3.7.6·high·Component: MaintenanceWhat this control requires
This control requires establishing a process for authorizing Maintenance personnel, maintaining a list of authorized personnel or organizations, and verifying that non-escorted personnel have the necessary access authorizations. It also mandates the designation of qualified personnel to supervise Maintenance activities for those without the required access. This control supports the Authorization Management capability within the Maintenance (3.7) family.
In plain English
This control requires establishing a process for authorizing Maintenance personnel, maintaining a list of authorized personnel or organizations, and verifying that non-escorted personnel have the necessary access authorizations. In practice, this means you can prove you access 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 high. Auditors expect a named owner, a remediation SLA, and a tooling artefact that evidences continuous operation.
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 3.7.6) 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
- Access. Document the trigger, the owner and the cadence.
- Authorized. Document the trigger, the owner and the cadence.
- Maintenance. Document the trigger, the owner and the cadence.
- Personnel. Document the trigger, the owner and the cadence.
- Risk. Document the trigger, the owner and the cadence.
- Scope: management, maintenance, personnel, access authorizations, authorization.
Evidence to collect
- Policy Document. A signed and version-controlled policy / standard / procedure document.
Signed policy or standard documents the safeguard. Focus: Maintenance Personnel.
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-5 — Maintenance Personnel
- HIPAA (45 CFR Part 164) 164.308(a)(4)(ii)(B) — Information Access Management - Access Authorization
- ISO/IEC 27001:2022 A.7.13 — Equipment maintenance
- SOC 2 (2017 TSC) CC2.3 — External Communication on Internal Control Matters
Related controls in NIST SP 800-171 Rev. 3
- Requirement 3.7.1 — Recategorized as NCO.
- Requirement 3.4.8 — Authorized Software - Allow by Exception
- Requirement 3.1.5 — Least Privilege
- Requirement 3.15.1 — Policy and Procedures
- Requirement 3.3.4 — Response to Audit Logging Process Failures
- Requirement 3.1.1 — Account Management
References
- NIST Computer Security Resource Center — NIST SP 800-171 Rev. 3
- Catalogue identifier:
Requirement 3.7.6
Topics: governance riskpolicy management