Alternate Work Site

To meet the FedRAMP Moderate alternate work site requirement (NIST SP 800-53 Rev 5 PE-17), you must explicitly define which non-facility locations staff may work from, apply specific security controls to those locations, and periodically evaluate whether those controls are effective. Treat alternate work sites as in-scope operating environments, not an exception. ¹

Key takeaways:

• Document what counts as an “allowed” alternate work site and who can approve exceptions. ¹
• Implement minimum remote-site controls (devices, network access, physical privacy, and handling of sensitive information) and make them enforceable. ¹
• Assess effectiveness with evidence (technical checks, attestations, and targeted testing) and track remediation. ¹

“Alternate work site” sounds like a remote work policy topic, but PE-17 is an operations control: define the locations where people can perform work that touches your FedRAMP boundary, implement controls that reduce physical and environmental risk outside your facilities, and validate those controls work in practice. The quickest path to compliance is to stop treating remote work as a generic HR policy and instead manage it like a distributed extension of your system environment.

For Cloud Service Providers and agencies operating FedRAMP Moderate systems, alternate work sites often include employee homes, client sites, coworking spaces, hotels, and other temporary locations. Each of these introduces common failure modes: unauthorized viewing, loss or theft of devices/media, insecure networks, and inability to demonstrate what protections were in place at the time of an incident. PE-17 exists to make those risks manageable and auditable. ¹

This page translates PE-17 into a requirement-level playbook you can hand to IT, Security, and Compliance to implement quickly: a decision model for “allowed” sites, a baseline control set, how to test effectiveness, and the artifacts auditors expect to see.

Regulatory text

NIST SP 800-53 Rev 5 PE-17 requires that you: (1) determine and document organization-defined alternate work sites allowed for employee use, (2) employ organization-defined controls at those alternate work sites, and (3) assess the effectiveness of controls at alternate work sites. ¹

Operator interpretation (what the assessor will look for):

• You have a clear, written definition of acceptable alternate work sites (not “remote work allowed”).
• You can show controls are actually applied outside your facilities (not just “employees are trained”).
• You can show ongoing verification (technical checks, reviews, or testing) and a way to fix gaps. ¹

Plain-English requirement interpretation

PE-17 means: if staff perform work related to your FedRAMP system from somewhere other than your controlled facilities, you must (a) decide which locations are permitted, (b) set and enforce minimum safeguards for those locations, and (c) periodically confirm those safeguards are working.

This is not limited to engineers. Any role that can access the environment (admin consoles, support tooling, incident response, compliance evidence, customer data, logs) can create exposure from an alternate work site.

Who it applies to

Entity types

• Cloud Service Providers operating systems assessed against FedRAMP Moderate. ¹
• Federal agencies using or operating FedRAMP Moderate systems. ¹

Operational context (where PE-17 triggers)

• Remote or hybrid work arrangements where staff access in-scope systems from home or another location.
• On-call and incident response performed from non-office settings.
• Travel scenarios (hotel, airport lounge) where staff connect to administer or support the system.
• Contractor/third party personnel who have authorized access and work offsite (treat them as in-scope personnel for this requirement where applicable).

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

Step 1: Define “alternate work site” and categorize what is allowed

Create a short, enforceable definition and a site categorization model. Example categories you can operationalize:

• Approved fixed site (employee home office with declared address)
• Approved temporary site (short-term location with stricter constraints)
• Prohibited site (public spaces where privacy cannot be maintained)

Write down:

• Which categories are allowed for which roles (e.g., production admin work only from approved fixed sites).
• Who approves enrollment of a site category (manager, Security, or both).
• What makes a site prohibited (shared devices, uncontrolled physical access, inability to prevent shoulder surfing, etc.). ¹

Practical tip: Don’t overfit this. You need clarity and enforceability more than perfect taxonomy.

Step 2: Define required controls for alternate work sites (minimum baseline)

PE-17 lets the organization define controls, but you still need a defensible baseline. Build your control set around what you can prove and enforce:

A. Device and access controls (most testable)

• Require managed endpoints for any access to in-scope systems (MDM/EDR enrolled, encrypted storage, screen lock, patching).
• Require phishing-resistant MFA where feasible and conditional access (device compliance and location/risk signals).
• Restrict administrative access to hardened jump hosts or VDI when staff are offsite.

