What 3.12.4 means in practice

The system security plan describes the system: its boundary, its environment of operation, how each requirement is implemented, and how it connects to other systems. It is updated on a set schedule and when the system changes. Without one an assessment cannot be completed, so no SPRS score is produced.

SPRS points and the CMMC POA&M

CMMC Level 2 practice
CA.L2-3.12.4
SPRS points
No point value of its own.
CMMC POA&M
Never. 32 CFR 170.21(a)(2)(iii) names 3.12.4 among the 6 requirements a CMMC POA&M may never include, whatever their point value.
Scoring note
No point value. Without a system security plan an assessment cannot be completed, so no score is produced.

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 3.12.4

NIST SP 800-171A gives 8 determination statements for 3.12.4, each found satisfied or other than satisfied. Determine if:

  1. 3.12.4[a] a system security plan is developed.
  2. 3.12.4[b] the system boundary is described and documented in the system security plan.
  3. 3.12.4[c] the system environment of operation is described and documented in the system security plan.
  4. 3.12.4[d] the security requirements identified and approved by the designated authority as non-applicable are identified.
  5. 3.12.4[e] the method of security requirement implementation is described and documented in the system security plan.
  6. 3.12.4[f] the relationship with or connection to other systems is described and documented in the system security plan.
  7. 3.12.4[g] the frequency to update the system security plan is defined.
  8. 3.12.4[h] system security plan is updated with the defined frequency.

NIST SP 800-171A (June 2018), assessment objectives for 3.12.4

Evidence that shows 3.12.4 is met

  • The current system security plan, with its approval and date.
  • The boundary diagram and the list of connections to other systems in the plan.
  • An implementation description for each requirement.
  • The update schedule and the revision history.

How PolicyCortex gathers the evidence

No PolicyCortex collector reads the evidence for 3.12.4. Your team provides the evidence listed above.

Meet the requirement once. Keep the evidence current.

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