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3.4.3Track changes

Changes are logged, reviewed, and approved rather than made and forgotten.

The requirement, verbatim

NIST SP 800-171 Rev. 2 · 3.4.3

Track, review, approve or disapprove, and log changes to organizational systems.

Requirement 3.4.3, practice name in the CMMC assessment guide: System Change Management.

NIST's discussion

Tracking, reviewing, approving/disapproving, and logging changes is called configuration change control. Configuration change control for organizational systems involves the systematic proposal, justification, implementation, testing, review, and disposition of changes to the systems, including system upgrades and modifications. Configuration change control includes changes to baseline configurations for components and configuration items of systems, changes to configuration settings for information technology products (e.g., operating systems, applications, firewalls, routers, and mobile devices), unscheduled and unauthorized changes, and changes to remediate vulnerabilities.

Processes for managing configuration changes to systems include Configuration Control Boards or Change Advisory Boards that review and approve proposed changes to systems. For new development systems or systems undergoing major upgrades, organizations consider including representatives from development organizations on the Configuration Control Boards or Change Advisory Boards. Audit logs of changes include activities before and after changes are made to organizational systems and the activities required to implement such changes.

NIST SP 800-128 provides guidance on configuration change control.

NIST SP 800-171 Rev. 2, discussion under 3.4.3. Whitespace normalised; wording unchanged.

Assessment objectives

An assessor decides each of these separately. The requirement is met only when every objective is.

  1. [a] changes to the system are tracked
  2. [b] changes to the system are reviewed
  3. [c] changes to the system are approved or disapproved
  4. [d] changes to the system are logged

NIST SP 800-171A, determination statements for 3.4.3.

For assessors: examine, interview, test

NIST SP 800-171A names what an assessor may examine, whom they may interview, and what they may test for this requirement. Assessors select from these lists; they are not a checklist of everything you must produce.

Examine
  • Configuration management policy
  • procedures addressing configuration change control
  • configuration management plan
  • system architecture and configuration documentation
  • change control records
  • system security plan
  • system audit logs and records
  • other relevant documents or records
Interview
  • Personnel with configuration change control responsibilities
  • personnel with information security responsibilities
  • system or network administrators
  • system developers
Test
  • Organizational processes for configuration change control
  • mechanisms supporting configuration change control

NIST SP 800-171A, potential assessment methods and objects for 3.4.3.

Evidence

No evidence examples are published for this requirement yet. The objectives above are what an assessor checks; evidence is whatever shows each one is true in your environment, dated and kept with your system security plan.

Scoring weight

Worth 1 point. Not meeting this requirement subtracts 1 from your 110-point SPRS score.

DoD NIST SP 800-171 Assessment Methodology v1.2.1 weighting, as carried in the Bedrock scoring table. The score starts at 110 and subtracts the weight of every requirement not met.

In Rev. 3

Rev. 2 is what your contract requires today. A standing DoD class deviation keeps Rev. 2 in force; NIST has published Rev. 3, but it is not adopted for contracts. In Rev. 3 this requirement is reworded: 03.04.03 Configuration Change Control.

See the Rev. 2 and Rev. 3 wording word by word, or start with the status page.

Where this page's facts come from
Requirement text
bedrock-cmmc-api@89b8e8e:migrations/004_reference_requirements.sql#Requirement.basicRequirement@rev2
Discussion
bedrock-cmmc-api@89b8e8e:migrations/004_reference_requirements.sql#Requirement.discussion@rev2
Practice name
bedrock-cmmc-api@89b8e8e:migrations/004_reference_requirements.sql#Requirement.title@rev2 (CMMC Assessment Guide practice name)
Objectives
bedrock-cmmc-api@89b8e8e:migrations/005_reference_objectives.sql#AssessmentObjective.description@rev2
Examine, interview, test
bedrock-cmmc-api@89b8e8e:migrations/005_reference_objectives.sql#AssessmentObjective.description@rev2 ({examineGuidance, interviewGuidance, testGuidance})
Level
bedrock-cmmc-api@89b8e8e:migrations/021_fix_level1_requirements.sql#Requirement.cmmcLevel@rev2
Weight
bedrock-cmmc-api@89b8e8e:internal/cmmc/requirement_values.go#requirementValues (DoD AM v1.2.1 / eMASS L2 template v3.8)
Rev. 3 mapping
bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/r2_r3_transition_map.json#r2_to_r3
Plain-language title and summary
editorial/CMMC Navigator.dc.html#RAW (Foxx Cyber editorial)