What evidence do auditors commonly ask for on CM-3 Configuration Change Control?

SSP CM-3 statement describing change types, the change advisory board, security impact analysis and retention of change records; Sample of production change tickets showing approval, security review, testing and post-implementation check; Configuration management policy and change control procedure; Approved baseline configurations for each platform family; Change advisory board minutes with risk assessments; Configuration drift detection reports from the CMDB or tooling.

What is the most common gap auditors find on CM-3?

Baselines exist on paper but production hosts drift without alerting

FedRAMP High (NIST SP 800-53 Rev 5 baseline) · CM - Configuration Management

`CM-3` Configuration Change Control

Determine, document, and approve changes; track, review, audit; CAB or equivalent; analyze security impact.

Source: FedRAMP High (NIST SP 800-53 Rev 5 baseline), CM-3. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open FedRAMP High (NIST SP 800-53 Rev 5 baseline) in the compliance library.

A FedRAMP baseline is a subset of NIST SP 800-53 Rev 5, enhancements included.

artefacts

held by a system

at each review

moderate

to go live

Cloud console / configuration management

where the evidence lives

teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

Approved baseline configurations for each platform family · Cloud console / configuration management
Configuration drift detection reports from the CMDB or tooling · Cloud console / configuration management

periodic reviewEvidence produced at each review

Sample of production change tickets showing approval, security review, testing and post-implementation check · Ticketing / ITSM
Change advisory board minutes with risk assessments · Cloud console / configuration management

governing documentDocuments that govern the control

SSP CM-3 statement describing change types, the change advisory board, security impact analysis and retention of change records · Policy repository / GRC workspace
Configuration management policy and change control procedure · Policy repository / GRC workspace

First move

Start with the 2 of 6 artefacts that already live in a system (Cloud console / configuration management); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

Baselines exist on paper but production hosts drift without alerting
Emergency changes bypass CAB and lack retrospective review
Unauthorised software present on endpoints not flagged by tooling

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

Build my evidence sheet

CM-2(7) Configure Systems and Components for High-Risk Areas · CM-3(1) Automated Documentation, Notification, and Prohibition