What 3.4.3 means in practice

Every change to the system is tracked, reviewed, approved or rejected, and logged. A ticketing or change management system usually holds this record, from the request through the approval to the change as made.

SPRS points and the CMMC POA&M

CMMC Level 2 practice
CM.L2-3.4.3
SPRS points
1 point. When it is not met, the DoD Assessment Methodology subtracts 1 from the score of 110.
CMMC POA&M
Allowed. It is worth 1 point, and 32 CFR 170.21(a)(2)(ii) admits requirements worth 1 point. Conditional status also needs a score of at least 88, and the item must be closed within 180 days.

Sources: NIST SP 800-171 DoD Assessment Methodology, version 1.2.1 (June 24, 2020), Annex A; 32 CFR 170.21, Plan of Action and Milestones requirements.

What an assessor checks for 3.4.3

NIST SP 800-171A gives 4 determination statements for 3.4.3, each found satisfied or other than satisfied. Determine if:

  1. 3.4.3[a] changes to the system are tracked.
  2. 3.4.3[b] changes to the system are reviewed.
  3. 3.4.3[c] changes to the system are approved or disapproved.
  4. 3.4.3[d] changes to the system are logged.

NIST SP 800-171A (June 2018), assessment objectives for 3.4.3

Evidence that shows 3.4.3 is met

  • The change management procedure.
  • Change tickets showing request, review, approval or rejection, and implementation.
  • Logs that tie implemented changes back to approved tickets.

How PolicyCortex gathers the evidence

No PolicyCortex collector reads the evidence for 3.4.3. Your team provides the evidence listed above.

Meet the requirement once. Keep the evidence current.

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