CMMC Level 2 Practice 3.6.1: Establish an operational incident-handling capability for organizational systems that includes

CMMC Level 2 Practice 3.6.1 requires you to stand up a working incident-handling capability for the systems in scope for CUI, not just a policy. You must define how incidents are detected, reported, triaged, contained, eradicated, recovered, and post-reviewed, and you must retain evidence that the process operates in day-to-day conditions. ¹

Key takeaways:

• Treat 3.6.1 as an operational capability with repeatable workflows, roles, and tooling, not a “document-only” control. ¹
• Scope the capability to your CMMC Level 2 environment (CUI boundary) and include third parties that can affect it. ²
• Build assessor-ready evidence: incident records, tickets, notifications, after-action reviews, and exercised procedures mapped to 3.6.1. ¹

For a CCO or GRC lead, the fastest path to meeting cmmc level 2 practice 3.6.1: establish an operational incident-handling capability for organizational systems that includes requirement is to translate “incident handling” into concrete operating procedures and proof that people follow them. Assessors typically look for two things: (1) clear, documented expectations for what happens when something goes wrong, and (2) records that show the capability works under real conditions.

This practice maps to NIST SP 800-171 Rev. 2 control 3.6.1 and sits inside the Incident Response family. ¹ Your obligation is not to prevent every incident. Your obligation is to be ready: know what qualifies as an incident, who is on point, how to escalate, what tools and data sources you will use, and how you will restore secure operations. You also need to handle incidents that occur through or within third-party services that touch your CUI environment, because incidents do not respect org charts.

The implementation guidance below is written to help you operationalize quickly: establish roles, build workflows, set minimum artifacts, and prepare for CMMC assessment expectations aligned to the CMMC Program framework. ^{3 2}

Regulatory text

Requirement (excerpt / mapping): CMMC Level 2 practice mapped to NIST SP 800-171 Rev. 2 requirement 3.6.1: “Establish an operational incident-handling capability for organizational systems that includes …” ¹

Operator meaning: You need an incident-handling capability that is active and usable for the organizational systems in your CMMC Level 2 scope. “Operational” means staff can execute it, leadership has assigned accountability, and you can show artifacts from real events and/or exercises that demonstrate the process works. ¹

Plain-English interpretation

You must be able to:

• Identify and declare incidents using defined criteria (what triggers “incident” vs. “event”).
• Route reports fast (employees and technical systems know where to send alerts).
• Manage the incident end-to-end (triage, containment, eradication, recovery, communications, and lessons learned).
• Prove it happened with documentation and records tied to your CUI environment. ¹

Who it applies to

Entity scope

• Organizations seeking CMMC Level 2 certification or attestation posture under the DoD CMMC Program, particularly those handling Controlled Unclassified Information (CUI). ^{2 3}

Operational scope (what systems)

• Systems inside your CUI boundary (the environment where CUI is stored, processed, or transmitted) and supporting security tooling that enables detection and response for that boundary. ¹
• Third parties that operate or administer in-scope infrastructure (e.g., MSPs, cloud providers, IR retainers) must be reflected in your incident handling paths, contracts, and contact lists because they can be the first to detect or the only party with certain logs. ¹

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

Step 1: Define “incident” for your environment and scope it to CUI

• Publish an incident classification guide that distinguishes:
  • security event (informational),
  • suspected incident (needs triage),
  • confirmed incident (execute response plan).
• Include examples tied to CUI risk: unauthorized access to CUI repositories, abnormal downloads, malware on endpoints used for CUI, misrouted CUI emails, lost devices with potential CUI exposure. ¹

Step 2: Assign roles and authority (RACI that works at 2 a.m.)

