Vulnerability Remediation
Remediate vulnerabilities in accordance with risk assessments.
What an assessor scores, the objectives
RA.L2-3.11.3 is met only when every one of these 2 objectives, from NIST SP 800-171A, is satisfied. A single missed objective makes the whole requirement not met.
- a.vulnerabilities are identified
- b.vulnerabilities are remediated in accordance with risk assessments
How a C3PAO checks it
NIST SP 800-171A defines three assessment methods. For RA.L2-3.11.3, an assessor uses these:
Risk assessment policy; procedures addressing vulnerability scanning; risk assessment; system security plan; security assessment report; vulnerability scanning tools and associated configuration documentation; vulnerability scanning results; patch and vulnerability management records; other relevant documents or records
Personnel with risk assessment, security assessment and vulnerability scanning responsibilities; personnel with vulnerability scan analysis responsibilities; personnel with vulnerability remediation responsibilities; personnel with information security responsibilities; system or network administrators
Organizational processes for vulnerability scanning, analysis, remediation, and information sharing; mechanisms supporting or implementing vulnerability scanning, analysis, remediation, and information sharing
What it means, in context
Vulnerabilities discovered, for example, via the scanning conducted in response to RA.L2 - 3.11.2, are remediated with consideration of the related assessment of risk. The consideration of risk influences the prioritization of remediation efforts and the level of effort to be expended in the remediation for specific vulnerabilities.
Not all vulnerabilities captured in a vulnerability scanner may pose the same level of risk to an organization. Prioritize mitigation efforts to close the most critical vulnerabilities first. Track all vulnerability remediation to ensure completion; also track vulnerabilities that you have determined not to remediate. This requirement, RA.L2-3.11.3, benefits from CA.L2 -3.12.2. RA.L2-3.11.3 allows remediation of vulnerabilities to take place based on the developed plans of actions for vulnerabilities from CA.L2-3.12.2. Example You are a system administrator. Each quarter you receive a list of vulnerabilities generated by your company ’s vulnerability scanner [a]. You prioritize that list and note which vulnerabilities should be targeted as soon as possible as well as which vulnerabilities you can safely defer addressing at this time. You document the reasoning behind accepting the risk of the unremediated flaws and note to continue to monitor these vulnerabilities in case you need to revise the decision at a later date [b]. Potential Assessment Considerations • Are the results of risk assessments used to prioritize vulnerabilities for remediation [b]? • For any given vulnerability is action taken for remediation, acceptance, avoidance, or transference of the vulnerability risk [b]? • Are all high risk vulnerabilities prioritized [b]?
What passing evidence looks like
Remediation happening in risk order: the scan findings triaged, the fixes applied or scheduled, and the record connecting finding to fix.
Common ways contractors fail RA.L2-3.11.3
- !The pair to 3.11.2: scans without remediation records answer half. A simple findings tracker (finding, severity, fix, date closed) shows the loop closes.
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RA.L2-3.11.3 questions, answered
How many points is CMMC requirement RA.L2-3.11.3 worth?+
RA.L2-3.11.3 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 RA.L2-3.11.3 be placed on a POA&M?+
Yes. A gap on RA.L2-3.11.3 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 RA.L2-3.11.3 belong to?+
RA.L2-3.11.3 is in the Risk Assessment (RA) family, one of the 14 families of NIST SP 800-171 that make up CMMC Level 2.
- NIST SP 800-171 Rev. 2 3.11.3