CM-4(1)—Impact Analyses | Separate Test Environments

IL4 High

IL5

IL6

>Control Description

Analyze changes to the system in a separate test environment before implementation in an operational environment, looking for security and privacy impacts due to flaws, weaknesses, incompatibility, or intentional malice.

>DoD Impact Level Requirements

No specific parameter values or requirements for this impact level.

>Discussion

A separate test environment requires an environment that is physically or logically separate and distinct from the operational environment. The separation is sufficient to ensure that activities in the test environment do not impact activities in the operational environment and that information in the operational environment is not inadvertently transmitted to the test environment. Separate environments can be achieved by physical or logical means.

If physically separate test environments are not implemented, organizations determine the strength of mechanism required when implementing logical separation.

>Related Controls

SA-11

SC-7

>Assessment Interview Topics

Questions assessors commonly ask

Process & Governance:

•What formal policies and procedures govern the implementation of CM-4(1) (Separate Test Environments)?
•Who are the designated roles responsible for implementing, maintaining, and monitoring CM-4(1)?
•How frequently is the CM-4(1) policy reviewed and updated, and what triggers policy changes?
•What training or awareness programs ensure personnel understand their responsibilities related to CM-4(1)?

Technical Implementation:

•Describe the specific technical mechanisms or controls used to enforce CM-4(1) requirements.
•What automated tools, systems, or technologies are deployed to implement CM-4(1)?
•How is CM-4(1) integrated into your system architecture and overall security posture?
•What configuration settings, parameters, or technical specifications enforce CM-4(1) requirements?

Evidence & Documentation:

•What documentation demonstrates the complete implementation of CM-4(1)?
•What audit logs, records, reports, or monitoring data validate CM-4(1) compliance?
•Can you provide evidence of periodic reviews, assessments, or testing of CM-4(1) effectiveness?
•What artifacts would you present during a FedRAMP assessment to demonstrate CM-4(1) compliance?

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