Minimum roles you should name:

• Incident Commander (owns coordination and decisions).
• Security/IR Operations (triage, investigation, containment actions).
• IT Operations (restore services, patching, rebuilds).
• Legal/Contracts (customer/DoD notification review where required by contract).
• Communications (internal comms templates).
• System Owners for in-scope systems (approve downtime, validate recovery). Document who can authorize containment steps like disabling accounts, isolating hosts, blocking egress, or shutting down a service. ¹

Step 3: Build the incident-handling workflow (playbooks + ticketing)

Create a single workflow that starts with “report/alert received” and ends with “post-incident review complete.” Your baseline playbooks should cover:

• Malware/ransomware on endpoints in the CUI boundary
• Suspected credential compromise (admin and standard users)
• Data spill/misrouting of CUI
• Third-party compromise affecting your tenant or managed environment

Make the workflow executable in your tooling:

• A ticket type for security incidents (with required fields: detection source, systems, time, severity, containment steps, evidence links, decision log).
• A chat/bridge process for major incidents (who starts it, who joins, how notes are captured).
• A single source of truth for status and timelines. ¹

Step 4: Establish intake and reporting channels (humans + machines)

You need at least:

• A monitored email alias or portal for employee reporting
• A hotline or on-call route for urgent events
• Alerts from security tooling relevant to the CUI boundary (SIEM/EDR/email security/cloud logs as applicable)

Document the expected response behavior: acknowledge, triage, escalate, and track to closure. ¹

Step 5: Prepare evidence-ready logging and preservation

Incident handling fails in assessments when teams cannot show what they knew and when they knew it. Require that responders:

• preserve relevant logs and snapshots,
• record containment actions and approvals,
• maintain chain-of-custody notes when needed (even lightweight),
• store artifacts in a controlled location with access restrictions.

Tie evidence retention to your recordkeeping approach for CMMC. ¹

Step 6: Exercise the capability and fix what breaks

If you have no recent real incidents, run tabletop exercises tied to your top scenarios and generate the same artifacts you would in a real event:

• an incident ticket,
• timeline,
• action log,
• communications artifacts,
• lessons learned and corrective actions.

An assessor usually accepts exercises as evidence of operational capability when they are realistic and documented. ¹

Step 7: Map 3.6.1 to control operation and recurring evidence capture

Operationalize the requirement as a control with:

• an owner,
• a cadence for review of incident tickets and post-incident actions,
• evidence collection tasks.

Daydream (as a GRC workflow system) fits naturally here: you can map 3.6.1 to your incident process, attach recurring evidence requests, and keep artifacts assessor-ready without chasing screenshots at the last minute. ²

Required evidence and artifacts to retain

Keep evidence that proves both design and operation:

Design artifacts (what you planned)

• Incident Response Policy or Incident Handling Standard (scope includes CUI boundary)
• Incident classification/severity matrix
• RACI/on-call roster and escalation paths
• Playbooks (top scenarios)
• Communications templates (internal stakeholder updates)

Operational artifacts (what you did)

• Incident tickets/case records (sanitized if needed, but show fields and workflow)
• Alert samples and triage notes
• Containment/eradication/recovery action logs
• Post-incident reviews (root cause, lessons learned, corrective actions)
• Evidence of third-party engagement when applicable (email thread, ticket, call notes)
• Tabletop/exercise records if no real incidents exist (agenda, attendees, injects, outputs) ¹

Common exam/audit questions and hangups

Assessors and internal auditors commonly probe:

1. “Show me your last incident.”
   Expect to produce a ticket with timestamps, actions, approvals, and closure rationale. ¹

2. “How do employees report a suspected incident?”
   They will test whether reporting paths are documented and monitored.

3. “What systems are in scope?”
   If your incident process covers the whole enterprise but you cannot show it includes CUI systems explicitly, you may get a finding for weak scoping.

4. “What happens if your MSP detects something first?”
   If third-party roles are unclear, response breaks down. Document handoffs and SLAs in contracts or operating procedures.

