03.14.01: Flaw Remediation

03.14.01: flaw remediation requirement is one of the fastest ways assessors distinguish a mature CUI security program from a policy-only program. Most teams can show a scanner report or a patch tool. Fewer can show a controlled, closed-loop system that starts with “we learned about a flaw” and ends with “we fixed it, validated the fix, and tracked exceptions with accountable approvals.”

For a Compliance Officer, CCO, or GRC lead, your job is not to run patch Tuesday. Your job is to make the requirement auditable across IT, security, and third parties: define scope (what counts as “in the system”), define decision rights (who can accept risk), define prioritization rules (what gets fixed first), and make the evidence easy to produce.

This page translates the 03.14.01: flaw remediation requirement into a working operating model you can implement quickly: a minimal process flow, roles and responsibilities, artifacts to retain, audit questions to pre-answer, and a practical execution plan you can run without rewriting your entire security program. (NIST SP 800-171 Rev. 3)

Regulatory text

Requirement (excerpt): “NIST SP 800-171 Rev. 3 requirement 03.14.01 (Flaw Remediation).” (NIST SP 800-171 Rev. 3)

Operator interpretation: You need a repeatable method to remediate discovered flaws (software defects, missing patches, misconfigurations with known security impact, vulnerable components) in the nonfederal system environment where CUI is processed, stored, or transmitted. The control is not satisfied by one-time cleanup; assessors expect ongoing operation with evidence that flaws are tracked through closure. (NIST SP 800-171 Rev. 3)

Plain-English interpretation (what the requirement is asking for)

If a vulnerability or security defect is found in your CUI environment, you must:

1. Know about it (from scanning, advisories, vendor notices, threat intel, pentest findings, incident learnings).
2. Decide what it means (affected assets, exploitability, business impact).
3. Fix it or mitigate it (patch, configuration change, compensating control).
4. Prove it’s fixed (validation and closure evidence).
5. Manage exceptions (risk acceptance with expiration and tracking). (NIST SP 800-171 Rev. 3)

Who it applies to

Entities: Federal contractors and other organizations operating nonfederal systems that handle CUI. (NIST SP 800-171 Rev. 3)

Operational context (where it bites):

• Endpoints, servers, cloud workloads, network devices, appliances, hypervisors, containers, and managed SaaS configurations that support CUI workflows.
• Third-party-managed infrastructure or applications in your CUI boundary. You still own compliance; the third party may operate the fix. (NIST SP 800-171 Rev. 3)

People who must participate:

• System Owners / Application Owners: approve downtime, validate functionality after fixes.
• IT Operations: deploy patches and configuration changes.
• Security (Vuln Mgmt): triage, prioritize, verify remediation.
• GRC/Compliance: define evidence, enforce exception governance, ensure scope coverage.
• Third parties: provide patch status and remediation proof for in-scope services. (NIST SP 800-171 Rev. 3)

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

1) Define the “CUI flaw remediation scope”

Create and maintain an inventory of in-scope assets and services that touch CUI, then map each to an owner and patch/remediation method (endpoint management, cloud policy, IaC pipeline, MDM, etc.). If you cannot enumerate assets, you cannot credibly claim flaws are remediated. (NIST SP 800-171 Rev. 3)

Deliverable: CUI asset/service list with owners and remediation channels. (NIST SP 800-171 Rev. 3)

2) Establish flaw intake sources and a single tracking system

You need one place where flaws become work:

• Vulnerability scanner findings
• Patch/vendor advisories
• Configuration baselines/drift detection
• Pen test reports and security assessments
• Incident/post-incident findings
• Third-party notices affecting your environment (including embedded components) (NIST SP 800-171 Rev. 3)

Operational rule: If it is not in the tracker, it is not real for audit purposes.

Deliverable: Centralized vulnerability/remediation backlog (ticketing system, GRC issue register, or integrated platform). (NIST SP 800-171 Rev. 3)

3) Triage and prioritize with documented rationale

Create triage criteria your team can apply consistently:

• Affected CUI boundary or supporting services
• Known exploit activity (if available through your intel sources)
• Exposure (internet-facing, privileged path, lateral movement risk)
• Asset criticality (mission impact, CUI concentration)
• Availability constraints (maintenance windows) (NIST SP 800-171 Rev. 3)

Evidence angle: Auditors expect to see why one flaw was fixed before another. A consistent rubric beats ad hoc reasoning.

