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FedRAMP FIPS 199 Security Categorization & Baseline Screener

FIPS 199 High-Water Mark Calculator & Low-Impact SaaS (Li-SaaS) Eligibility Evaluation (NIST SP 800-53 Rev 5 Standards)

Determine your cloud application's federal security classification by evaluating potential impact levels across Confidentiality, Integrity, and Availability. Test eligibility for the streamlined 36-control Low-Impact SaaS (Li-SaaS) baseline, assess resources, and export an audit-ready compliance boundary memorandum.

Step 1: System & Organization Context

Step 2: FIPS 199 Information Types Matrix2 Active Types

(NIST SP 800-60 Vol II C.2.2.4)

Publicly accessible information, static website pages, and marketing resources.

(NIST SP 800-60 Vol II C.3.5.1)

User profile logins, administrative emails, passwords, and access audit logs.

(NIST SP 800-60 Vol II C.3.5.2)

Social Security numbers, date of birth, home addresses, or tax identifiers of citizens.

(NIST SP 800-60 Vol II C.3.1.2)

Defense technical drawings, legal briefs, sensitive procurement records, or export-controlled details.

(NIST SP 800-60 Vol II C.2.8.1)

Clinical diagnoses, medical history, clinical records, or health insurance claims.

(NIST SP 800-60 Vol II C.2.2.1)

Federal loan applications, grants, billing accounts, or agency balance sheets.

(NIST SP 800-60 Vol II C.2.6.1)

Real-time municipal dispatch data, electrical grid logs, or emergency medical dispatch records.

FedRAMP Low-Impact SaaS (Li-SaaS) Eligibility Evaluation

Because your FIPS 199 overall categorization is LOW, you may qualify for the ultra-streamlined 36-control baseline. Check all 5 mandatory federal criteria below:

The application strictly does NOT store or process SSNs, driver's licenses, biometric records, passport details, or banking coordinates. (Basic email and login names are permitted).

The application does not house defense technical parameters, ITAR/export data, proprietary architectural prints, or non-public federal records.

The application does not capture, transmit, or warehouse patient healthcare identifiers, clinical notes, treatment records, or medical billing data.

The application is built on top of cloud infrastructure that already possesses an active, compliant FedRAMP authorization (e.g. AWS GovCloud, Azure Government).

The system strictly avoids tracking troop coordinates, tactical satellite paths, intelligence analysis reports, or strategic national security logistics.

To satisfy Li-SaaS criteria, all five conditions must be checked, indicating your compliance boundary contains zero high-risk unclassified or sensitive datasets.

FIPS 199 High-Water Mark

Conf.Low
Integ.Low
Avail.Low
Overall System CategorizationLow
DETERMINED FEDRAMP BASELINE
FEDRAMP Low
NIST SP 800-53 Controls:156 Controls
Est. Authorization Timeline:6 – 10 months
Est. 3PAO Assessment Fee:$100,000 – $180,000
Screener Compliance Advisor:Your system is categorized under the standard FedRAMP Low baseline. It requires implementing 156 security controls under NIST SP 800-53 Rev 5. While more comprehensive than Li-SaaS, it is highly manageable for standard commercial SaaS offerings seeking defense or executive branch procurement.

FIPS 199 System Security Categorization Boundary Memorandum

Prepared in accordance with NIST Special Publication 800-60 Guidelines & FedRAMP Policies
Confidential Draft
System Boundary Name:

My Cloud Application

Target Federal Sponsor:

Department of Commerce

Calculated Security High-Water Mark:

SC = { Confidentiality: Low, Integrity: Low, Availability: Low }

FedRAMP Security Baseline:

FEDRAMP Low (156 Controls under NIST SP 800-53 Rev 5)

Analyzed Information Types & FIPS 199 Valuations

Information Type Name (NIST Reference)ConfidentialityIntegrityAvailability
Public Web Content & Marketing Data
NIST SP 800-60 Vol II C.2.2.4
N/ALowLow
Account Credentials & Directory Logs
NIST SP 800-60 Vol II C.3.5.1
LowLowLow

