Network management and resilience

To meet the network management and resilience requirement, you must (1) segment your network so critical systems and sensitive data are isolated from general traffic, and (2) monitor network activity so you can detect, contain, and recover from cyber events quickly. Operationalize this by defining a standard network architecture, enforcing segmentation boundaries, and proving continuous monitoring plus response workflows ¹.

Key takeaways:

• Segmentation is a control, not a diagram: enforce boundaries with technical rules, not just “zones” on paper ¹.
• Monitoring must produce action: alerts route to owners, incidents get triaged, and changes are tracked end-to-end ¹.
• Evidence wins exams: keep architecture standards, segment rules, logs, alert tickets, and validation results together ¹.

“Network management and resilience” sounds broad, but HICP’s requirement is focused: segment and monitor network infrastructure for cyber resilience ¹. For a Compliance Officer, CCO, or GRC lead, the fastest path is to translate that sentence into (a) enforceable network boundaries around your highest-risk assets (EHR, identity systems, backups, medical device networks, payment systems), and (b) monitoring that can detect lateral movement, misconfigurations, and suspicious traffic early enough to contain impact.

Most audit failures here are not about missing tools. They’re about missing operational clarity: no written architecture standard, inconsistent segmentation between sites/cloud, unclear alert ownership, and weak evidence that segmentation and monitoring work as intended. You need a control story that an examiner can follow in one sitting: what you segmented, why you segmented it, how you enforce it, how you monitor it, how you respond, and how you validate it.

This page gives requirement-level guidance you can implement quickly, with artifacts you can retain for audit readiness under HICP-aligned expectations ¹.

Regulatory text

Regulatory excerpt (HICP-05): “Segment and monitor network infrastructure for cyber resilience.” ¹

Operator interpretation: what you must do

1. Segment: Create and enforce network boundaries so a compromise in one area does not automatically spread to critical systems or sensitive data stores. Segmentation must exist in configuration (firewall rules, ACLs, security groups, microsegmentation policies), not only in a network diagram ¹.
2. Monitor: Collect and review network telemetry (logs, flows, detections) to identify abnormal activity and support rapid containment and recovery. Monitoring must connect to an escalation path and response workflow ¹.
3. Resilience outcome: Your design and operations should reduce blast radius and shorten detection-to-containment time by making lateral movement harder and more visible ¹.

Plain-English interpretation (what “good” looks like)

You can explain, in plain language, “If a workstation gets infected, it cannot directly reach the EHR database or backup environment; and if something tries, we will see it and respond.” That statement becomes true only if:

• network zones are defined based on risk and function,
• traffic between zones is explicitly controlled,
• exceptions are documented and reviewed,
• monitoring has coverage across key choke points and produces tickets, not just dashboards ¹.

Who this applies to (entity and operational context)

Entity types: Healthcare organizations ¹.
Operational contexts where examiners focus:

• Multi-site networks (clinics, hospitals, labs) with shared connectivity
• Hybrid environments (on-prem + cloud + SaaS)
• High-availability clinical operations where downtime is a patient safety issue
• Networks that include medical devices, OT-like systems, or segmented “clinical VLANs”
• Remote access (VPN, ZTNA, vendor access) that can bypass internal boundaries

If you rely on third parties for managed firewalls, SOC monitoring, MDR, or network operations, this requirement still lands on you. Your job is to define standards, verify they’re enforced, and retain evidence.

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

Step 1: Define a network architecture standard (the control backbone)

Create a short, enforceable “Network Architecture and Segmentation Standard” that answers:

• Zones/segments you require (examples: user, server, identity, EHR/app, database, backups, management, guest, medical device)
• Trust rules (default deny between zones; allow by documented need)
• Admin pathways (separate admin network/jump hosts; restrict management plane exposure)
• Remote access patterns (how VPN/ZTNA lands; what it can reach)
• Cloud mapping (how security groups/VPCs/subnets map to the same zoning concept)
• Logging/monitoring minimums (what must log, where it goes, who reviews)
  This is the “standard” referenced in the HICP recommended control: “Maintain network architecture standards and monitoring response.” ¹

Practical tip: Keep the standard readable. If it’s too long, engineers won’t follow it and auditors won’t trust it.

