CM.L2-3.4.4 · Level 2

Analyze the security impact of changes prior to implementation.

NIST SP 800-171 Rev 2 · §3.4.4

Assessment objectives

From NIST SP 800-171A · 1 objective must be met to satisfy this control

3.4.4[a] Analyze the security impact of changes prior to implementation.

Examine

[SELECT FROM: Configuration management policy; procedures addressing security impact analysis for changes to the system; configuration management plan; security impact analysis documentation; security plan; analysis tools and associated outputs; change control records; system audit logs and records; other relevant documents or records].

Interview

[SELECT FROM: Personnel with responsibility for conducting security impact analysis; personnel with information security responsibilities; system or network administrators].

Test

[SELECT FROM: Organizational processes for security impact analysis].

What we look for in practice

The following are placeholder notes that should be refined based on practice experience.

What assessors look for in practice. Documented evidence that this control is implemented across all CUI-handling systems within scope. Specific artifacts vary, but expect requests for written procedures, system configurations, and operational records demonstrating the control is active.

Common failure patterns. Typical issues include incomplete documentation, inconsistent implementation across systems, and missing periodic review records. Refine this section as your practice accumulates direct assessment experience.

Strong evidence looks like. Formal policy referencing this control, technical configurations demonstrating enforcement, periodic review logs with sign-off, and procedures for handling exceptions.

Scoring and POA&M context. 1-point control under the DoD Assessment Methodology. Lower scoring impact, but still required for full compliance. POA&M-eligible — deferral up to 180 days is allowed under conditional certification per 32 CFR 170.21.