not meet the specific needs or compliance requirements mandated by the DoD. This misunderstanding can result in non–compliance with CMMC, a critical framework designed to enhance the cybersecurity posture of the Defense Industrial Base (DIB).

Non–compliance with CMMC carries severe repercussions for DoD contractors and subcontractors. It can lead to the loss of eligibility for DoD contracts, reputational damage, and potential security breaches. The CMMC framework is structured to protect Controlled Unclassified Information (CUI) within the DIB, and adherence to its requirements is not negotiable. Therefore, understanding the clear distinction between FedRAMP Moderate Equivalency and FedRAMP Moderate Authorization is imperative for ensuring compliance and maintaining the integrity of operations within the DoD supply chain.

Distinguishing Between Equivalency and Authorization for CMMC Compliance

The Cybersecurity Maturity Model Certification (CMMC) framework plays a pivotal role in distinguishing between FedRAMP Moderate Equivalency and FedRAMP Moderate Authorization for DoD contractors and subcontractors. CMMC, a set of cybersecurity standards necessary for all DoD contracts, emphasizes the need for comprehensive and formally recognized cybersecurity practices. While FedRAMP Moderate Equivalency may indicate a high level of security alignment, without the formal authorization by the FedRAMP PMO, CSPs may not fully meet the CMMC requirements stipulated for DoD contracts.

Need to comply with CMMC? Here is your complete CMMC compliance checklist.

This alignment with CMMC prerequisites is where FedRAMP Moderate Authorization sets itself apart. By achieving this level of authorization, CSPs affirm that their cloud services have been rigorously assessed and approved by the FedRAMP PMO, thereby meeting the CMMC requirements for handling controlled unclassified information (CUI) within the DoD’s defense industrial base (DIB). This not only ensures compliance with DoD standards but also significantly mitigates the risk of cybersecurity vulnerabilities and non–compliance penalties.

The Importance of Pursuing FedRAMP Moderate Authorization

While achieving FedRAMP Moderate Equivalency is a noteworthy accomplishment for any CSP, it is merely a stepping stone towards the ultimate goal of FedRAMP Moderate Authorization. Authorization signifies a CSP’s full compliance with the FedRAMP security framework and its acceptance across all federal agencies, including the DoD. It is a testament to a CSP’s commitment to the highest standards of security and data protection, ensuring their eligibility for a broader range of federal contracts and bolstering their reputation within the federal marketplace.

DoD contractors and subcontractors must, therefore, prioritize engaging with CSPs that have achieved FedRAMP Moderate Authorization. This not only ensures adherence to DoD’s stringent security requirements but also aligns with the overarching goals of the CMMC framework. By choosing CSPs that are fully authorized, DoD entities can safeguard their operations against security risks and maintain compliance with federal cybersecurity mandates.

Kiteworks Helps Defense Contractors Demonstrate CMMC Compliance With a FedRAMP Moderate Authorized Private Content Network

Understanding the critical differences between FedRAMP Moderate Equivalency and FedRAMP Moderate Authorization is essential for DoD contractors, subcontractors, and CSPs navigating the complex landscape of federal cloud service provisions. While both achievements indicate a high level of security and compliance, it is the formal FedRAMP Moderate Authorization that provides the comprehensive assurance of security and compliance necessary for DoD contracts. This guide emphasizes the importance of not only aiming for equivalency but progressing towards full authorization to meet the DoD’s stringent requirements and support national security effectively.

As we move forward, it is imperative for all stakeholders in the defense supply chain to recognize the significance of these distinctions and the role they play in maintaining the integrity and security of DoD operations. By prioritizing full compliance with FedRAMP and CMMC standards, we can ensure a secure and resilient federal cloud ecosystem.

The Kiteworks Private Content Network, a FIPS 140-2 Level validated secure file sharing and file transfer platform, consolidates email, file sharing, web forms, SFTP, managed file transfer, and next-generation digital rights management solution so organizations control, protect, and track every file as it enters and exits the organization.

Kiteworks supports nearly 90% of CMMC 2.0 Level 2 requirements out of the box. As a result, DoD contractors and subcontractors can accelerate their CMMC 2.0 Level 2 accreditation process by ensuring they have the right sensitive content communications platform in place.

With Kiteworks, DoD contractors and subcontractors unify their sensitive content communications into a dedicated Private Content Network, leveraging automated policy controls and tracking and cybersecurity protocols that align with CMMC 2.0 practices.

Kiteworks enables rapid CMMC 2.0 compliance with core capabilities and features including:

• Certification with key U.S. government compliance standards and requirements, including SSAE-16/SOC 2, NIST SP 800-171, and NIST SP 800-172
• FIPS 140-2 Level 1 validation
• FedRAMP Authorized for Moderate Impact Level CUI
• AES 256-bit encryption for data at rest, TLS 1.2 for data in transit, and sole encryption key ownership

Kiteworks deployment options include on-premises, hosted, private, hybrid, and FedRAMP virtual private cloud. With Kiteworks: control access to sensitive content; protect it when it’s shared externally using automated end-to-end encryption, multi-factor authentication, and security infrastructure integrations; see, track, and report all file activity, namely who sends what to whom, when, and how. Finally demonstrate compliance with regulations and standards like GDPR, HIPAA, CMMC, Cyber Essentials Plus, IRAP, and many more.

To learn more about Kiteworks, schedule a custom demo today.

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