Step 2: Build an inventory of segmentation “enforcement points”

Document where segmentation is actually enforced:

• Firewalls and rulebases (perimeter and internal)
• Router ACLs
• Cloud security groups / NACLs
• Microsegmentation policies (if used)
• VPN/ZTNA policy engines
• Network access control (if used)

Create a simple matrix: Zone A → Zone B → Allowed ports/protocols → Business justification → Owner → Ticket/reference. This matrix becomes your primary audit artifact for “segmented.”

Step 3: Implement segmentation controls and harden exceptions

Do the technical work (or drive it through IT/network owners):

• Set inter-zone traffic to “deny by default” where feasible, then add explicit allows.
• Restrict high-risk pathways: user-to-server, user-to-database, user-to-backups, and any direct path to identity infrastructure.
• Separate management interfaces from production user networks.
• Require documented exceptions with an expiration or periodic review cadence.

Exam reality: Most environments have legacy exceptions. Your compliance win is to show you govern them.

Step 4: Establish monitoring coverage that supports containment

Define monitoring requirements tied to segmentation:

• Log sources: firewall allow/deny, VPN/ZTNA auth events, IDS/IPS alerts if present, DNS where available, critical switch/router logs if relevant.
• Collection: centralize logs to your SIEM/log platform (in-house or managed).
• Detections: rules for lateral movement indicators, unusual east-west traffic, repeated denies, new inbound rules, remote admin activity.
• Triage: assign alert ownership (SOC/NOC/IR), severity criteria, and response SLAs you can meet.

Monitoring is not “we have a SIEM.” Monitoring is: “This alert fired, ticket was created, triaged, resolved, and the rule/change record exists.”

Step 5: Create a “monitoring response” runbook tied to network events

Write a short runbook for network-driven incidents:

• What constitutes a network security incident (examples tied to your environment)
• Immediate containment steps (block IP, disable account, isolate segment, revoke VPN session)
• Who can approve emergency firewall changes
• How to document actions (ticketing, change record, IR case)

This directly supports the HICP recommended control language around “monitoring response.” ¹

Step 6: Validate segmentation and monitoring (prove it works)

Validation should include:

• Rule review: periodic review of inter-zone rules and exceptions
• Connectivity testing: confirm “should not talk” paths fail, and “must talk” paths work
• Monitoring test: generate a benign test event (example: simulated deny bursts or controlled scan in a test segment) and confirm alerting plus ticket creation
• Change control: confirm firewall/security group changes are tracked and approved

If you use Daydream to manage evidence, treat validation outputs as first-class artifacts: test records, screenshots, exported rule reports, and tickets all map cleanly to the network management and resilience requirement.

Required evidence and artifacts to retain (audit-ready)

Keep these in a single “Network Management & Resilience” evidence folder (or control record):

Design and governance

• Network Architecture and Segmentation Standard (approved, versioned) ¹
• Network diagrams (logical zones and major enforcement points)
• Zone-to-zone traffic matrix (allowed flows, owners, justifications)
• Exception register (with approvals and review notes)

Operational proof

• Firewall/security group configuration exports (or rule reports) showing segmentation enforcement
• Change tickets for segmentation rule changes (approval + implementation notes)
• Monitoring configuration summary (log sources enabled, forwarding confirmation)
• Sample alerts and associated incident/ticket records showing triage and closure
• Periodic reviews (meeting notes, sign-offs) and validation test records

Third party dependencies (if applicable)

• Managed SOC/MDR scope statements showing network telemetry coverage
• Service reports that evidence monitoring and response activities

Common exam/audit questions and hangups

Auditors and assessors tend to ask:

• “Show me where segmentation is enforced, not just drawn.”
• “Which systems are in the most protected segments, and why?”
• “How do you control traffic from user networks to critical applications and identity?”
• “Where do firewall logs go, and who reviews alerts?”
• “Prove a real example of detection → ticket → action.”
• “How do you review and remove old firewall rules and exceptions?”

