FedRAMP Moderate

Data centers must implement and maintain all 325 baseline security controls from NIST SP 800-53 Revision 4, spanning 18 control families (Access Control, Audit and Accountability, Security Assessment and Authorization, etc.), with specific control tailoring permitted only through documented risk-based justifications approved by federal authorizing officials.

Each control must be demonstrated as operational and effective through comprehensive testing, with particular rigor applied to AC (Access Control), IA (Identification and Authentication), SC (System and Communications Protection), and SI (System and Information Integrity) families.

Documentation of control implementation must include policy statements, procedure narratives, evidence artifacts (logs, configurations, certificates), and assessment findings that collectively demonstrate compliance against explicit control statements and supplemental guidance.

FedRAMP Moderate requires CSPs to implement continuous monitoring programs generating telemetry from all infrastructure layers, with automated security event logging to a centralized Security Information and Event Management (SIEM) system capable of correlating and analyzing events in near-real-time.

Data centers must achieve detection and reporting of security incidents within one hour of discovery, maintain audit logs with immutable storage for minimum 90 days online and 1 year archive, and conduct monthly vulnerability assessments across all system components.

The continuous monitoring strategy must include privileged account activity monitoring, configuration compliance scanning, threat intelligence integration, and anomaly detection capabilities, with monthly reports submitted to the federal agency demonstrating control effectiveness and identifying any control deficiencies or security events.

Data centers must engage authorized 3PAOs (selected from GSA's approved vendor list) to conduct comprehensive security assessments annually, involving detailed testing of all 325 controls through on-site evaluation, configuration review, log analysis, and interviews with operations staff.

The 3PAO generates a System Security Plan (SSP) documenting control implementation, a Security Assessment Report (SAR) detailing test procedures and results, and a Plan of Action and Milestones (POA&M) identifying any control deficiencies with remediation timelines.

CSPs must remediate identified deficiencies to meet specified timelines: critical findings within 30 days, high-priority within 90 days, and medium/low within 180 days, with progress monitored through GSA's FedRAMP system of record.

Data center infrastructure must employ FIPS 140-2 Level 2 certified cryptographic modules for all data in transit and at rest, with encryption keys managed through Hardware Security Modules (HSMs) or equivalent cryptographic key management systems physically located within the CSP's control.

All data transmission across network boundaries must use TLS 1.2 or higher with approved cipher suites, and sensitive federal data must be encrypted using AES-256 at rest.

Agencies retain explicit requirements to audit cryptographic key generation, storage, and destruction processes, necessitating detailed key management documentation and periodic third-party verification of cryptographic implementation.

Data center facilities must implement multi-layered physical security including 24/7/365 manned security guards, biometric access controls, closed-circuit video surveillance with tamper-evident recording, and environmental controls maintaining audit trails of facility access.

For processing moderate-impact federal data, CSPs must either maintain dedicated data center facilities exclusively for federal workloads or implement validated logical isolation using government-approved boundary protection mechanisms that segregate federal infrastructure from commercial tenant environments.

Physical security assessments by 3PAOs include verification of perimeter controls, access logs covering entry/exit for 12+ months, visitor management procedures, and secure destruction equipment certified for sanitization of magnetic media and solid-state devices.

All CSP personnel with access to federal data or systems must undergo government-performed background investigations meeting OPM (Office of Personnel Management) standards, typically requiring Secret clearance-level adjudication covering criminal history, credit, employment verification, and residency background.

Data center operators must maintain current background investigation documentation for all infrastructure, operations, security, and administrative staff, conduct annual recertification of continued eligibility, and immediately notify federal authorizing officials of personnel changes, security incidents, or investigation findings.

CSPs must implement role-based access training, nondisclosure agreement execution, and rules of behavior acknowledgment for all personnel, with documented evidence maintained in personnel security files.

Data centers must establish incident response procedures with defined escalation paths ensuring federal agency notification within one hour of discovery of any security incident potentially affecting federal data, with detailed incident reports submitted within 24 hours.

Security event classifications must align with NIST SP 800-61 (Computer Security Incident Handling Guide), with suspected breaches reported to US-CERT and relevant federal agencies through established federal incident reporting channels.

CSPs must maintain incident response capability with 24/7 staffing, forensic investigation capacity, evidence preservation procedures, and post-incident analysis documentation to support root-cause determination and control improvement initiatives.

Data centers must develop and maintain comprehensive System Security Plans documenting the security architecture, all 325 control implementations with specific evidence and responsibility assignments, system boundaries, data flows, interconnections, and deployment model characteristics (SaaS, PaaS, IaaS).

The SSP must align with federal agency requirements, document all deviations from baseline controls through formal exception processes, and be updated annually with 3PAO assessment findings, system changes, and control effectiveness updates.

SSPs serve as the authoritative technical reference for federal authorizing officials and must demonstrate traceability between control requirements, implementation narratives, and supporting security documentation.