CM.L2-3.4.3 System Change Management

CMMC Practice CM.L2-3.4.3 – System Change Management: Track, review, approve, or disapprove, and log changes to organizational systems.

Links to Publicly Available Resources

Discussion [NIST SP 800-171 R2]
Tracking, reviewing, approving/disapproving, and logging changes is called configuration change control. Configuration change control for organizational systems involves the systematic proposal, justification, implementation, testing, review, and disposition of changes to the systems, including system upgrades and modifications. Configuration change control includes changes to baseline configurations for components and configuration items of systems, changes to configuration settings for information technology products (e.g., operating systems, applications, firewalls, routers, and mobile devices), unscheduled and unauthorized changes, and changes to remediate vulnerabilities. Processes for managing configuration changes to systems include Configuration Control Boards or Change Advisory Boards that review and approve proposed changes to systems.
For new development systems or systems undergoing major upgrades, organizations consider including representatives from development organizations on the Configuration Control Boards or Change Advisory Boards. Audit logs of changes include activities before and after changes are made to organizational systems and the activities required to implement such changes.
NIST SP 800-128 provides guidance on configuration change control.

Further Discussion
You must track, review, and approve configuration changes before committing to production. Changes to computing environments can create unintended and unforeseen issues that can affect the security and availability of the systems. Relevant experts and stakeholders must review and approve proposed changes. They should discuss potential impacts before the organization puts the changes in place. Relevant items include changes to the physical environment and to the systems hosted within it.