B. Network controls

• Require secure remote access (for example, VPN or ZTNA) with strong authentication.
• Block access from untrusted networks for privileged actions where feasible.
• Disable split tunneling for high-risk roles if your risk decision supports it (document the rationale either way).

C. Physical and environmental controls

• Require a private workspace or reasonable privacy protections (positioning screens, not taking sensitive calls in public areas).
• Require secure storage of devices and any sensitive information when unattended.
• Prohibit printing of sensitive materials at alternate work sites unless explicitly approved and protected.

D. Information handling

• Define what data can be viewed/handled offsite (logs, tickets, customer data) and what must remain in controlled environments.
• Require secure disposal rules for any work notes or physical artifacts.

The key is consistency: “organization-defined controls” must be documented, communicated, and implemented in a way that produces evidence. ¹

Step 3: Implement enforcement points (where policy becomes real)

Auditors struggle with “policy-only” controls. Add technical and procedural enforcement:

• Conditional access rules that require compliant devices for system access.
• Centralized logging that shows remote access paths and privileged sessions.
• Workflow gates for access approvals (role-based access and recertification triggers when someone becomes remote).

If you use Daydream to manage control owners and evidence requests, map PE-17 to a recurring evidence workflow: approved site register, control baseline, remote access configuration exports, and assessment results. That keeps the control from decaying between audits.

Step 4: Train personnel with role-specific expectations

Training should align to the controls you enforce:

• General staff: privacy practices, device handling, reporting loss/theft quickly.
• Privileged users: restrictions on public networks, required use of VDI/jump boxes, handling of sensitive logs and secrets. Keep acknowledgments tied to the alternate work site policy and updated when controls change. ¹

Step 5: Assess effectiveness and track remediation

PE-17 explicitly requires you to assess whether alternate work site controls work. Use multiple methods:

• Technical verification: reports from MDM/EDR (encryption enabled, screen lock, patch compliance), identity provider logs (MFA, device compliance), VPN/ZTNA logs.
• Targeted testing: sample-based checks of remote admins (are they using required paths, are privileged sessions recorded).
• Attestations: periodic employee affirmation for approved fixed sites (privacy, secure storage, no shared devices).
• Incident-driven review: if a remote-work-related event occurs, treat it as a control effectiveness signal and adjust.

Document findings, assign owners, and track corrective actions to closure. ¹

Required evidence and artifacts to retain

Maintain evidence that ties directly to the three PE-17 verbs: determine/document, employ, assess. A practical evidence set:

1. Alternate Work Site Policy / Standard

• Definitions, allowed site categories, prohibited conditions, role-based restrictions, exception process. ¹

2. Approved alternate work site register (or equivalent)

• List of staff approved for remote work, site category, approval date, approver, exceptions with expiration.

3. Control baseline for alternate work sites

• Endpoint security baseline (encryption, EDR, patching, screen lock).
• Remote access requirements (VPN/ZTNA, MFA, device compliance).
• Physical privacy and information handling rules.

4. Technical evidence

• Configuration exports/screenshots for conditional access, MFA policies, remote access tooling.
• MDM/EDR compliance reports.
• Logs demonstrating remote privileged access follows required paths.

5. Effectiveness assessment records

• Testing procedures, sampling approach, results, identified gaps, remediation tickets, closure evidence. ¹

6. Training and acknowledgment

• Training content, completion records, policy acknowledgment.

Common exam/audit questions and hangups

Expect these lines of inquiry:

• “Show me your documented list of allowed alternate work sites. Who decided and when was it updated?” ¹
• “How do you prevent admins from accessing production from a personal laptop?”
• “What controls apply to staff working from coworking spaces or while traveling?”
• “How do you verify these controls are in place and effective, beyond policy statements?” ¹
• “Show evidence of your last effectiveness assessment and the remediation outcomes.”

