What evidence do auditors commonly ask for on PL-1 Policy and Procedures?

SSP PL-1 statement naming the planning policy owner and its review cadence (policy yearly for High, at least every three years for Moderate; procedures yearly for both); Planning policy and procedure with review approval; Concept of operations describing system mission and data flows; Privacy and security integration documentation; System security plan with control allocation matrix; Rules of behaviour signed by users including privileged personnel.

What is the most common gap auditors find on PL-1?

Planning artefacts lack version history and approval signatures

FedRAMP High (NIST SP 800-53 Rev 5 baseline) · PL - Planning

`PL-1` Policy and Procedures

Develop, document, disseminate and review the policy for planning, and its procedures, on the FedRAMP-defined cadence: policy at least annually under High and at least every three years under Moderate, procedures at least annually and after significant changes under both.

Source: FedRAMP High (NIST SP 800-53 Rev 5 baseline), PL-1. 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

hard

to go live

Policy repository / GRC workspace

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

Rules of behaviour signed by users including privileged personnel · Identity provider / directory

periodic reviewEvidence produced at each review

none for this control

governing documentDocuments that govern the control

SSP PL-1 statement naming the planning policy owner and its review cadence (policy yearly for High, at least every three years for Moderate; procedures yearly for both) · Policy repository / GRC workspace
Planning policy and procedure with review approval · Policy repository / GRC workspace
Concept of operations describing system mission and data flows · Document repository
Privacy and security integration documentation · Policy repository / GRC workspace
System security plan with control allocation matrix · Policy repository / GRC workspace

First move

Mostly documents and reviews. Pull the 1 system-held artefact from your Identity provider / directory on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.

Common gaps auditors find

Planning artefacts lack version history and approval signatures
Privacy considerations addressed separately from security planning
System security plan not refreshed after material system changes

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

PE-18 Location of System Components · PL-2 System Security and Privacy Plans