Requirement
Develop and implement plans of action designed to correct deficiencies and reduce or eliminate vulnerabilities in organizational systems.
Assessment Objectives
- Deficiencies and vulnerabilities to be addressed by the plan of action are identified
- A plan of action is developed to correct identified deficiencies and reduce or eliminate identified vulnerabilities
- The plan of action is implemented to correct identified deficiencies and reduce or eliminate identified vulnerabilities
Potential Assessment Methods and Objects [NIST SP 800-171A]
Examine
- 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
- Personnel with plan of action development and implementation responsibilities
- Personnel with information security responsibilities
Test
- Mechanisms for developing, implementing, and maintaining plan of action
Discussion [NIST SP 800-171 REV. 2]
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.
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. 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
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].
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]?
References
- NIST SP 800-171 Rev. 2 3.12.2
