LLMResponse CM.L2-3.4.3.c
I'll help you evaluate how to best collect evidence for the assessment objective "[c] changes to the system are approved or disapproved" within CM.L2-3.4.3. Based on the CMMC Level 2 Assessment Guide and your assessment approaches, I'll rank the evidence types and prioritize assessment approaches.
Evidence Types Ranking for "[c] changes to the system are approved or disapproved"
1. **Artifacts (I1)** - Highest priority evidence type because it provides direct proof of approval/disapproval decisions:
- Change request forms with formal approval/disapproval signatures or electronic authorizations - Change Advisory Board decision records - System-generated approval workflow records - Email approvals from authorized approvers - Ticket system entries showing approval/disapproval status and rationale
2. **Documents (I2)** - Second most valuable evidence type:
- Configuration management policy that defines approval authorities - Procedures detailing the approval/disapproval process - Authorization matrices showing who can approve what types of changes - System security plan sections describing change approval requirements - Delegation of authority documentation for change approvals
3. **Screen Share (I4)** - Valuable for demonstrating the approval process:
- Live demonstration of approval/disapproval workflows - Showing the approval history for sample changes - Display of approval queues and decision documentation
4. **Physical Review (I3)** - Lower priority but still relevant:
- Physical change approval forms with signatures - Observation of an approval meeting or board session - Posted approval authorities or decision matrices
Assessment Approach Prioritization
1. **Examine (C1)** - Primary approach because:
- It provides direct evidence of approval decisions - Shows consistent application of approval processes - Demonstrates proper authority levels for different types of changes - Key assessment objects: change control records, configuration management plan, agenda/minutes from configuration change control oversight meetings
2. **Interview (C2)** - Second priority for this objective:
- Helps confirm understanding of approval authorities - Reveals how approval decisions are made in practice - Identifies any exceptions to normal approval processes - Key personnel: members of change control board, personnel with configuration change control responsibilities, system or network administrators
3. **Test (C3)** - Third priority but still important:
- Verify that changes cannot bypass approval requirements - Test that appropriate approvals are obtained before implementation - Validate that approval records are properly maintained - Key assessment objects: organizational processes for configuration change control
Practical Implementation Strategy
For optimal assessment of "[c] changes to the system are approved or disapproved":
1. Start by examining approval documentation:
- Recent change requests with approval/disapproval decisions - Change Advisory Board minutes showing decision rationales - Evidence that changes were properly authorized before implementation - Documentation of disapproved changes to show the process works both ways
2. Interview key personnel involved in change approvals:
- Change approval authorities - Change Advisory Board members - Change initiators who have experienced the approval process - Focus on understanding how approval decisions are made and documented
3. Test the approval process by:
- Tracing a change from request through approval to implementation - Verifying that unapproved changes cannot be implemented - Confirming appropriate separation of duties in the approval process
This comprehensive approach will provide strong evidence that your organization is meeting the requirement for approving or disapproving changes to organizational systems, which is essential for CMMC Level 2 compliance.