CMMC Level 2 Practice 3.14.1: Identify, report, and correct system flaws in a timely manner

CMMC Level 2 Practice 3.14.1 requires you to run a repeatable vulnerability and defect-management process that finds system flaws, routes them to the right owners, fixes them within defined time expectations, and proves it with evidence. Operationalize it by formalizing intake, triage, remediation, verification, and reporting across all systems in scope for CUI. ¹

Key takeaways:

• “Timely manner” must be defined by you as measurable internal targets (by severity and system criticality), then followed consistently.
• Assessors look for end-to-end traceability: detection → ticket → fix → validation → closure, plus metrics and exceptions.
• Evidence beats intent: recurring scan results, tickets, patch records, approvals, and closure verification are the core artifacts.

The fastest way to fail cmmc level 2 practice 3.14.1: identify, report, and correct system flaws in a timely manner requirement is to treat it as “we patch sometimes” instead of a controlled operational loop. This practice is part of CMMC Level 2’s alignment to NIST SP 800-171 Rev. 2 and focuses on whether your organization can reliably detect security-relevant weaknesses, route them to accountable owners, and remediate them on a schedule that matches risk. ¹

For a Compliance Officer, CCO, or GRC lead, the work is less about choosing a scanning tool and more about making sure the process is measurable, repeatable, and auditable across the CUI boundary. You need defined remediation targets, documented escalation rules, and proof that exceptions are controlled rather than ignored. Your assessor will test whether you can show consistent practice over time, not whether you can produce a policy PDF the week before the assessment. ²

This page gives requirement-level implementation guidance you can hand to IT, SecOps, and system owners: what to implement, how to run it week to week, what evidence to retain, and the audit questions that cause delays.

Regulatory text

Excerpt (as provided): “CMMC Level 2 practice mapped to NIST SP 800-171 Rev. 2 requirement 3.14.1 (Identify, report, and correct system flaws in a timely manner).” ¹

Operator interpretation: You must implement a closed-loop flaw remediation lifecycle for systems in scope for CMMC Level 2. That lifecycle must:

1. identify flaws (examples: vulnerabilities, missing patches, insecure configurations, defective controls),
2. report them through defined channels to accountable owners, and
3. correct them within time expectations you define and enforce, with validation that the fix worked. ¹

Plain-English interpretation (what the requirement really demands)

“System flaws” includes more than missing OS patches. Treat it as any weakness that could reduce confidentiality of CUI or the effectiveness of security controls, including:

• Vulnerabilities from authenticated scans (servers, endpoints, network devices, cloud workloads).
• Misconfigurations (open management ports, weak cipher suites, overly permissive firewall rules).
• Unsupported software and end-of-life platforms.
• Broken security tooling (logging agent offline, EDR not reporting).
• Defects found by admins, users, or third parties (including managed service providers). ¹

“Timely manner” is where teams get stuck. The standard does not hand you a single universal clock. Your job is to define internal remediation targets that reflect risk, then demonstrate you meet them or manage exceptions with approval and compensating controls. ¹

Who it applies to (entity and operational context)

This applies to organizations seeking or maintaining CMMC Level 2 for contracts involving Controlled Unclassified Information (CUI) handled in contractor systems. In practice, that means:

• Defense contractors and subcontractors with CUI in their environment.
• Shared services supporting CUI enclaves (identity, endpoint management, vulnerability management, ticketing) if they are part of the assessment scope.
• Third parties operating systems in scope (MSPs, cloud operators) where you still must govern the process and retain evidence. ^{3 2}

What you actually need to do (step-by-step)

1) Define scope and ownership (so flaws land with the right team)

• Maintain an inventory of in-scope assets (systems that store, process, or transmit CUI, plus supporting components).
• Assign a system owner for each asset group (server fleet, endpoints, network devices, M365/Azure tenant, Linux baseline, etc.).
• Identify who can approve exceptions (risk acceptance) and who can authorize emergency changes. ¹

Deliverable: RACI matrix for flaw remediation (SecOps, IT Ops, system owners, change management, GRC).

