CMMC Level 2 Practice 3.6.2: Track, document, and report incidents to designated officials and/or authorities both internal

To meet CMMC Level 2 Practice 3.6.2, you must run an incident tracking and reporting workflow that captures incidents in a system of record, documents what happened and what you did, and routes required notifications to the right internal officials and, when applicable, external authorities. Assessors will look for consistent operation and repeatable evidence. ¹

Key takeaways:

• Define “incident” for your CUI environment and require every incident to be logged, triaged, and time-stamped in a ticketing/workflow tool. ¹
• Pre-assign who gets notified, when, and how; test the reporting path with tabletop exercises and retain the artifacts. ¹
• Build assessment-ready evidence: incident register, reports, notifications, after-action reviews, and metrics showing the process runs in practice. ¹

Practice cmmc level 2 practice 3.6.2: track, document, and report incidents to designated officials and/or authorities both internal requirement is operational, not theoretical. You are being asked to prove two things: (1) you can reliably capture and manage incidents as work, and (2) you can escalate and report those incidents to the right people quickly and consistently. The control fails most often where teams rely on informal channels (chat messages, hallway conversations) or where “incident response” exists as a policy but not as a running workflow with tickets, timestamps, and approval trails.

For a CCO or GRC lead, the fastest path is to treat 3.6.2 like an auditable business process: define scope (what counts as an incident in systems handling CUI), assign roles (who is “designated”), implement the workflow in a system of record, and pre-author the reporting templates so responders can execute under pressure. Your assessor will not grade you on having the most sophisticated tooling. They will grade you on whether the process exists, is followed, and is evidenced. ¹

Regulatory text

Requirement (mapped): “CMMC Level 2 practice mapped to NIST SP 800-171 Rev. 2 requirement 3.6.2 (Track, document, and report incidents to designated officials and/or authorities both internal).” ¹
Program context: CMMC is implemented through the DoD program and rule framework. ^{2 3}

Operator meaning: You need an incident handling mechanism that:

1. tracks incidents (a controlled log/workflow),
2. documents incidents (facts, impact, actions, decisions), and
3. reports incidents to designated internal officials and, when applicable, external authorities.

Plain-English interpretation

If something that looks like a security incident happens in your CUI environment, you must open a record, work it to closure, and notify the right people through defined channels. “Designated officials” means you pre-identify who receives reports (by role, not by person), and you can show those notifications occurred. ¹

This practice is narrower than “do incident response well.” It focuses on traceability and reporting discipline:

• Traceability: every incident is uniquely identified, time-stamped, and status-tracked.
• Reporting discipline: escalation is not improvised; it follows a defined route.

Who it applies to

Entities: Defense contractors and other organizations handling Controlled Unclassified Information (CUI) who are pursuing or required to meet CMMC Level 2. ^{2 3}

Operational context: Any environment where you store, process, or transmit CUI (including enclaves, cloud services in scope, endpoints, and supporting identity and logging systems). If a third party operates part of the in-scope environment (e.g., managed security provider, hosting provider), you still need your own tracking and reporting workflow and clear handoffs. ¹

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

1) Define “incident” for your CUI scope

• Write an incident definition aligned to your environment: unauthorized access, malware, suspicious authentication, data exfiltration indicators, misdelivery of CUI, lost devices with CUI access, etc.
• Establish severity levels and what triggers “reporting” versus “record only.” Output: Incident classification standard (1–2 pages) mapped to systems handling CUI. ¹

2) Designate officials and document the reporting matrix

Create a simple RACI + notification matrix:

• Internal designated officials (minimum set): Incident Response Lead, CISO/IT Security, Legal/Compliance, Program/Contract leadership for affected contracts, and an executive sponsor for major incidents.
• External authorities: Identify which events might require notification to government or other authorities based on your contracts and incident type; document who makes the decision to notify and who sends it. Output: “Incident Reporting & Escalation Matrix” (roles, triggers, channels, required content). ¹

3) Implement a system of record for incident tracking

Pick one place where incidents live end-to-end:

• Ticketing system (ITSM), security incident platform, or a controlled GRC workflow. Minimum features:
• Unique ID, timestamps, status, owner, severity, affected assets, affected data type (CUI yes/no), and links to evidence (logs, emails, screenshots). Output: Configured incident record type + required fields + access controls. ¹

Practical note: Email inboxes and chat channels do not satisfy “track” and “document” unless they feed a controlled record with retention and audit history.

4) Standardize the incident report package (templates)

Create templates responders can fill fast:

• Initial incident report (what/when/how detected, suspected scope, immediate containment actions)
• Update report (new findings, impact assessment, root cause hypothesis)
• Closure report (root cause, confirmed scope, lessons learned, corrective actions, validation) Output: Approved templates stored in your controlled document repository. ¹

5) Build the reporting workflow (who gets what, when)

For each severity level, define:

• Notification triggers: “CUI potentially impacted,” “lateral movement suspected,” “privileged account compromise,” etc.
• Delivery channels: ticket notification, email distribution list, phone bridge for high severity.
• Minimum content: incident ID, classification, summary, current status, requested decisions. Output: Workflow procedure that a responder can execute without interpretation. ¹

6) Train, test, and prove the process runs

• Train on how to open an incident, what fields are mandatory, and how to send the report.
• Run tabletop exercises that specifically test “report to designated officials” and capture artifacts. Output: Training roster, tabletop agenda, attendance, after-action notes, and follow-up tickets. ¹

7) Operationalize recurring evidence capture (assessment readiness)

Set a cadence to export or snapshot:

• Incident register
• Closed incident reports
• Evidence links
• Metrics (counts by category/severity, time-to-triage, overdue incidents) A platform like Daydream can help you map 3.6.2 to the exact workflow steps and automate recurring evidence collection so you are not assembling proof manually right before assessment.