Hangups that slow teams down:

• No single owner for segmentation across sites/cloud
• Monitoring tools exist, but logs aren’t consistently forwarded
• Network changes happen outside change control during emergencies, with no later reconciliation

Frequent implementation mistakes (and how to avoid them)

1. Mistake: segmentation by VLAN naming only.
   Fix: require enforcement at L3/L4 with explicit rules between zones; retain rule exports as evidence.

2. Mistake: “flat” remote access that drops users into broad internal access.
   Fix: restrict VPN/ZTNA to specific apps/segments; document the pattern in the architecture standard.

3. Mistake: monitoring without ownership.
   Fix: define alert owners and routing. Every high-severity alert should create a ticket.

4. Mistake: unmanaged exceptions.
   Fix: maintain an exception register and review it on a defined cadence; remove or tighten stale rules.

5. Mistake: cloud segmentation treated as separate from on-prem.
   Fix: map VPCs/subnets/security groups to the same zone model; show the mapping in documentation.

Enforcement context and risk implications

No public enforcement cases were provided in the supplied source catalog for this requirement, so this page does not list specific cases. Operationally, weak segmentation and weak monitoring increase blast radius and prolong dwell time during an incident, which can raise patient safety risk and business interruption exposure in healthcare environments ¹.

Practical 30/60/90-day execution plan

Days 0–30: Establish control design and evidence structure

• Assign accountable owners: Network Engineering (build), Security Operations (monitoring), GRC (evidence and governance).
• Publish the Network Architecture and Segmentation Standard (draft → approve).
• Identify critical segments (identity, EHR/app, database, backups, management).
• Stand up an evidence register in Daydream (or your GRC system): list each artifact, owner, and where it lives.
• Confirm firewall and remote access logging is enabled at key enforcement points.

Days 31–60: Implement high-impact segmentation and monitoring workflows

• Build/clean the zone-to-zone traffic matrix for critical segments.
• Reduce broad “any/any” rules where feasible; document unavoidable exceptions with approvals.
• Route network alerts into ticketing with assigned queues and triage procedures.
• Write the network monitoring response runbook and confirm on-call coverage.

Days 61–90: Validate, tune, and make it exam-ready

• Run segmentation validation tests and document outcomes.
• Execute a monitoring test: confirm alert → ticket → response steps are performed and recorded.
• Perform the first formal firewall rule and exception review; record decisions and changes.
• Produce a one-page “control narrative” for auditors: scope, zones, enforcement points, monitoring, response, validation evidence pointers.

Frequently Asked Questions

What counts as “segmentation” for the network management and resilience requirement?

Segmentation means enforced boundaries that restrict traffic between network areas, typically through firewalls, ACLs, security groups, or microsegmentation policies. A diagram alone is not evidence; you need configuration and rule outputs that show the restrictions ¹.

Do we need microsegmentation to be compliant?

No. HICP’s requirement is to segment and monitor; it does not prescribe a specific technology ¹. Many organizations meet the intent with well-designed zones and internal firewalling plus monitoring and response.

How do we show auditors that monitoring is real and not just a tool subscription?

Retain log forwarding evidence, sample alerts, and the related tickets/incident records that show triage and action. Examiners want a trace from detection to response steps ¹.

We have legacy firewall rules that are too risky to change quickly. What should we do first?

Document the current state, create an exception register, and prioritize tightening paths into identity systems, backups, and high-value clinical applications. Pair any temporary exceptions with monitoring rules and a removal plan ¹.

Does this requirement apply to cloud networks too?

Yes, in practice it applies wherever your network exists. You should map cloud network constructs (VPCs/subnets/security groups) to your zone model and retain exports or reports that evidence enforced segmentation and monitoring ¹.

What evidence is strongest if a third party runs our SOC or network?

Keep the contract scope/SOW excerpts that define telemetry sources and response responsibilities, plus service reports or ticket exports showing monitoring and response activity. You still need your own architecture standard and segmentation decisions documented ¹.

Related compliance topics

• 2025 SEC Marketing Rule Examination Focus Areas
• Access and identity controls
• Access Control (AC)
• Access control and identity discipline
• Access control management

Footnotes

1. HHS 405(d) HICP