Deliverable: Documented severity/prioritization rules and sample triage records showing application. (NIST SP 800-171 Rev. 3)

4) Assign remediation actions and deadlines (even if you don’t publish “SLA days”)

Each flaw should have:

• Clear owner (person/team)
• Planned remediation method (patch, config change, version upgrade, compensating control)
• Target completion date
• Dependencies (downtime, vendor release, change advisory board) (NIST SP 800-171 Rev. 3)

If you choose to implement internal timelines by severity, treat them as policy commitments and enforce them. If you cannot enforce fixed timelines, set dates case-by-case and document why.

Deliverable: Tickets or work items with ownership and due dates. (NIST SP 800-171 Rev. 3)

5) Control the change (so remediation doesn’t create new risk)

Route remediation through your change process appropriate to the environment:

• Emergency change path for high-risk flaws
• Standard change approvals for routine patch cycles
• Testing expectations for critical apps
• Rollback plans for high-impact changes (NIST SP 800-171 Rev. 3)

Deliverable: Change records tied to flaw tickets. (NIST SP 800-171 Rev. 3)

6) Verify remediation and close the loop

Closure needs validation. Examples:

• Rescan shows vulnerability no longer present
• Configuration check proves setting is corrected
• Package/version evidence confirms upgrade applied
• Compensating control test results (e.g., rule in place, segmentation verified) (NIST SP 800-171 Rev. 3)

Deliverable: Verification evidence attached to each closed flaw. (NIST SP 800-171 Rev. 3)

7) Manage exceptions with time-bound governance

If you can’t remediate:

• Document why (technical infeasibility, vendor no patch, operational constraint)
• Implement compensating controls
• Obtain risk acceptance approval from an authorized leader
• Set an expiration/review trigger and track to closure (NIST SP 800-171 Rev. 3)

Deliverable: Exception register entries mapped to specific flaw IDs and affected assets, with approvals and review dates. (NIST SP 800-171 Rev. 3)

8) Extend the process to third parties in your CUI boundary

Contractually require third parties to:

• Notify you of relevant flaws
• Provide remediation status
• Provide evidence on request (attestations, patch reports, change records)
• Support your assessment timelines (NIST SP 800-171 Rev. 3)

Deliverable: Contract/security addendum language, third-party remediation attestations, and issue tracking for third-party findings. (NIST SP 800-171 Rev. 3)

Where Daydream fits: Daydream helps you map 03.14.01 to a clear control statement, assign owners, and automate recurring evidence collection so your “proof of remediation” is ready without manual scramble. (NIST SP 800-171 Rev. 3)

Required evidence and artifacts to retain

Use this as your audit evidence checklist for the 03.14.01: flaw remediation requirement:

Evidence type	What “good” looks like	Where it usually lives
Asset scope for CUI boundary	Inventory of in-scope assets/services with owners	CMDB, cloud inventory, GRC scope doc
Flaw intake records	Scanner outputs, advisories, pen test findings ingested into tracking	Vuln scanner, ticketing system
Triage/prioritization	Documented rules + examples of applied decisions	SOP + ticket fields/comments
Remediation work items	Owner, plan, target date, status	Tickets/boards
Change control linkage	Approved changes tied to remediation	ITSM/Change tool
Verification/closure proof	Rescan results or config/patch evidence attached to ticket	Scanner + ticket attachments
Exception governance	Risk acceptance with compensating controls and review cadence	GRC exception register
Third-party remediation evidence	Attestations/reports and your tracking	VRM/GRC + contract repository

All artifacts should be retained in a way that an assessor can trace from “finding” to “fix” for a sample of items across time. (NIST SP 800-171 Rev. 3)

Common exam/audit questions and hangups

Assessors and internal auditors tend to focus on these points for the 03.14.01: flaw remediation requirement:

1. Scope completeness: “Show me every asset in the CUI boundary and how you know it’s covered by scanning and patching.” (NIST SP 800-171 Rev. 3)
2. Repeatability: “Is this process documented and followed, or does it depend on a few people?” (NIST SP 800-171 Rev. 3)
3. Timeliness logic: “How do you decide what gets fixed first, and how do you handle overdue items?” (NIST SP 800-171 Rev. 3)
4. Verification: “How do you confirm the flaw is actually remediated?” (NIST SP 800-171 Rev. 3)
5. Exceptions: “Who can accept risk, and how do you prevent exceptions from becoming permanent?” (NIST SP 800-171 Rev. 3)
6. Third parties: “If a third party hosts or supports CUI systems, how do you know they remediate flaws?” (NIST SP 800-171 Rev. 3)

Frequent implementation mistakes (and how to avoid them)

1. Mistake: Treating scanning reports as remediation proof.
   Fix: Require ticket closure to include validation evidence (rescan/config check) tied to the same flaw record. (NIST SP 800-171 Rev. 3)

