3.14.1·critical·Component: System and Communications ProtectionWhat this control requires
This control requires identifying, reporting, and correcting system flaws, and installing security-relevant software and firmware updates within a defined time period after the release. This includes patches, service packs, hot fixes, and anti-virus signatures. Organizations must address flaws discovered during security assessments, continuous monitoring, incident response, and error handling. This control supports the Flaw Remediation System capability within the System and Communications Protection (3.14) family.
In plain English
This control requires identifying, reporting, and correcting system flaws, and installing security-relevant software and firmware updates within a defined time period after the release. In practice, this means you can prove you response management-level controls on a defined cadence.
Why it matters
DoD contractors and their subcontractors must implement all 100 SP 800-171 requirements to keep CUI handling contracts. Gaps are scored against the SPRS scoring methodology; below a 110-point starting score, each unmet requirement deducts points and a below-threshold score can disqualify a bid.
This control is rated critical in the source catalogue. Treat gaps here as production incidents in the risk register, not housekeeping.
What an auditor looks for
A C3PAO conducting a CMMC Level 2 assessment uses NIST SP 800-171A objectives. They expect a System Security Plan (SSP), Plan of Action & Milestones (POA&M) for any gaps, and objective evidence (configurations, ticket records, training records) for every requirement.
Within System and Communications Protection, the assessor will trace your implementation back to the catalogue reference (Requirement 3.14.1) and look for objective evidence on the latest two assessment cycles.
How to implement
Incident Response
Runbook. Maintain a runbook keyed by incident type with named roles (IC, comms, scribe), an out-of-band comms channel, and a 72-hour timeline for external notification.
Tabletop. Run a quarterly tabletop exercise (ransomware, insider, supply-chain) and feed gaps back into the runbook.
Operational checklist
- Response. Document the trigger, the owner and the cadence.
- Time. Document the trigger, the owner and the cadence.
- Protection. Document the trigger, the owner and the cadence.
- System. Document the trigger, the owner and the cadence.
- Incident. Document the trigger, the owner and the cadence.
- Scope: management, time, software, firmware, security, response, protection, remediation.
Evidence to collect
- Ticketing Workflow.
ticketing_workflowevidence
Workflow metrics (ServiceNow, Jira) show approvals and remediation. Focus: Flaw Remediation.
Common pitfalls
- Runbooks that name a role but no person, or list a paging channel that no longer exists.
How it maps to other frameworks
Computed from shared tags, control component and key-operation subjects — handy when you are reconciling controls across an audit.
- NIST SP 800-53 Rev. 5 IR-5(1) — Automated Tracking, Data Collection, And Analysis
- SOC 2 (2017 TSC) CC7.4 — Incident Response
- ISO/IEC 27001:2022 A.5.27 — Learning from information security incidents
Related controls in NIST SP 800-171 Rev. 3
- Requirement 3.6.2 — Incident Monitoring, Reporting, and Response Assistance
- Requirement 3.6.4 — Incident Response Training
- Requirement 3.3.6 — Audit Record Reduction and Report Generation
- Requirement 3.14.3 — Security Alerts, Advisories, and Directives
- Requirement 3.14.6 — System Monitoring
- Requirement 3.2.1 — Literacy Training and Awareness
References
- NIST Computer Security Resource Center — NIST SP 800-171 Rev. 3
- Catalogue identifier:
Requirement 3.14.1
Topics: incident responsechange managementcontinuous monitoring