ISC2 Governance, Risk and Compliance (CGRC) Practice Question
While compiling the authorization package for a federal agency system, you discover several moderate vulnerabilities documented in the Security Assessment Report that will not be fixed for two months. To comply with NIST authorization guidance, how should you handle these issues before submitting the package to the authorizing official?
List every unresolved vulnerability in the POA&M, including planned corrective actions, resources, and milestone dates, and include it in the authorization package.
Remove the vulnerabilities from the package until they are fully remediated, then resubmit an updated SAR.
Combine all vulnerabilities into one consolidated risk statement without milestones to keep the package concise.
Note the vulnerabilities only in the SSP control narratives and create the POA&M after an Authorization to Operate is granted.
NIST SP 800-37 and related federal guidance define the authorization package as consisting of the System Security Plan (SSP), Security Assessment Report (SAR), and the Plan of Action and Milestones (POA&M). Any control weaknesses or deficiencies that cannot be remediated before the authorization decision must be recorded in a POA&M. Each entry must identify the weakness, planned remediation actions, responsible party, required resources, and a realistic milestone date for completion. Omitting the findings, delaying their documentation, or combining them into a single vague statement would deprive the authorizing official of the information needed to make a risk-based decision and violates OMB and NIST requirements. Therefore, the analyst should create or update the POA&M to include each unresolved finding with appropriate details and timelines, and submit it as part of the authorization package.
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ISC2 Governance, Risk and Compliance (CGRC)
System Compliance
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