Practice CA.L2-3.12.2 Details

Source of Reference: The official CMMC Level 1 Self-Assessment Guide from the Office of the Under Secretary of Defense Acquisition & Sustainment.

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CA.L2-3.12.2 – PLAN OF ACTION

SECURITY REQUIREMENT

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

ASSESSMENT OBJECTIVES

Determine if:

[a] deficiencies and vulnerabilities to be addressed by the plan of action are identified;

[b] a plan of action is developed to correct identified deficiencies and reduce or eliminate identified vulnerabilities; and

[c] the plan of action is implemented to correct identified deficiencies and reduce or eliminate identified vulnerabilities.

POTENTIAL ASSESSMENT METHODS AND OBJECTS

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].DISCUSSION [NIST SP 800-171 R2]

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.

This practice, CA.L2-3.12.2, which ensures developing and implementing plans of action to correct and reduce vulnerabilities in systems, is driven by risk management practice 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 practice CA.L2-3.12.3.

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 a 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]?

KEY REFERENCES

• NIST SP 800-171 Rev 2 3.12.2