03.17.02: Acquisition Strategies, Tools, and Methods

To meet the 03.17.02: acquisition strategies, tools, and methods requirement, you must build acquisition and procurement practices that consistently select, configure, and manage products and services in ways that protect CUI across the system lifecycle. Operationally, that means embedding security requirements into purchase decisions, validating what you buy, and retaining evidence that acquisition choices support NIST SP 800-171 controls ¹.

Key takeaways:

• Treat procurement as a security control: bake CUI and NIST SP 800-171 needs into sourcing, contracting, and onboarding ¹.
• Standardize tools and methods (templates, checklists, gates) so buying decisions are repeatable and auditable ¹.
• Evidence matters as much as intent: keep artifacts that show what was required, evaluated, approved, and verified ¹.

03.17.02 sits in the “System and Services Acquisition” family of NIST SP 800-171 Rev. 3 and targets a common failure mode: security teams document great controls, but procurement keeps buying tools, services, and components that undermine those controls. For CCOs and GRC leads supporting federal contractors and other nonfederal organizations that handle CUI, this requirement is where governance meets spending authority. If you cannot show that acquisition decisions follow defined strategies, use consistent tools/methods, and drive security outcomes, assessors will treat your program as aspirational instead of operating.

This page focuses on fast operationalization. You will translate 03.17.02 into: (1) an acquisition security standard that procurement can execute, (2) intake and approval workflows that create reliable evidence, and (3) a small set of “gates” that stop high-risk purchases until security conditions are met. You will also see what artifacts to retain, how auditors typically probe this control, and how to avoid the trap of “policy-only compliance” ¹.

Regulatory text

Excerpt (as provided): “NIST SP 800-171 Rev. 3 requirement 03.17.02 (Acquisition Strategies, Tools, and Methods).” ¹

What the operator must do

You must define and use acquisition strategies, tools, and methods that support secure acquisition of systems, system components, and services used in environments that process, store, or transmit CUI. In practice, an assessor will look for a repeatable procurement-to-security workflow: documented criteria, consistent evaluation steps, and records showing you applied them to real purchases ¹.

Plain-English interpretation

03.17.02 requires you to make buying decisions in a controlled, security-aware way. “Strategies” are your rules of the road (what you require and why). “Tools and methods” are the operational mechanisms that force consistency (intake forms, due diligence checklists, standard contract language, approval gates, and tracking). If you can buy a cloud service, agent, or outsourced IT function that touches CUI without security review and documented conditions, you are not meeting the intent ¹.

Who it applies to

Entity scope

• Federal contractors and subcontractors operating nonfederal systems that handle CUI ¹.
• Any organization implementing NIST SP 800-171 Rev. 3 as a contractual requirement for CUI protection ¹.

Operational scope (where it shows up)

• Procurement and sourcing (new purchases, renewals, and expansions).
• IT and security architecture review for new technologies.
• Third-party onboarding for services that can access CUI (managed service providers, SaaS platforms, consultants).
• Asset management and configuration baselines (standard builds, approved product lists).
• M&A or rapid onboarding of new business units where inherited tools appear in the environment.

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

Step 1: Define your “CUI-relevant acquisition scope”

Create a written scope statement that says which purchases trigger the 03.17.02 process. At minimum, include:

• Any system/service that stores, processes, or transmits CUI.
• Any third party with administrative access to CUI systems.
• Any component that becomes part of the CUI boundary (identity provider, endpoint agent, backup, logging, EDR, ticketing integrated with CUI data).

Deliverable: Acquisition Security Standard (CUI Scope) aligned to NIST SP 800-171 ¹.

Step 2: Establish acquisition “strategies” as decision rules

Write decision rules procurement can apply without guessing. Common strategies include:

• Approved product/service categories for CUI environments (for example: identity, endpoint, email, remote access).
• Minimum security requirements per category (encryption expectations, access control expectations, logging and retention expectations, vulnerability management expectations).
• Prohibited patterns (for example: unmanaged remote admin tools in the CUI boundary unless explicitly approved).
• Contract requirements for third parties (security obligations, breach notification, access controls, data handling).

Deliverable: Security requirements catalog for acquisition mapped to internal controls and to your CUI boundary definition ¹.

Step 3: Build “tools and methods” that enforce consistency

Implement practical mechanisms that create audit-ready evidence:

• Security intake questionnaire embedded in procurement intake.
• Architecture/security review checklist for systems entering the CUI boundary.
• Standard contractual addendum for CUI-touching third parties.
• Approval workflow with required sign-offs (procurement, security, system owner, legal where needed).
• Exception workflow with time-bound compensating controls and senior approval.

If you use Daydream, configure the requirement record for 03.17.02: acquisition strategies, tools, and methods requirement with a control statement, ownership, and recurring evidence requests so you can produce a consistent evidence packet on demand ¹.

Deliverable: Procurement-to-security workflow diagrams and templates that are actually used.

Step 4: Integrate the workflow into purchasing and change management

This requirement fails most often because security reviews happen “in email” or after signature. Put the gate early:

• Require a security review ticket before purchase order issuance for scoped items.
• Require a renewal review when scope or data access changes.
• Tie approvals to the CUI system boundary so teams know which purchases are in-scope.

Deliverable: Written procedure + system evidence (tickets, approvals, procurement records) ¹.

