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CM-4 (02)Impact Analyses | Verification of Controls

Moderate
High

>Control Description

After system changes, verify that the impacted controls are implemented correctly, operating as intended, and producing the desired outcome with regard to meeting the security and privacy requirements for the system.

>FedRAMP Baseline Requirements

No FedRAMP-specific parameter values or requirements for this baseline.

>Discussion

Implementation in this context refers to installing changed code in the operational system that may have an impact on security or privacy controls.

>Assessment Interview Topics

Questions assessors commonly ask

Process & Governance:

  • What formal policies and procedures govern the implementation of CM-4(2) (Verification Of Controls)?
  • Who are the designated roles responsible for implementing, maintaining, and monitoring CM-4(2)?
  • How frequently is the CM-4(2) policy reviewed and updated, and what triggers policy changes?
  • What training or awareness programs ensure personnel understand their responsibilities related to CM-4(2)?

Technical Implementation:

  • Describe the specific technical mechanisms or controls used to enforce CM-4(2) requirements.
  • What automated tools, systems, or technologies are deployed to implement CM-4(2)?
  • How is CM-4(2) integrated into your system architecture and overall security posture?
  • What configuration settings, parameters, or technical specifications enforce CM-4(2) requirements?

Evidence & Documentation:

  • What documentation demonstrates the complete implementation of CM-4(2)?
  • What audit logs, records, reports, or monitoring data validate CM-4(2) compliance?
  • Can you provide evidence of periodic reviews, assessments, or testing of CM-4(2) effectiveness?
  • What artifacts would you present during a FedRAMP assessment to demonstrate CM-4(2) compliance?

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