5. “How do you capture lessons learned and ensure remediation happens?”
   A post-incident review without tracked corrective actions reads as “checkbox IR.” ¹

Frequent implementation mistakes and how to avoid them

• Mistake: Policy-only incident response.
  Fix: require incident tickets and post-incident reviews as mandatory artifacts for any confirmed incident or exercise. ¹

• Mistake: No decision authority documented.
  Fix: explicitly define who can isolate hosts, disable accounts, and approve downtime.

• Mistake: Unclear boundary (CUI vs. non-CUI).
  Fix: label systems in your asset inventory and align alerts/logging to that boundary. ¹

• Mistake: Third-party dependencies ignored.
  Fix: keep a third-party incident contact register and predefine when you engage them and how evidence is shared.

• Mistake: Exercises that produce no artifacts.
  Fix: treat a tabletop like a real incident from a documentation standpoint: tickets, timelines, action items, closure. ¹

Enforcement context and risk implications

CMMC is a DoD program with requirements implemented through contracts and the CMMC framework structure. ³ Practically, weak incident handling creates two risks you can control:

• Operational risk: you lose time during a security event because roles, actions, and approvals are unclear.
• Assessment/contractual risk: you cannot demonstrate “operational capability” during an assessment if you lack incident records, exercises, or evidence of repeatability tied to in-scope systems. ^{2 1}

Practical 30/60/90-day execution plan

First 30 days (stabilize and document the minimum viable capability)

• Confirm your CUI boundary and list the in-scope systems and key third parties. ²
• Assign incident roles, escalation paths, and an on-call process.
• Stand up an incident ticket workflow with required fields and an evidence attachment standard.
• Draft the incident classification guide and top playbooks.

Days 31–60 (make it real in operations)

• Connect detection sources for the CUI boundary to your intake (alerts create tickets or at least create triage tasks).
• Run a tabletop for a CUI-relevant scenario; generate full artifacts.
• Implement a post-incident review template with tracked corrective actions.
• Create a third-party incident contact register and validate contacts.

Days 61–90 (prove repeatability and assessor readiness)

• Run a second exercise with a different scenario (credential compromise or data spill).
• Perform a management review of incident records and corrective actions; document outcomes.
• Package evidence by control: map artifacts to 3.6.1 in your SSP/control tracker.
• If you use Daydream, configure recurring evidence requests and a dashboard view for 3.6.1 so you can produce artifacts on demand without rework. ²

Frequently Asked Questions

Does 3.6.1 require a dedicated SOC or 24/7 monitoring?

3.6.1 requires an operational incident-handling capability, not a specific organizational model. If you rely on an MSP/MSSP for monitoring or response, document the handoffs, contacts, and evidence flow so you can demonstrate operation. ¹

What if we have never had an incident in the CUI environment?

Run a realistic tabletop or simulated incident and produce the same records you would for a real event (ticket, timeline, actions, lessons learned). That is often the cleanest way to demonstrate operational capability. ¹

Can one enterprise incident response plan cover both CUI and non-CUI systems?

Yes, but you must clearly show that the plan applies to the CUI boundary and that the supporting tooling, roles, and evidence exist for those systems. Assessors will look for scope clarity and artifacts tied to in-scope assets. ¹

What evidence is most persuasive to an assessor for 3.6.1?

Completed incident tickets with timestamps and actions, plus post-incident reviews with corrective actions, usually carry the most weight. Exercises are also persuasive when documented like real events and tied to CUI scenarios. ¹

How do we handle incidents that involve a cloud provider or MSP?

Define triggers for engaging the third party, keep an incident contact register, and ensure your contract or operating procedures support timely information sharing and evidence retention. Your incident record should show what you requested, what they provided, and what actions you took. ¹

How do we keep this from becoming a “paper drill” that nobody follows?

Put the workflow in the tools teams already use (ticketing, chat bridge, on-call), require minimum fields and attachments for closure, and review incident records periodically with leadership so corrective actions get funded and completed. ¹

Footnotes

1. NIST SP 800-171 Rev. 2

2. DoD CMMC Program Guidance

3. 32 CFR Part 170