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NIST 800-53 CM-1 Configuration Management Policy and Procedures

CM-1 requires a documented configuration management policy and procedures with a named owner and a review cycle. Here is what a reviewer wants to see.

Safeguard Security Team
3 min read

CM-1 is the policy control for the Configuration Management family. Every family in 800-53 opens with one. The text asks you to develop, document and share a configuration management policy and the procedures that carry it out, name an official to own them, and review and update both on a set schedule and after defined events.

The policy must cover purpose, scope, roles, responsibilities, management commitment, coordination among organizational entities and compliance. It must be consistent with applicable laws and standards. 800-53 binds federal systems and, by contract, others. For everyone else it is a reference, and a short policy that matches it will satisfy most customer questionnaires.

What it means in practice

NIST's guidance makes two points that save effort. First, organization level policy is preferable and can remove the need for a separate policy per system. Second, the policy can sit inside a general security policy or be split into several documents. You do not need a thick binder.

The guidance also warns that simply restating the controls is not a policy. A real policy says who decides what, which changes need approval, and what happens when someone ignores the rule.

Evidence to collect

  • The signed or approved policy, with version history and a date.
  • The procedures document, or the runbooks and wiki pages that act as procedures.
  • The named owner of the policy, shown by role or title.
  • Proof of distribution, such as an acknowledgement log or intranet publication record.
  • Review records showing the last review date and what changed.

Common gaps

  • A policy copied from a template that names tools you do not use.
  • No named owner, or an owner who left.
  • Procedures that describe a process nobody follows.
  • No review after an incident or audit finding, which the guidance lists as a trigger for an update.
  • Policy dated three years ago with no review stamp.

How to implement it

Write the policy in two pages. Cover scope, roles, how baselines are set, how changes are approved and how exceptions are handled. Link it to the procedures for CM-2 baselines, CM-3 change control and CM-8 inventory. Put the review date in the calendar and add an event trigger for incidents and major audit findings.

Quick check

Does one organization wide policy cover every system?

It can. The guidance prefers organization level policy and says it may remove the need for system specific versions, with procedures filling in the detail where needed.

Sources

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