2. Mistake: No defined CUI boundary inventory.
   Fix: Start with a “minimum viable inventory” for CUI workflows, then harden it into CMDB governance. (NIST SP 800-171 Rev. 3)

3. Mistake: “We patch monthly” with no exception discipline.
   Fix: Track high-risk items separately with an emergency path and documented approvals for deferrals. (NIST SP 800-171 Rev. 3)

4. Mistake: Exceptions approved in email with no expiration.
   Fix: Centralize exceptions, require compensating controls, require re-approval on a set schedule, and link each exception to specific assets and flaw IDs. (NIST SP 800-171 Rev. 3)

5. Mistake: Third-party remediation assumed, not verified.
   Fix: Add contract language and request periodic remediation evidence for in-scope services; track third-party findings like internal findings. (NIST SP 800-171 Rev. 3)

Risk implications (why operators get burned)

Unremediated flaws create predictable paths to CUI compromise: privilege escalation, lateral movement, and data exfiltration. For compliance, the immediate failure mode is simpler: during an assessment, you cannot show closed-loop operation or you cannot prove remediation occurred for sampled flaws. That becomes a gap even if your team “generally patches.” (NIST SP 800-171 Rev. 3)

Practical 30/60/90-day execution plan

First 30 days: Stand up the minimum auditable workflow

• Define CUI boundary scope and assign system owners. (NIST SP 800-171 Rev. 3)
• Pick the single tracking system and standard ticket fields (asset, flaw ID, severity, owner, due date, validation evidence). (NIST SP 800-171 Rev. 3)
• Document triage rules and exception approval authority. (NIST SP 800-171 Rev. 3)
• Run one end-to-end cycle on a small set of representative assets and capture evidence. (NIST SP 800-171 Rev. 3)

Next 60 days: Expand coverage and tighten governance

• Extend scanning and intake across the full CUI boundary; validate you are not missing asset classes (cloud, network, endpoints, SaaS configurations). (NIST SP 800-171 Rev. 3)
• Create dashboards for open flaws, overdue items, and exceptions; review them in a recurring forum with IT and security owners. (NIST SP 800-171 Rev. 3)
• Formalize change-control linkage and verification requirements for closure. (NIST SP 800-171 Rev. 3)
• Add third-party remediation expectations for in-scope providers and start collecting attestations or reports. (NIST SP 800-171 Rev. 3)

By 90 days: Prove ongoing operation (assessment-ready)

• Demonstrate trendable evidence: multiple remediation cycles with closure proof, plus exceptions that are reviewed and expiring. (NIST SP 800-171 Rev. 3)
• Run an internal mini-assessment: sample findings from different months and trace “finding → ticket → change → validation → closure.” (NIST SP 800-171 Rev. 3)
• Move evidence collection to a recurring cadence. Daydream can reduce manual effort by mapping the requirement to control owners and pulling routine artifacts into an audit-ready package. (NIST SP 800-171 Rev. 3)

Frequently Asked Questions

What counts as a “flaw” for 03.14.01?

Treat any security-relevant defect or weakness that could impact confidentiality, integrity, or availability in the CUI boundary as a flaw, including missing patches and vulnerable configurations. Track it through remediation or documented exception. (NIST SP 800-171 Rev. 3)

Do we need vulnerability scanning to satisfy the 03.14.01: flaw remediation requirement?

The requirement focuses on remediation, but you still need a reliable way to discover flaws or receive flaw information. Scanning is a common control, but advisories, assessments, and configuration monitoring also feed the intake process. (NIST SP 800-171 Rev. 3)

What if a patch doesn’t exist yet?

Open an exception tied to the specific flaw and affected assets, document compensating controls, and require periodic re-evaluation until a patch or upgrade path exists. Keep the approval and review trail. (NIST SP 800-171 Rev. 3)

How do we show “verification” to an assessor?

Attach evidence that the flaw condition no longer exists, such as a clean rescan result, a configuration compliance report, or version evidence. The key is traceability from the original finding to the validating proof. (NIST SP 800-171 Rev. 3)

How should we handle flaws in third-party services that process CUI?

Put contractual obligations in place for notification and remediation evidence, and track third-party findings in the same workflow as internal findings. You remain accountable for the requirement, even if the third party performs the fix. (NIST SP 800-171 Rev. 3)

What’s the minimum evidence set to keep this from becoming a paperwork drill?

Keep the chain of custody for each sampled flaw: detection record, triage decision, remediation ticket with owner and date, change record if applicable, and validation evidence. A small set of complete records is more defensible than many partial ones. (NIST SP 800-171 Rev. 3)