NIST SP 800-171 Rev. 3 3.7.1 — Recategorized as NCO.

What this control requires

Document the disposition of legacy Maintenance controls reclassified as Non-Contract Obligations (NCO) and ensure associated procedures remain archived for reference. This control supports the Maintenance Program Governance capability within the Maintenance (3.7) family.

In plain English

Document the disposition of legacy Maintenance controls reclassified as Non-Contract Obligations (NCO) and ensure associated procedures remain archived for reference. In practice, this means you can prove you maintenance 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.

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 Maintenance, the assessor will trace your implementation back to the catalogue reference (Requirement 3.7.1) and look for objective evidence on the latest two assessment cycles.

How to implement

Policy Management

Docs. Keep each policy in version-controlled Markdown alongside the code that implements it; ship a signed PDF snapshot at each annual review and link the SHA into the SoA.

Operational checklist

• Maintenance. Document the trigger, the owner and the cadence.
• Risk. Document the trigger, the owner and the cadence.
• Policy. Document the trigger, the owner and the cadence.
• Scope: management, nco., maintenance, procedures.

Evidence to collect

• Policy Document. A signed and version-controlled policy / standard / procedure document.
• Infra Scan. Continuous infrastructure-posture telemetry — AWS Config, Azure Policy compliance, GCP Organisation Policy, Wiz / Prisma findings.

Signed policy or standard documents the safeguard. Focus: Recategorized as NCO..

Common pitfalls

• Policies that no engineer has read; the version in Confluence drifts from the version that's actually being enforced.

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 MA-7 — Field Maintenance
• ISO/IEC 27001:2022 A.7.13 — Equipment maintenance
• HIPAA (45 CFR Part 164) 164.308(a)(5)(ii)(B) — Security Awareness, Training, and Tools - Protection from Malicious Software
• SOC 2 (2017 TSC) CC2.3 — External Communication on Internal Control Matters
• BSI C5:2020 SP-01 — Documentation, communication and provision of policies and instructions

Related controls in NIST SP 800-171 Rev. 3

• Requirement 3.7.6 — Maintenance Personnel
• Requirement 3.13.2 — Recategorized as NCO
• Requirement 3.15.1 — Policy and Procedures
• Requirement 3.4.1 — Baseline Configuration
• Requirement 3.13.15 — Session Authenticity
• Requirement 3.15.3 — Rules of Behavior

References

• NIST Computer Security Resource Center — NIST SP 800-171 Rev. 3
• Catalogue identifier: Requirement 3.7.1

Topics: governance riskpolicy management