Overview
  1. 03.01: Access Control
  2. 03.02: Awareness and Training
  3. 03.03: Audit and Accountability
  4. 03.04: Configuration Management
  5. 03.05: Identification and Authentication
  6. 03.06: Incident Response
  7. 03.07: Maintenance
  8. 03.08: Media Protection
  9. 03.09: Personnel Security
  10. 03.10: Physical Protection
  11. 03.11: Risk Assessment
  12. 03.12: Security Assessment
  13. 03.13: System and Communications Protection
  14. 03.14: System and Information Integrity

Security Requirements for 03.12.02 Plan of Action

The plan of action is a key document in the information security program. Organizations develop plans of action that describe how any unimplemented security requirements will be met and how any planned mitigations will be implemented. Organizations can document the system security plan and plan of action as separate or combined documents and in any chosen format.Federal agencies may consider the submitted system security plans and plans of action as critical inputs to an overall risk management decision to process, store, or transmit CUI on a system hosted by a nonfederal organization and whether it is advisable to pursue an agreement or contract with the nonfederal organization. [NIST CUI] provides supplemental material for Special Publication 800-171 including templates for plans of action.

Assessment GuidanceExamine 0/8

How an assessor determines this requirement is met. Source: CMMC Assessment Guide – Level 2, Version 2.13 (NIST SP 800-171 Rev. 2).

Discussion

When you write a plan of action, define the clear goal or objective of the plan. You may include the following in the action plan:

ownership of who is accountable for ensuring the plan’s performance; specific steps or milestones that are clear and actionable; assigned responsibility for each step or milestone; milestones to measure plan progress; and completion dates.

This requirement, CA.L2-3.12.2, which ensures developing and implementing operational plans of action to correct and reduce vulnerabilities in systems, is driven by risk management requirement RA.L2-3.11.1, which promotes periodically assessing risk to organizational systems. CA.L2-3.12.2 promotes monitoring security controls on an ongoing basis as defined in requirement CA.L2-3.12.3.

An operational plan of action in accordance with CA.L2-3.12.2 differs from a CMMC assessment POA&M as described in 32 CFR § 170.21. The assessment POA&M places conditions on which security requirements can be assessed as NOT MET and allows the OSA to qualify for a CMMC Status of Conditional Level 2 (Self), Conditional Level 2 (C3PAO), or Conditional Level 3 (DIBCAC). Operational plans of action are not subject to the 180 day POA&M closeout requirement. Severity, availability of remediation, and business requirements are among the factors to consider when creating and maintaining operational plans of action.

Examples

  1. Example 1

    As IT director, one of your duties is to develop action plans when you discover that your company is not meeting security requirements or when a security issue arises [b]. A recent vulnerability scan identified several items that need to be addressed so you develop a plan to fix them [b]. Your plan identifies the people responsible for fixing the issues, how to do it, and when the remediation will be completed [b]. You also define how to verify that the person responsible has fixed the vulnerability [b]. You document this in an operational plan of action that is updated as milestones are reached [b]. You have a separate resource review the modifications after they have been completed to ensure the plan has been implemented correctly [c].

Assessment Methods

Examine
The process of reviewing, inspecting, observing, studying, or analyzing assessment objects (e.g., policies, procedures, plans, system designs, mechanisms) to facilitate understanding, achieve clarification, or obtain evidence.Example: An assessor reads the access control policy and inspects system configuration settings to confirm they match.

Not all of the evidence listed is required to meet this requirement — check the items your organization has collected.

Interview
The process of holding discussions with individuals or groups within an organization to facilitate understanding, achieve clarification, or identify the location of evidence.Example: An assessor asks a system administrator to describe how user accounts are approved, reviewed, and disabled.
  • Personnel with plan of action development and implementation responsibilities
  • Personnel with information security responsibilities
Test
The process of exercising assessment objects (e.g., activities, mechanisms) under specified conditions to compare actual behavior with expected behavior.Example: An assessor attempts to sign in with a disabled account to confirm that access is denied.
  • Mechanisms for developing, implementing, and maintaining plan of action

Potential Assessment Considerations

  • Is there an action plan to remediate identified weaknesses or deficiencies [a]?
  • Is the action plan maintained as remediation is performed [b]?
  • Does the action plan designate remediation dates and milestones for each item [c]?

Key References

NIST SP 800-171 Rev. 2 3.12.2

Evidence

  1. 03.12.02.a

    Deficiencies and vulnerabilities to be addressed by the plan of action are identified

  1. 03.12.02.b

    A plan of action is developed to correct identified deficiencies and reduce or eliminate identified vulnerabilities

  1. 03.12.02.c

    The plan of action is implemented to correct identified deficiencies and reduce or eliminate identified vulnerabilities