CMMC compliance requires use of FedRAMP® Moderate authorized services and FIPS 140-2 encryption in many situations. But what does that mean? Neither term is common in the commercial space.
FedRAMP® and FIPS 140-2 play vital roles in securing contractor information systems. But they serve different purposes. Let’s demystify these frameworks and understand how they complement each other in protecting sensitive information.
The Common Ground
FedRAMP® and FIPS 140-2 frameworks both establish standards for their information security:
- FIPS 140-2 sets standards for cryptographic module security
- FedRAMP® defines comprehensive security requirements for cloud services
Both FedRAMP® and FIPS 140-2 emerged from the Federal government’s efforts to enhance information security. Both help keep information out of the hands of those who should not have access to it. They share several fundamental characteristics:
FedRAMP® and FIPS 140 both rely heavily on independent verification. For FIPS 140-2, accredited laboratories conduct rigorous testing of cryptographic modules. This results in an encryption product being certified as “FIPS 140-2 Validated.”
Similarly, FedRAMP® requires Third Party Assessment Organizations (3PAOs) to evaluate cloud service providers’ information security standards and data encryption practices. After a cloud service passes an assessment, it becomes “FedRAMP Authorized.”
Key Distinctions
Despite these similarities, the frameworks serve different purposes and operate differently:
Scope and Focus
FIPS 140-2 specifically targets cryptographic modules – the building blocks of secure communications and data protection. So, it’s focused on encryption hardware and software. It evaluates how well modules implement encryption algorithms, manage keys, and resist tampering.
FedRAMP® takes a broader view. It examines entire cloud service offerings, including their infrastructure, operations, and security practices. This encompasses everything from access control and incident response to physical security and personnel screening.
Implementation Approach
FIPS 140-2 certification is a one-time validation of a cryptographic module’s design and implementation. Once certified, the module remains approved unless modified. You can find a comprehensive list of FIPS 140-2 validated modules here. Click on the “Show All” button to see the complete list. As of February 11, 2025, there are 1104 FIPS 140-2 validated modules.
FedRAMP® takes a more dynamic approach. Beyond initial authorization, it requires continuous monitoring and regular reassessment to ensure cloud services maintain their security posture as threats evolve. A complete list of FedRAMP® authorized cloud service providers can be found here.
Security Levels
These frameworks also differ in how they categorize security requirements. FIPS 140-2 defines four security levels based on physical security and tamper resistance. FedRAMP®, meanwhile, aligns with FIPS 199 impact levels (Low, Moderate, High) based on the potential impact of security breaches.
Practical Implications
FIPS 140-2 validated modules must be used when transmitting CUI outside of your organization’s boundaries. Many companies advertise FIPS 140-2 compliant products. But that is not sufficient. They must be validated.
Likewise, Cloud Service Providers (CSPs) that store CUI must be FedRAMP® authorized at the Moderate level. DFARS 252.204-7012 – (b)(2)(ii)(D)
Looking Forward
FIPS-140 module validation is a long, expensive, process. FedRAMP® is even more costly, with certification costs over $1M. This means that choices are limited. However, the good news is that the common CSPs like AWS, Azure, and Google are certified. This gives organizations viable options for compliance.
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