NIST 800-171 3.9.2 (PS.L2-3.9.2): Personnel Actions

Ensure that organizational systems containing CUI are protected during and after personnel actions such as terminations and transfers.

NIST SP 800-171 Rev. 2, requirement 3.9.2

CMMC Level 2 practice PS.L2-3.9.2Published 2026-11-11

What 3.9.2 means in practice

When someone leaves or moves to another job, their access ends or changes at the same time: accounts disabled, credentials and badges collected, and shared passwords changed. Assessors compare HR departure dates with account disable dates.

SPRS points and the CMMC POA&M

CMMC Level 2 practice: PS.L2-3.9.2
SPRS points: 5 points. When it is not met, the DoD Assessment Methodology subtracts 5 from the score of 110.
CMMC POA&M: Not allowed. It is worth 5 points, and 32 CFR 170.21(a)(2)(ii) admits only requirements worth 1 point, with one exception: 3.13.11 when encryption is used but not FIPS validated.

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 3.9.2

NIST SP 800-171A gives 3 determination statements for 3.9.2, each found satisfied or other than satisfied. Determine if:

3.9.2[a] a policy and/or process for terminating system access and any credentials coincident with personnel actions is established.
3.9.2[b] system access and credentials are terminated consistent with personnel actions such as termination or transfer.
3.9.2[c] the system is protected during and after personnel transfer actions.

NIST SP 800-171A (June 2018), assessment objectives for 3.9.2

Evidence that shows 3.9.2 is met

The offboarding and transfer procedure.
HR termination and transfer records matched to the dates accounts were disabled or changed.
Records of returned equipment, badges and tokens.

How PolicyCortex gathers the evidence

PolicyCortex reads this evidence with the collectors below, read only, and grades 3.9.2 from it. Each line says what the product checks.

BambooHR: Leavers and joiners; Microsoft Entra ID and Okta: Leaver account lookups. Reads who left in the last 90 days from BambooHR and checks that each leaver's Microsoft Entra ID and Okta accounts were disabled within the removal window and not used after the termination date.

Related pages

Calculator: SPRS score calculator: mark 3.9.2 and the other 109 requirements and see the score.
Sample package: Sample package: an SSP, a POA&M and an evidence chain the product generated from demonstration data.
Family: All 2 Personnel Security requirements (3.9).
Previous: 3.9.1: Personnel Screening
Next: 3.10.1: Physical Access
All requirements: All 110 NIST SP 800-171 requirements, by family.

Related records

Guides and articles describe the work. The evidence that work produces is described in three proof pages, the architecture page, and the two pages on authorization.

proof.state: Proof of State. What the environment was, as of a date someone else picks: point-in-time records, content hashed and chained.
proof.change: Proof of Change. Who or what altered the environment, under what authority, with before and after state hashes.
proof.agency: Proof of Agency. What a machine was permitted to do before it acted, what it did, and what would have stopped it.
architecture: Architecture. How the chain is built and where the evidence is stored in each delivery mode.
authorization: Continuous ATO. How an authorizing official's decision is recorded with its package, and how the authorized system is checked against it every hour.
baseline: NIST SP 800-53. The Low, Moderate and High baselines as evidence, with the SSP, SAR and POA&M generated from one record.