How GovRAMP High Baseline Stacks Up Against FedRAMP Class D (High)

GovRAMP (formerly StateRAMP) continues to provide useful avenues for Cloud Service Providers (CSPs) to build secure products for use by State agencies. Earlier this year, GovRAMP released a modified high baseline for CSPs to leverage in protecting the most sensitive SLED data processed by agencies.

The requirements remain largely similar to FedRAMP. For CSPs already certified as FedRAMP Rev 5 Class D (formerly High baseline), the security posture in place largely transfers to GovRAMP high baseline.

Both frameworks are built on the same NIST SP 800-53 Revision 5 foundation. GovRAMP’s High baseline and FedRAMP’s Rev 5 Class D baseline draw from the same control families and the same underlying security architecture. The differences that do exist are not accidental and are a result of the different regulatory environments and customer bases that GovRAMP and FedRAMP serve.

The Control Modifications from FedRAMP to GovRAMP High Baseline

GovRAMP’s Federal Overlay comparison identifies 12 control differences from FedRAMP’s High baseline, which fall into four categories. Here’s a high-level roll up of the differences:

Personal Identity Verification (PIV) Cards - IA-02(12), IA-08(01), SA-04(10)

GovRAMP has not selected the three controls centered around PIV cards for obvious reasons. FedRAMP Rev 5 Class D mandates that CSPs accept and verify PIV credentials from non-organizational Federal users and that they limit those cards to FIPS 201-approved PIV products.

If your customer base is federal agencies requiring PIV authentication, then you cannot rely on a GovRAMP High authorization alone. For state-only deployments, PIV is not a baseline requirement, and the GovRAMP path is sufficient.

Cryptographic Standards – CP-09(08), IA-02(06), MP-05, SC-13

When it comes to cryptography, GovRAMP accepts a broader range of modules. CSPs working to meet GovRAMP parameters can use encryption that follows government requirements, including cryptographic modules that are in “Review Pending” status. If you’re dual-tracking, then you’ll still need to build according to FedRAMP’s requirement to use FIPS-validated modules when encrypting Federal data.

Federal Policy Memo Alignment – AU-11, CA-6, SC-8(1), SI-4(10)

Four controls had parameters tied to federal policy memos (M-21-31, M-22-09) and OMB guidance (A-130). Since these memos apply to federal agencies, not state agencies, GovRAMP has not incorporated that language into the associated GovRAMP parameters for these controls.

Red Teaming – CA-08(02)

GovRAMP does not require a red team engagement for authorization. However, the absence of a requirement does not mean the absence of value. Red team exercises can provide visibility into real-world attack patterns and organizational response capabilities that compliance testing cannot surface.

Many CSPs pursuing GovRAMP High are doing so to build credibility for eventual federal sales or to serve state agencies handling increasingly sensitive data.

Why GovRAMP High Matters

The differences between the two programs are a result of the different requirements between State and Federal agencies. GovRAMP has created a path that is highly aligned to existing federal requirements.

Whether you pursue GovRAMP High as your entry point or leverage an existing FedRAMP Class D certification, the 12 control differences are manageable and well-documented in the overlay. Either version demonstrates significant dedication to the protection of government data to increasingly sophisticated government customers.

How Schellman Can Help with Your GovRAMP Journey

Schellman is the #1 independent assessor in the FedRAMP marketplace, and we've brought that same expertise and rigor to GovRAMP since conducting our first assessment in 2022. Whether you’re mapping your authorization roadmap across both frameworks or focusing solely on the SLED market, our deep experience with both programs positions us to guide you efficiently through the compliance journey.

We understand the nuances of aligning your security posture across federal and state agency requirements. With Schellman, you gain not just an assessor, but a partner who knows the landscape, anticipates obstacles, and has successfully guided organizations like yours through both FedRAMP and GovRAMP authorizations. Contact us today to learn more about how we can help you navigate the path forward with confidence.