Hangups that create findings:

• “Remote work allowed” exists, but no definition of allowed locations or conditions.
• Controls exist technically, but there is no documented mapping showing they apply to alternate work sites.
• No repeatable assessment method; only ad hoc reviews after incidents.

Frequent implementation mistakes and how to avoid them

1. Mistake: Treating PE-17 as an HR telework policy.
   Fix: Build it as a security standard with enforceable requirements and evidence sources.

2. Mistake: Allowing exceptions without expiration.
   Fix: Require time-bound exceptions with re-approval and compensating controls documented.

3. Mistake: Relying on “user training” as the primary control.
   Fix: Put conditional access, device compliance, and privileged access pathways in front of the risk.

4. Mistake: Ignoring contractors/third parties with access.
   Fix: Extend the alternate work site rules to any authorized personnel with in-scope access, and require equivalent endpoint and remote access controls.

5. Mistake: No effectiveness assessment cadence or owner.
   Fix: Assign a control owner and run recurring evidence collection and testing; Daydream can automate reminders, evidence requests, and reviewer sign-off.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for PE-17, so treat this as an audit-and-authorization risk: weak alternate work site controls commonly surface as assessment findings because they are easy to test (device compliance, MFA, remote admin paths) and hard to defend with “policy only.” The business impact is delayed authorization, increased POA&M volume, and higher incident exposure tied to lost devices, insecure remote access, or inadvertent disclosure.

Practical execution plan (30/60/90)

You asked for speed; use this as a rollout sequence that aligns to how assessors test PE-17.

First 30 days (get to “documented and enforceable”)

• Publish the alternate work site definition, allowed categories, and exception process. ¹
• Identify roles requiring stricter constraints (admins, incident responders, support with sensitive access).
• Implement or tighten conditional access: managed device + MFA required for in-scope access.
• Stand up the evidence spine: where logs/reports come from, who exports them, where they’re stored, who reviews.

By 60 days (prove controls operate)

• Build the approved site register and complete initial enrollment for remote/hybrid staff.
• Roll out technical baselines to endpoints and confirm compliance reporting works.
• Implement privileged remote work paths (VDI/jump host) and document when required.
• Run the first effectiveness assessment and open remediation items. ¹

By 90 days (make it repeatable and audit-ready)

• Close high-risk remediation items and document compensating controls for anything outstanding.
• Operationalize a recurring assessment cycle and align it to audit evidence windows. ¹
• Add metrics that are defensible without statistics: completion status, exception inventory, open findings aging.
• Automate evidence collection and sign-offs in Daydream so PE-17 stays current without spreadsheet drift.

Frequently Asked Questions

Does “alternate work site” include an employee’s home?

Yes, if employees access or support the in-scope system from home, home becomes an alternate work site you must define as allowed (or not) and control under PE-17. Document the category, required controls, and how you verify them. ¹

Are hotels, airports, and coffee shops alternate work sites?

They can be. The practical approach is to classify them as prohibited for sensitive or privileged activities unless you define strict conditions and controls (for example, VDI-only, no customer data display). Your documentation should match what you actually permit. ¹

What does “assess the effectiveness” mean for remote sites?

It means you do more than publish rules. Show evidence of checks such as device compliance reports, access log review, sampling of privileged sessions, and tracked remediation when controls fail. ¹

How do we handle employees who refuse to register their home address?

Don’t force unnecessary personal data collection. You can approve a “fixed remote site” through an attestation model (employee confirms conditions are met) and validate through technical controls that don’t require an exact address, as long as you can explain and evidence your approach. ¹

Do we need onsite inspections of home offices?

PE-17 requires effectiveness assessment, not a specific inspection method. Most teams rely on technical enforcement plus attestations and targeted testing, because it scales and produces better audit evidence. ¹

How should we treat third party contractors who work remotely?

If they have authorized access to the system, treat their work location as an alternate work site in scope for PE-17. Require equivalent endpoint and remote access controls, and retain evidence through your third party onboarding and access approval workflows. ¹

Footnotes

1. NIST Special Publication 800-53 Revision 5