NIST Special Publication 800-171 Revision 2

Date Published: January 28th, 2021

Withdrawn on May 14, 2024. Superseded by SP 800-171 Rev. 3

Author(s): Ron Ross (NIST), Victoria Pillitteri (NIST), Kelley Dempsey (NIST), Mark Riddle (NARA), Gary Guissanie (IDA)

Note: A Class Deviation is in effect as of May 2, 2024 (DEVIATION 2024O0013). The deviation clause requires contractors, who are subject to 252.204-7012, to comply with National Institute of Standards and Technology (NIST) Special Publication (SP) 800-171 Revision 2, instead of the version of NIST SP 800-171 in effect at the time the solicitation is issued or as authorized by the contracting officer. Click Here

3.12.2: Develop and implement plans of action designed to correct deficiencies and reduce or eliminate vulnerabilities in organizational systems.

Control Family: Security Assessment

Control Type: Basic

SPRS Value: 3

SPRS Supplemental Guidance: N/A

CMMC Level(s):

  • CA.L2-3.12.2

Top Ten Failed Requirement:

No

Referenced in:

DFARS 252.204-7012

Derived From: NIST SP 800-53r4

  • CA-2

  • CA-5

  • CA-7

  • PL-2

NIST Supplemental Guidance:

[NIST CUI]

Discussion:

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.

Upon assessment, assessors must determine if- 

3.12.2[a] deficiencies and vulnerabilities to be addressed by the plan of action are identified.
3.12.2[b] a plan of action is developed to correct identified deficiencies and reduce or eliminate identified vulnerabilities.
3.12.2[c] the plan of action is implemented to correct identified deficiencies and reduce or eliminate identified vulnerabilities.

Assessors are instructed to-

Examine: [SELECT FROM: Security assessment and authorization policy; procedures addressing plan of action; system security plan; security assessment plan; security assessment report; security assessment evidence; plan of action; other relevant documents or records].

Interview: [SELECT FROM: Personnel with plan of action development and implementation responsibilities; personnel with information security responsibilities].

Test: [SELECT FROM: Mechanisms for developing, implementing, and maintaining plan of action].

FURTHER 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.

Example

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].

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]?