2) Establish flaw intake channels (identify + report)

Use multiple feeders; don’t rely on one scanner.

• Vulnerability scanner findings (authenticated where possible).
• Patch management platform reports.
• Configuration compliance checks (benchmarks, drift detection).
• User/admin reported issues (helpdesk categories).
• Threat intel/notification from OEMs and service providers. ¹

Control design tip: Normalize all findings into a single system of record (ticketing or GRC issue register) so you can prove end-to-end closure.

3) Create triage rules and a “timely manner” standard you can defend

Build a written standard that answers:

• How do you rate severity (CVSS, exploitability, asset criticality, CUI exposure)?
• What remediation target applies by severity category?
• What is the escalation path if remediation is late?
• What qualifies for a temporary mitigation vs. full remediation? ¹

Decision table (example structure you should implement):

Finding type	Severity driver	Owner	Required action	Allowed exception path
Vulnerability	Exploitable + internet-facing	SysOps	Patch or mitigate; verify	Documented risk acceptance + compensating control
Misconfiguration	CUI boundary control weakness	NetOps/SecOps	Correct config; validate	Emergency change allowed; log post-change review
Tooling failure	Monitoring gap	SecOps	Restore telemetry; confirm	Short-term alternate monitoring documented

Keep it measurable, but avoid publishing remediation times you cannot consistently meet.

4) Execute remediation through change control (correct)

• Open a ticket for each actionable flaw (or a parent ticket with clearly linked child tasks).
• Record: affected assets, severity rationale, due date per your standard, remediation plan, and test/rollback plan if relevant.
• Implement fixes through standard change management or an emergency process when needed.
• For exceptions, require: business justification, compensating controls, expiration date, approver, and re-review triggers. ¹

5) Verify and close (prove the fix worked)

Assessors will ask how you know the flaw was corrected.

• Re-scan the asset or re-run the configuration check.
• Capture evidence of the successful patch/config change.
• Close the ticket only after validation.
• Track repeats (same finding recurring) as a root cause signal. ¹

6) Measure, report, and improve (keep it running)

You need management visibility to prove “timely” is real:

• Backlog by severity and age.
• Overdue items and escalations.
• Exception register and expirations.
• Recurring flaw trends tied to asset classes or teams. ²

Practical note: Many teams can “do remediation,” but cannot show metrics over time. Build reporting into the process from the start.

Required evidence and artifacts to retain (assessment-ready)

Keep evidence that demonstrates repeatable operation across time:

• Flaw remediation policy/standard defining intake, triage, remediation targets, escalation, and exception handling. ¹
• Asset inventory / system boundary showing what is in scope for CUI. ²
• Vulnerability scan reports (raw outputs and summaries) showing identified flaws. ¹
• Tickets / work items showing assignment, dates, actions taken, and closure notes.
• Patch/config change records (change requests, approvals, deployment logs).
• Validation evidence (re-scan results, “fixed” status, screenshots/exports).
• Exception/risk acceptance register with approvals and expirations.
• Metrics (backlog, overdue, mean time-to-close as an internal metric, trend reports) with meeting notes where they’re reviewed. ²

If you use Daydream, map 3.14.1 to a named control, then schedule recurring evidence capture (scan exports, ticket samples, metrics) so you are not rebuilding proof right before an assessment. ²

Common exam/audit questions and hangups

Expect questions like:

• “Show me the last set of vulnerability scans for in-scope assets, and the resulting remediation tickets.” ¹
• “How do you define ‘timely’? Where is that documented, and who approved it?” ¹
• “Pick one critical finding. Walk me from identification through closure, including validation.” ¹
• “How do you handle flaws owned by a third party or cloud provider?” ²
• “What happens when remediation is overdue? Show escalation evidence.” ¹

Hangups that slow assessments:

• No consistent asset scope, so scan coverage is unclear.
• Tickets exist but do not tie back to scan evidence.
• “Fixed” is asserted without validation.
• Exceptions exist in email threads, not in a controlled register.

