SI.L2-3.14.1 · NIST SP 800-171 3.14.1

Flaw Remediation

Identify, report, and correct system flaws in a timely manner.

5 points if not metMust be fully met, cannot POA&M6 assessment objectives

What an assessor scores, the objectives

SI.L2-3.14.1 is met only when every one of these 6 objectives, from NIST SP 800-171A, is satisfied. A single missed objective makes the whole requirement not met.

  • a.the time within which to identify system flaws is specified
  • b.system flaws are identified within the specified time frame
  • c.the time within which to report system flaws is specified
  • d.system flaws are reported within the specified time frame
  • e.the time within which to correct system flaws is specified
  • f.system flaws are corrected within the specified time frame

How a C3PAO checks it

NIST SP 800-171A defines three assessment methods. For SI.L2-3.14.1, an assessor uses these:

Examine

System and information integrity policy; procedures addressing flaw remediation; procedures addressing configuration management; system security plan; list of flaws and vulnerabilities potentially affecting the system; list of recent security flaw remediation actions performed on the system (e.g., list of installed patches, service packs, hot fixes, and other software updates to correct system flaws); test results from th e installation of software and firmware updates to correct system flaws; installation/change control records for security -relevant software and firmware updates; other relevant documents or records

Interview

System or network administrators; personnel with information security responsibilities; personnel installing, configuring, and maintaining the system; personnel with responsibility for flaw remediation; personnel with configuration management responsibility

Test

Organizat ional processes for identifying, reporting, and correcting system flaws; organizational process for installing software and firmware updates; mechanisms supporting or implementing reporting, and correcting system flaws; mechanisms supporting or implementing testing software and firmware updates

What it means, in context

Organizations identify systems that are affected by announced software and firmware flaws including potential vulnerabilities resulting from those flaws and report this information to designated personnel with information security responsibilities. Security-relevant updates include patches, service packs, hot fixes, and anti- virus signatures. Organizations address flaws discovered during security assessments, continuous m onitoring, incident response activities, and system error handling. Organizations can take advantage of available resources such as the Common Weakness Enumeration (CWE) database or Common Vulnerabilities and Exposures (CVE) database in remediating flaws discovered in organizational systems. Organization-defined time periods for updating security -relevant software and firmware may vary based on a variety of factors including the criticality of the update (i.e., severity of the vulnerability related to the discovered flaw). Some types of flaw remediation may require more testing than other types of remediation. NIST SP 800 -40 provides guidance on patch management technologies.

All software and firmware have potential flaws. Many vendors work to remedy those flaws by releasing vulnerability information and updates to their software and firmware. OSAs must have a process to review relevant vendor notifications and updates about problems or weaknesses. After reviewing the information, the OSA must implement a patch management process that allows for software and firmware flaws to be fixed without adversely affecting the system functionality. OSAs must define the time frames within which flaws are identified, reported, and corrected for all systems. OSAs should consider purchasing support from their vendors to ensure timely access to updates. Example You know that software vendors typically release patches, service packs, hot fixes, etc. and want to make sure your software is up to date. You develop a policy that requires checking vendor websites for flaw notifications every week [a]. The policy further requires that those flaws be assessed for severity and patched on end -user computers once each week and servers once each month [c,e]. Consistent with that policy, you configure the system to check for updates weekly or daily depending on the criticality of the software [b,e]. Your team reviews available updates and implements the applicable ones according to the defined schedule [f]. Potential Assessment Considerations • Is the time frame (e.g., a set number of days) within which system flaw identification activities (e.g., vulnerability scans, configuration scans, manual review) must be performed defined and documented [a]? • Are system flaws (e.g., vulnerabilities, misconfigurations) identified in accordance with the specified time frame [b]? • Is the time frame (e.g., a set number of days dependent on the assessed severity of a flaw) within which system flaws must be corrected defined and documented [e]? • Are system flaws (e.g., applied security patches, made configuration changes, or implemented workarounds or mitigations) corrected in accordance with the specified time frame [f]?

What passing evidence looks like

Flaws identified, reported, and corrected in time: the patch policy with its timeframes, the update tool status showing the fleet current, and one flaw tracked from report to fix.

Common ways contractors fail SI.L2-3.14.1

  • !Within the time frames you define, so define them (critical patches 14 days, routine monthly is a common small shop standard) and then show the fleet actually meets them.

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SI.L2-3.14.1 questions, answered

How many points is CMMC requirement SI.L2-3.14.1 worth?+

SI.L2-3.14.1 is worth 5 points in the CMMC Level 2 score under 32 CFR 170.24. If it is not met, you lose 5 from your total of 110.

Can SI.L2-3.14.1 be placed on a POA&M?+

No. SI.L2-3.14.1 must be fully met before you can file. It cannot be deferred to a POA&M, so it is a gate on your assessment.

What family does SI.L2-3.14.1 belong to?+

SI.L2-3.14.1 is in the System & Information Integrity (SI) 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 3.14.1
  • FAR Clause 52.204-21 b.1.xii