Required evidence and artifacts to retain

Assessors typically want to see design + operation. Keep both.

Design artifacts

• Incident Response Policy and Incident Handling Procedure that includes tracking/documentation/reporting steps. ¹
• Incident classification/severity definition and “what is an incident” criteria. ¹
• Reporting & escalation matrix naming designated roles (and alternates) and external notification decision owner. ¹
• Reporting templates (initial/update/closure). ¹

Operational artifacts

• Incident tickets/records showing required fields populated and time-stamped.
• Example incident report packages sent to internal designated officials (emails, ticket notifications, meeting minutes).
• Evidence of internal reporting during an incident: screenshots, distribution list membership, call bridge notes.
• Post-incident reviews / corrective action plans with tracking to closure.

Common exam/audit questions and hangups

1. “Show me how you decide something is an incident.” If your definition is vague, you’ll get inconsistent tickets and inconsistent reporting.
2. “Who are the designated officials?” Naming a person is fragile; assessors prefer role-based designation with alternates. ¹
3. “Prove you reported incidents.” They will ask for artifacts beyond a policy: actual records, notifications, and closure reports.
4. “How do you ensure third-party incidents enter your process?” If an MSSP detects an event, you still need your own incident ID and your own reporting record.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails 3.6.2	Fix
Tracking incidents in multiple places (SIEM case, email thread, spreadsheet)	No single source of truth; weak audit trail	Mandate one system of record; link out to tools for evidence only.
No clear “designated officials” list	Reporting becomes discretionary	Publish an escalation matrix by role with backups and distribution lists.
Incident tickets lack CUI relevance fields	You can’t prove CUI-scoped reporting	Add “CUI potentially involved” and “system boundary” fields; require completion.
Tabletop exercises exist but don’t test reporting	Gaps appear during real events	Include explicit injects: “Notify program leadership,” “Brief compliance/legal,” “Draft report.”
Treating “report” as a one-time action	Reporting is ongoing as facts change	Require initial + update + closure reporting for defined severities.

Enforcement context and risk implications

No public enforcement cases were provided in the source set for this requirement, so don’t anchor your program to assumed penalty patterns. What you can say with confidence: weak incident reporting increases the chance you miss contractual notification duties and creates assessment risk because CMMC relies on verifiable practice operation. ^{2 3 1}

Practical execution plan (30/60/90-day)

You asked for speed; here is a plan you can run without waiting on major tooling changes.

First 30 days (stabilize the minimum viable process)

• Publish incident definition + severity levels for the CUI environment.
• Name designated officials by role; create distribution lists and alternates.
• Configure the incident record in your ticketing/workflow system with required fields.
• Approve initial/update/closure report templates.
• Run one reporting-path tabletop and capture artifacts.

Days 31–60 (make it repeatable and auditable)

• Integrate detection sources into intake (SOC alerts create draft tickets; helpdesk can escalate).
• Add quality checks: required fields, manager review for closure, and evidence link requirements.
• Build a standard incident “report packet” export (PDF or GRC attachment bundle).
• Start a recurring metrics review with Security + Compliance.

Days 61–90 (assessment hardening)

• Sample-test closed incidents for completeness; fix gaps with coaching.
• Tune escalation triggers for CUI-related events based on lessons learned.
• Expand tabletop scope to include a third party scenario and executive reporting.
• Implement recurring evidence capture and control mapping in Daydream so your 3.6.2 evidence stays current between assessments.

Frequently Asked Questions

What counts as an “incident” for 3.6.2?

Define it for your CUI scope and include events that could affect confidentiality, integrity, or availability of CUI systems. Document the criteria so different teams classify events consistently. ¹

Do we have to report every incident to external authorities?

3.6.2 requires reporting to designated officials and/or authorities; it does not list specific external notification thresholds in the provided text. Document your decision path and contract-driven triggers, then prove you followed it. ¹

Can our MSSP track incidents for us?

They can support detection and casework, but you still need a controlled record and reporting trail inside your compliance boundary. Make the handoff explicit: MSSP case ID links to your internal incident ID and reporting artifacts. ¹

What evidence is strongest for assessors?

Closed incident records with timestamps, ownership, linked evidence, and copies of reports/notifications sent to designated roles. Tabletop artifacts help when you have limited real incidents, but they should not be your only proof. ¹

We rarely have incidents. Will that hurt us?

Low incident volume is common; assessors still expect the mechanism to exist and be testable. Use tabletop exercises and simulated tickets to prove the workflow, reporting, and documentation steps. ¹

How granular should documentation be in an incident ticket?

Enough to reconstruct what happened, what data/systems were affected, decisions made, actions taken, and who was notified. If a new responder can’t pick it up mid-stream, your documentation is too thin. ¹

Footnotes

1. NIST SP 800-171 Rev. 2

2. DoD CMMC Program Guidance

3. 32 CFR Part 170