Requirement text: CM.2.065: Track, review, approve, or disapprove, and log changes to organizational
systems.
DISCUSSION FROM SOURCE: DRAFT NIST SP 800-171 R2
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.
CMMC CLARIFICATION
You should track, review, and approve changes before committing to production. Changes
to computing environments can create unintended and unforeseen issues. They can affect
the security and availability of the systems. Organizations should hold regular meetings
about changes. Relevant experts should review and approve proposed changes. They should
discuss potential impacts, before the organization puts the changes in place. Relevant items
include changes to the physical environment and to the system hosted within it.
Example
Once a month, the management and technical team leads join a change control board
meeting. During this meeting, everyone reviews all proposed changes to the environment.
This includes changes to the physical and computing environments. The meeting ensures
that relevant subject matter experts review changes and propose alternatives where needed.
References
• NIST SP 800-171 Rev 1 3.4.3
• NIST CSF v1.1 PR.IP-1, PR.IP-3
• CERT RMM v1.2 KIM:SG5.SP2
• NIST SP 800-53 Rev 4 CM-3
• AU ACSC Essential Eight