3.4.9
CM.L2-3.4.9 · Level 2
Control and monitor user-installed software.
NIST SP 800-171 Rev 2 · §3.4.9
Control and monitor user-installed software.
Assessment objectives
From NIST SP 800-171A · 3 objectives must be met to satisfy this control
Examine
[SELECT FROM: Configuration management policy; procedures addressing user installed software; configuration management plan; security plan; system design documentation; system configuration settings and associated documentation; list of rules governing user-installed software; system monitoring records; system audit logs and records; continuous monitoring strategy; other relevant documents or records].
Interview
[SELECT FROM: Personnel with responsibilities for governing user-installed software; personnel operating, using, or maintaining the system; personnel monitoring compliance with user-installed software policy; personnel with information security responsibilities; system or network administrators].
Test
[SELECT FROM: Organizational processes governing user-installed software on the system; mechanisms enforcing rules or methods for governing the installation of software by users; mechanisms monitoring policy compliance].
Examine
[SELECT FROM: Configuration management policy; procedures addressing user installed software; configuration management plan; security plan; system design documentation; system configuration settings and associated documentation; list of rules governing user-installed software; system monitoring records; system audit logs and records; continuous monitoring strategy; other relevant documents or records].
Interview
[SELECT FROM: Personnel with responsibilities for governing user-installed software; personnel operating, using, or maintaining the system; personnel monitoring compliance with user-installed software policy; personnel with information security responsibilities; system or network administrators].
Test
[SELECT FROM: Organizational processes governing user-installed software on the system; mechanisms enforcing rules or methods for governing the installation of software by users; mechanisms monitoring policy compliance].
Examine
[SELECT FROM: Configuration management policy; procedures addressing user installed software; configuration management plan; security plan; system design documentation; system configuration settings and associated documentation; list of rules governing user-installed software; system monitoring records; system audit logs and records; continuous monitoring strategy; other relevant documents or records].
Interview
[SELECT FROM: Personnel with responsibilities for governing user-installed software; personnel operating, using, or maintaining the system; personnel monitoring compliance with user-installed software policy; personnel with information security responsibilities; system or network administrators].
Test
[SELECT FROM: Organizational processes governing user-installed software on the system; mechanisms enforcing rules or methods for governing the installation of software by users; mechanisms monitoring policy compliance].
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.