CM.L2-3.4.4 · NIST SP 800-171 3.4.4

Security Impact Analysis

Analyze the security impact of changes prior to implementation.

1 point if not metPOA&M eligible1 assessment objective

What an assessor scores, the objectives

CM.L2-3.4.4 is met only when every one of these 1 objectives, from NIST SP 800-171A, is satisfied. A single missed objective makes the whole requirement not met.

  • a.the security impact of changes to the system is analyzed prior to implementation

How a C3PAO checks it

NIST SP 800-171A defines three assessment methods. For CM.L2-3.4.4, an assessor uses these:

Examine

Configuration management policy; procedures addressing security impact analysis for system changes; configuration management plan; security impact analysis documentation; system security plan; analysis tools and associated outputs; change control records; system audit logs and records; other relevant documents or records

Interview

Personnel with responsibility for conducting security impact analysis; personnel with information security responsibilities; system or network administrators

Test

Organizational processes for security impact analysis

What it means, in context

Organizational personnel with information security responsibilities (e.g., system administrators, system security officers, system security managers, and systems security engineers) conduct security impact analyses. Individuals conducting security impact analyses possess the necessary skills and technical expertise to analyze the changes to systems and the associated security ramifications. Security impact analysis may include reviewing security plans to understand security requirements and reviewing system design documentation to understand the implementation of controls and how specific changes might affect the controls. Security impact analyses may also include risk assessments to better understand the impact of the changes and to determine if additional controls are required. NIST SP 800 -128 provides guidance on configuration change control and security impact analysis.

Changes to complex environments are reviewed for potential security impact before implemented. Changes to IT systems can cause unforeseen problems and have unintended consequences for both users and the security of the operating environment. Analyze the security impact of changes prior to implementing them. This can uncover and mitigate potential problems before they occur. Example You have been asked to deploy a new web browser plug -in. Your standard change management process requires that you produce a detailed plan for the change, including a review of its potential security impact. A subject- matter expert who did not submit the change reviews the plan and tests the new plug-in for functionality and security. You update the change plan based on the expert’s findings and submit it to the change control board for final approval [a]. Potential Assessment Considerations • Are configuration changes tested, validated, and documented before installing them on the operational system [a]?

What passing evidence looks like

Security impact analysis visible in the change record: a column or line per change answering what could this break or expose, filled in BEFORE implementation.

Common ways contractors fail CM.L2-3.4.4

  • !One sentence per change is fine (opens port 443 inbound to the scanner, mitigated by source IP restriction). The failure is a change log with no security thought recorded at all.

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Prove CM.L2-3.4.4, and the other 109

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CM.L2-3.4.4 questions, answered

How many points is CMMC requirement CM.L2-3.4.4 worth?+

CM.L2-3.4.4 is worth 1 point in the CMMC Level 2 score under 32 CFR 170.24. If it is not met, you lose 1 from your total of 110.

Can CM.L2-3.4.4 be placed on a POA&M?+

Yes. A gap on CM.L2-3.4.4 can be deferred to a Plan of Action and Milestones, provided your overall score is 88 or better and the item closes within 180 days.

What family does CM.L2-3.4.4 belong to?+

CM.L2-3.4.4 is in the Configuration Management (CM) family, one of the 14 families of NIST SP 800-171 that make up CMMC Level 2.

Key references
  • NIST SP 800-171 Rev. 2 3.4.4