Step 5: Verify what you bought matches what was approved

Acquisition controls are incomplete if you do not confirm the deployed reality:

• Validate configuration against your baseline for CUI environments.
• Confirm third-party access paths and privileges match the approved design.
• Ensure logging/monitoring is on and retained per your program requirements.

Deliverable: Implementation verification records (configuration screenshots/exports, access reviews, onboarding checklists) ¹.

Step 6: Operationalize ongoing governance

Treat this as a living process:

• Maintain an approved technology list for CUI environments.
• Track exceptions and revisit them through governance.
• Update templates when NIST mappings or your environment changes.

Deliverable: Governance minutes, exception logs, and updated templates.

Required evidence and artifacts to retain

Keep evidence that proves the process exists and was followed:

Artifact	What it proves	Where it usually lives
Acquisition Security Standard (CUI scope)	Defined strategies and scope	GRC repository / policy library
Security requirements catalog (by product/service type)	Consistent evaluation criteria	GRC tool / wiki
Procurement intake form + completed examples	Method is used on real purchases	Procurement system / ticketing
Security review checklist + completed examples	Repeatable due diligence	Ticketing / architecture review records
Contract clauses / addendum templates + executed samples	Requirements flowed down to third parties	Contract repository
Approval workflow records	Governance and accountability	Ticketing + procurement approvals
Exception register + approvals	Controlled deviations	GRC register
Verification records (config, access, logging)	What was bought was securely deployed	CMDB, config management, screenshots/exports

Assessors usually accept redacted examples; do not remove the decision trail.

Common exam/audit questions and hangups

Expect questions like:

• “Show me how a new SaaS tool gets approved for CUI use. Where is the checklist and the last three completed reviews?” ¹
• “How do you ensure third-party contracts include CUI handling and security requirements?” ¹
• “What stops a business unit from buying a tool on a credit card and connecting it to the CUI environment?” ¹
• “How do you verify the purchased service was configured as reviewed?” ¹

Hangups:

• Evidence exists but is scattered across email threads.
• The organization has templates but cannot show consistent use.
• Renewals bypass security review even though scope expanded.

Frequent implementation mistakes and how to avoid them

1. Mistake: Policy-only control.
   Fix: require workflow records (tickets, approvals, completed checklists) for a sample of purchases and renewals ¹.

2. Mistake: Treating “third-party risk” as separate from acquisition.
   Fix: route third-party onboarding through the same acquisition gate when the third party touches CUI systems or data ¹.

3. Mistake: No defined CUI boundary for procurement decisions.
   Fix: publish what counts as “CUI-relevant acquisition,” and connect it to system inventory and architecture review ¹.

4. Mistake: No verification step.
   Fix: add a post-purchase implementation check that confirms access, logging, and configuration match the approved design ¹.

5. Mistake: Exceptions are informal and permanent.
   Fix: log exceptions with compensating controls and a re-approval trigger when conditions change.

Enforcement context and risk implications

No public enforcement cases were provided for this specific requirement in the supplied source catalog. Practically, the risk is contractual and operational: weak acquisition controls increase the chance that unmanaged tools, insecure third-party access, or misconfigured services enter the CUI boundary. Assessors may treat these as systemic control failures because acquisition affects multiple downstream controls (access control, audit logging, configuration management) ¹.

Practical execution plan (30/60/90)

You asked for speed. Use phases rather than day-count commitments.

First phase (Immediate)

• Name an owner: procurement + security joint accountability.
• Define in-scope purchase triggers tied to the CUI boundary.
• Publish the minimum acquisition security standard and the “stop/go” gate.

Second phase (Near-term)

• Deploy the intake form, checklist, and contract addendum templates.
• Train procurement and system owners on the workflow.
• Start collecting evidence on new purchases and renewals.

Third phase (Operationalize and scale)

• Build an approved technology list for CUI environments.
• Implement exception management with governance review.
• Centralize evidence collection in Daydream so 03.17.02 artifacts are requested and stored consistently ¹.

Frequently Asked Questions

Does 03.17.02 apply to renewals, or only new purchases?

Treat renewals as in-scope when the system is used in the CUI boundary or the third party has CUI access. Renewals often expand scope (features, integrations, data types), which is exactly what acquisition methods must control ¹.

What counts as “tools and methods” for this requirement?

Concrete mechanisms: intake forms, checklists, contract templates, approval workflows, exception logs, and tracking registers. Assessors want to see repeatable execution, not just narrative policy ¹.

We have decentralized purchasing. How can we pass an assessment?

Define mandatory gates for CUI-relevant purchases and route them through a central review workflow even if spend approval is local. The control objective is consistent security outcomes and evidence across the organization ¹.

Do we need a separate process for third-party onboarding versus technology acquisition?

You can keep different playbooks, but they must converge on the same security decision points for CUI access and CUI boundary inclusion. The assessor will follow the risk path, not your org chart ¹.

What evidence is strongest for 03.17.02?

Completed review packets for actual purchases: intake + checklist + approvals + contract terms (if applicable) + verification that the deployed configuration matches what was approved. Pick a sample that includes at least one third-party service with CUI access ¹.

How does Daydream help with this control without turning it into paperwork?

Use Daydream to map 03.17.02 to a single control owner, standard evidence requests, and a recurring collection schedule, then attach real procurement tickets and approval artifacts as they happen. That reduces the scramble when an assessment starts ¹.

Footnotes

1. NIST SP 800-171 Rev. 3