Statutory Compliance & Security Boundary Guidance

  • FIPS 199 Compliance: This categorization was formulated strictly following the High-Water Mark principle mapped out in Section 2 of FIPS Pub 199. Any subsequent inclusion of sensitive data types (such as PHI or ITAR blueprints) will instantly escalate the categorization and security control count.
  • IaaS Boundary Leverage: To maintain the compliance validity of the baseline, the CSP must maintain compliance agreements with the Infrastructure host (their cloud hosting provider). Ensure the Customer Responsibility Matrix (CRM) is imported and analyzed to determine shared vs. customer-owned controls.
  • 3PAO Audit Readiness: All security parameters, policies, system security plans (SSP), and automated compliance test results should be cataloged and mapped directly against NIST SP 800-53 Rev 5 families (specifically including Access Control, Audit & Accountability, and System & Communications Protection).
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Understanding FedRAMP FIPS 199 Security Categorization & NIST Rev 5 Baselines

For software-as-a-service (SaaS) companies aiming to sell their cloud products to federal agencies, navigating the Federal Risk and Authorization Management Program (FedRAMP) is a key commercial gateway. The absolute foundation of the entire authorization framework is the FIPS 199 Security Categorization. It determines not only how your system's data is guarded but also maps out the entire budget, timeline, and audit scope for your engineering teams.

The Mechanics of FIPS 199 (Confidentiality, Integrity, and Availability)

Federal Information Processing Standards Publication 199 (FIPS 199) outlines the formal statutory standards for security categorization. It breaks system and information security down into three distinct objectives:

  • Confidentiality: The objective that handles unauthorized data disclosure or breach. Compromises in confidentiality lead to unauthorized users accessing personal records, defense prints, or billing profiles.
  • Integrity: The objective that governs data accuracy and protects against unauthorized alteration, corruption, or destruction. An integrity breach can disrupt municipal dispatch systems or distort payroll ledgers.
  • Availability: The objective managing the continuous readiness and reliability of the cloud service. Availability compromises result in system outages, preventing agencies or federal citizens from utilizing critical cloud tools.

Under FIPS 199, each objective is given an impact level of Low, Moderate, or High. An impact level represents the magnitude of the adverse consequence that would occur if that objective were compromised:

  • Low Impact: A compromise results in limited adverse effects. Operations can continue, but with slight friction or minor financial repair.
  • Moderate Impact: A compromise results in serious adverse effects. The agency incurs operational outages, substantial financial damage, or non-life-threatening physical harm to individuals.
  • High Impact: A compromise results in severe or catastrophic consequences. Operations fail completely, causing life-threatening events, national security disruption, or irreparable business damage.

Applying the High-Water Mark (HWM) Principle

The overall security categorization of any federal information system is calculated using the High-Water Mark (HWM). This rule dictates that the overall baseline rating is determined by the highest individual rating assigned to any of the three security objectives. For example:

Confidentiality: LOW | Integrity: MODERATE | Availability: LOW ===> System Categorization: MODERATE

Under-categorizing a system leads to security posture failures and rejected authorization packages during Joint Authorization Board (JAB) or Agency reviews. Over-categorizing a system, on the other hand, can force you to spend thousands of dollars implementing unnecessary technical requirements. For example, a system unnecessarily classified as Moderate must implement 323 security controls instead of the 156 required for a Low baseline.

The Streamlined FedRAMP Li-SaaS Framework (Low-Risk SaaS)

To accelerate cloud adoption, the federal government introduced the Low-Impact SaaS (Li-SaaS) baseline. This is a tailored sub-category of the Low baseline intended for lightweight, business-enabling software (such as project management trackers, poll tools, and collaboration channels).

While a standard Low baseline requires 156 security controls, Li-SaaS scales this down to only 36 controls. However, qualifying for Li-SaaS is highly restricted:

  • The SaaS must NOT process or house any Sensitive PII (such as social security numbers, banking details, or biometric files).
  • The SaaS must NOT house any Controlled Unclassified Information (CUI) or export-controlled defense datasets.
  • The SaaS must operate entirely on an active, authorized FedRAMP IaaS/PaaS environment.
  • The overall FIPS 199 valuation must be Low-Impact across Confidentiality, Integrity, and Availability.

Transitioning to NIST SP 800-53 Rev 5 Control Standards

FedRAMP has fully transitioned to the **NIST SP 800-53 Rev 5** control catalog. Key modifications in Rev 5 include a profound integration of data privacy controls, a pivot toward automated assessment standards, and a significant emphasis on **Supply Chain Risk Management (SCRM)**. Under Rev 5, CSPs are required to audit third-party software components and track libraries inside their boundary to prevent malicious injections or unauthorized supply chain breaches.

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