Frequent implementation mistakes (and how to avoid them)

1. Scanning without authenticated coverage. Many high-value findings require authenticated scans. Document where you cannot authenticate and what you do instead. ¹
2. No defined remediation targets. If “timely” is undefined, the assessor will treat it as uncontrolled. Write a standard and apply it consistently. ¹
3. Treating patching as the only flaw source. Track config drift, unsupported software, and security tooling outages as system flaws. ¹
4. Exception sprawl. Risk acceptances without expiration dates become permanent gaps. Require expirations and re-approval. ¹
5. Poor closure discipline. Don’t close tickets until validation evidence is attached.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this specific practice. From an operational risk view, weak flaw remediation increases the chance that known vulnerabilities or misconfigurations expose CUI, and it commonly cascades into failures in adjacent CMMC practices (configuration management, incident response, audit logging) because those controls depend on healthy systems and secure baselines. ^{1 2}

Practical 30/60/90-day execution plan

First 30 days (stand up the control so it can run)

• Confirm CUI scope and in-scope asset inventory owners. ²
• Write the flaw remediation standard: intake sources, severity method, remediation targets, escalation, exception workflow. ¹
• Choose the system of record for findings (ticketing or GRC register) and define required ticket fields.
• Run an initial scan cycle (or collect current outputs) and open remediation tickets for top findings.

By 60 days (prove repeatability and close the loop)

• Run a second identification cycle (scans/config checks) and demonstrate trend movement.
• Implement validation steps: mandatory re-scan or config check before closure.
• Start a weekly or biweekly remediation review meeting with owners; record minutes and decisions.
• Stand up exception register with approvers and expirations; migrate any “email exceptions” into the register.

By 90 days (assessment-ready evidence package)

• Demonstrate consistent performance against your “timely” targets, with documented escalations where you missed. Keep the misses; explain them.
• Produce a packaged evidence set: scan outputs, sample tickets, closure validation, exception log, and metrics reviewed by management.
• In Daydream, map 3.14.1 to your documented control and set recurring evidence requests to keep artifacts current for audits. ²

Frequently Asked Questions

What counts as a “system flaw” for 3.14.1?

Treat it as any weakness that could reduce confidentiality of CUI or weaken security controls, including vulnerabilities, misconfigurations, unsupported software, and broken security tooling. Document your categories and ensure each has an intake and remediation path. ¹

How do we define “timely manner” without a mandated deadline?

Write internal remediation targets based on severity and asset criticality, then show consistent operation and escalation when targets are missed. Assessors want a defined standard plus evidence you follow it. ¹

Do we need a vulnerability scanner to meet the requirement?

You need a reliable way to identify flaws; vulnerability scanning is the most common control, but it’s not the only feeder. Whatever you use, you must show detection, reporting, remediation, and validation with evidence. ¹

How do we handle flaws in cloud services or third-party managed systems?

Treat the third party’s responsibilities as part of your process: capture their advisories, open internal tickets, track mitigations, and retain their remediation evidence where available. If you cannot obtain proof, document compensating controls and the governance steps you took. ²

What evidence sampling do assessors usually accept?

Expect to provide scan outputs plus multiple end-to-end examples of tickets from identification through validated closure, including at least one exception. Keep evidence across time so it shows repeatability. ¹

Can we accept risk instead of fixing a flaw?

Yes, but only with a controlled exception workflow: documented justification, compensating controls, approver, expiration, and re-review. Exceptions should be visible in metrics and reviewed routinely. ¹

Footnotes

1. NIST SP 800-171 Rev. 2

2. DoD CMMC Program Guidance

3. 32 CFR Part 170