Knowledge is Power
BARE METAL CYBERKnowledge is Power

Sitewide Search

Search Bare Metal Cyber

Search courses, individual lessons, wiki entries, books, podcasts, magazine articles, Daily Cyber News, and Darwin.

NIST SP 800-171 CUI Protection Center

03.04.04 — Impact Analyses

Read the official CUI requirement and assessment content, then use the separately labeled Bare Metal Cyber perspective to connect it to implementation, evidence, and sustained operation.

2Source controls
2Assessment objectives
3Assessment methods

03.04 — Configuration Management · NIST SP 800-171 Revision 3

Active
Official NIST requirement content

Security requirement

  1. a.Analyze changes to the system to determine potential security impacts prior to change implementation.
  2. b.Verify that the security requirements for the system continue to be satisfied after the system changes have been implemented.
Official NIST discussion

Discussion

Organizational personnel with security responsibilities conduct impact analyses that include reviewing system security plans, policies, and procedures to understand security requirements; reviewing system design documentation and operational procedures to understand how system changes might affect the security state of the system; reviewing the impacts of system changes on supply chain partners with stakeholders; and determining how potential changes to a system create new risks and the ability to mitigate those risks. Impact analyses also include risk assessments to understand the impacts of changes and determine whether additional security requirements are needed. Changes to the system may affect the safeguards and countermeasures previously implemented. This requirement is related to 03.04.03. Not all changes to the system are configuration controlled.

Bare Metal Cyber interpretation

Implementation perspective

Treat Impact Analyses as a CUI protection outcome that must be reflected in the system boundary, documented implementation, operational behavior, and assessment evidence. Pay particular attention to approved baselines, secure configuration, change control, inventories, and drift management within the CUI boundary.

  1. Confirm the requirement is in scope for the CUI system components, services, users, and external connections being assessed.
  2. Resolve every organization-defined parameter through an approved governance and tailoring process.
  3. Map each clause of the requirement to an accountable owner, implementation mechanism, and evidence source.
  4. Verify that inherited and shared implementations are supported by current provider evidence and responsibility boundaries.
  5. Collect evidence during normal operation and review changes, exceptions, and deficiencies on a risk-based cadence.

Questions to ask

  • Which CUI assets, data flows, users, and services are protected by this requirement?
  • Which portions are implemented locally, inherited, shared, or not applicable, and what evidence supports that determination?
  • Do the system security plan, deployed configuration, operating process, and assessment evidence tell the same story?
  • What change, incident, or threshold should trigger reassessment?

Evidence and validation

  • approved baseline configurations
  • change tickets and approvals
  • configuration scan and drift reports
  • software and hardware inventories

Common failure patterns

  • baselines documented but not enforced
  • emergency changes never reconciled
  • cloud or ephemeral assets missing from inventory
  • security impact analysis performed after deployment
Official NIST SP 800-171A content

Assessment objectives and methods

Assessment objectives (2)
  1. b.

    the security requirements for the system continue to be satisfied after the system changes have been implemented.

  2. a.

    changes to the system are analyzed to determine potential security impacts prior to change implementation.

Examine

  • configuration management policy and procedures
  • procedures for security impact analyses for system changes
  • configuration management plan
  • security impact analysis documentation
  • system design documentation
  • analysis tools and outputs
  • change control records
  • system audit records
  • system security plan
  • other relevant documents or records

Interview

  • personnel with security impact analysis responsibilities
  • personnel with information security responsibilities
  • members of change control board
  • system developers
  • system administrators

Test

  • processes for security impact analyses
Official source-control relationships

Source NIST SP 800-53 controls

These controls are referenced by the official SP 800-171 Rev. 3 OSCAL record. Open the corresponding control pages for complete control text, enhancements, D3FEND mappings, and related learning.

Source controlCM-4Open SP 800-53 control →Source controlCM-4(2)Open SP 800-53 control →
Source record

Authoritative sources

Bare Metal Cyber is an independent educational publisher and is not affiliated with or endorsed by NIST. The official publications, the responsible federal agency, and the governing contract or agreement determine applicability, tailoring, assessment depth, and required implementation.