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Requirements / System and Information Integrity (SI)

SI.L2-3.14.1

Flaw Remediation

Official Source Material

Identify, report, and correct system flaws in a timely manner.

Determine if:

  1. [a] the time within which to identify system flaws is specified;
  2. [b] system flaws are identified within the specified time frame;
  3. [c] the time within which to report system flaws is specified;
  4. [d] system flaws are reported within the specified time frame;
  5. [e] the time within which to correct system flaws is specified; and
  6. [f] system flaws are corrected within the specified time frame.

Source: CMMC Assessment Guide - Level 2, Version 2.13, September 2024

Practitioner Guidance

How to meet it

Write three timeframes before you touch a patch.

Objectives [a], [c], and [e] each demand a specified time: how quickly flaws are identified, how quickly they are reported, and how quickly they are corrected. The remaining objectives, [b], [d], and [f], are proof you meet those times. Numbers come first: a scan cadence, a reporting cadence, and remediation windows by severity, written into policy.

Reporting is the step that fails organizations that patch well.

Scanning and fixing without a documented reporting step leaves [c] and [d] with no evidence. Reporting means the identified flaws land somewhere reviewable on a schedule: a generated report, a ticket, an email to the responsible person. When one person runs the whole loop, the report is still written: the dated list of flaws produced before patching begins is the reporting evidence.

Flaws are more than missing patches.

Configuration weaknesses found by scans, findings from the security assessments CA.L2-3.12.1 requires, and weaknesses surfaced during incident response are all system flaws in this requirement's sense. Route them through the same identify, report, and correct loop with the same timeframes.

Evidence is the loop running end to end.

A vulnerability report dated inside your identification window covers [b]. The ticket or emailed report with its timestamp covers [d]. Patch deployment history showing correction inside the window covers [f]. A tracking spreadsheet with an open tab and a closed tab is a complete system for a small environment.

Do not put a review board in front of routine patches.

A monthly approval gate for operating system updates slows correction and returns no security. You own your change process. Classify routine patches as standard changes that deploy automatically to a test group and then to production on defined days. Save the approvals for changes that warrant them.

What falls short

  • Patch management tooling with no specified timeframes. However fast the patching, [a], [c], and [e] ask for defined times, and undefined times cannot be met.
  • Scan results that are generated and never reported to anyone on a defined cadence. Identification without reporting leaves [c] and [d] unanswered.

Edge cases

  • A system that breaks when patched is a documented risk decision, not a silent gap. Record the exception, isolate and mitigate the system, and revisit it on a schedule, because an undocumented unpatched system is a plain [f] failure.
  • Software the customer directs you not to update leaves the flaw open through no fault of yours. Keep the customer's written direction, record the affected flaws, and mitigate around them, because the direction is your evidence when the correction timeframe cannot be met.

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