03.06.02: Incident Monitoring, Reporting, and Response Assistance

To meet the 03.06.02: incident monitoring, reporting, and response assistance requirement, you must actively monitor for security incidents affecting CUI systems, report incidents through defined internal and external channels, and provide concrete response assistance (people, process, and technical support) so incidents are contained, investigated, and resolved. Your goal is repeatable execution with provable evidence aligned to NIST SP 800-171 Rev. 3.

Key takeaways:

• Build a single incident workflow that ties monitoring → triage → reporting → response assistance to CUI scope.
• Define “who reports what, to whom, and when” in writing, then test it with realistic exercises.
• Retain evidence that the process ran: alerts, tickets, timelines, notifications, and after-action improvements.

03.06.02 sits in the incident response family of NIST SP 800-171 Rev. 3 and is assessed like an operational control, not a policy checkbox. Assessors and customers expect you to show that you can (1) detect potential incidents in the environment that processes, stores, or transmits CUI, (2) escalate and report them through defined paths, and (3) materially assist response activities until closure. The “assistance” language is where many programs fail: you need more than a phone tree and an outsourced SOC statement. You need clear accountabilities, access to the right logs and tools, and a practiced method for supporting forensics, containment, eradication, recovery, and lessons learned.

This page translates the 03.06.02: incident monitoring, reporting, and response assistance requirement into an operator-ready implementation plan: who owns each step, what to document, how to structure evidence, and how to avoid common audit traps. It also covers practical realities in federal contracting environments (MSPs, SaaS platforms, and multiple enclaves) where incident detection and response are shared responsibilities and gaps often appear at the seams. Primary source: NIST SP 800-171 Rev. 3.

Regulatory text

Requirement excerpt: “NIST SP 800-171 Rev. 3 requirement 03.06.02 (Incident Monitoring, Reporting, and Response Assistance).” (NIST SP 800-171 Rev. 3)

Operator meaning (what you must do):

• Monitor your CUI environment for indicators of a security incident (not just outages).
• Report suspected or confirmed incidents through documented internal escalation and any required external notifications (contractual/customer/regulatory, as applicable to your contracts).
• Assist response by providing the operational support needed to contain, investigate, and remediate incidents, including coordination with third parties that provide security operations, IT operations, cloud hosting, or application support.

Practical test: If an assessor asks, “Show me the last time you detected a suspicious event in the CUI enclave and what you did next,” you should be able to produce a complete timeline with artifacts.

Plain-English interpretation of the requirement

03.06.02 expects an end-to-end incident capability that works under pressure:

1. Monitoring: You have coverage (logs, alerts, and human review) across endpoints, identity, network, cloud, and key applications in scope for CUI.
2. Reporting: You don’t rely on informal chats. You have clear triggers, severity definitions, and notification paths.
3. Response assistance: The organization can actually help resolve the incident. That includes providing logs, isolating hosts, disabling accounts, preserving evidence, coordinating with an MSP/MSSP, and supporting root-cause and corrective actions.

This is a “prove it” requirement. A policy alone rarely passes.

Who it applies to (entity and operational context)

Applies to:

• Federal contractors and subcontractors operating nonfederal systems that handle CUI. (NIST SP 800-171 Rev. 3)
• Any business unit, enclave, application, or network segment designated as the CUI environment (including hybrid and cloud components).

Operational contexts where scoping fails:

• CUI lives in M365/Google Workspace, a ticketing tool, or an engineering SaaS platform, but monitoring is limited to on-prem logs.
• An MSP/MSSP “monitors,” but you cannot show alert review, escalation criteria, or that you can retrieve logs quickly.
• Development and build systems touch CUI artifacts, but IR procedures cover only corporate endpoints.

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

1) Define CUI incident scope and severity

• Identify which systems are in the CUI boundary (systems, identities, networks, cloud tenants, critical SaaS).
• Define what counts as an incident for your environment (examples: suspected credential compromise, malware detection on a CUI endpoint, anomalous access to CUI repositories, unauthorized data transfer, integrity violation).
• Create a severity model that maps to actions (who gets paged, who approves containment steps, when legal/customer engagement starts).

Deliverable: CUI incident classification matrix (1 page is fine) linked to your incident response procedure.

2) Establish monitoring coverage and alert ownership

• Inventory log sources for the CUI boundary: identity provider, endpoints, EDR, VPN/ZTNA, email security, cloud audit logs, firewalls, key applications, and privileged access tooling.
• Document which alerts are enabled and who reviews them.
• Set up a daily review routine (even if outsourced) with a clear escalation path into your ticketing/IR platform.

Deliverables: logging/telemetry map + alert list + “alert-to-ticket” workflow.

3) Implement the reporting workflow (internal and external)

• Write a short internal reporting runbook:
  • How staff report suspicious activity (security@, hotline, ticket type, on-call number).
  • Triage steps and required fields (who/what/when/where, systems affected, CUI involvement, initial containment).
• Define external reporting triggers based on contracts and customer requirements. Keep this in a contract obligations register tied to your incident plan.

Deliverables: incident reporting SOP + notification matrix (internal roles, customer contacts, third-party contacts).

4) Define “response assistance” as concrete capabilities

Spell out what your org will do during incident response. Minimum coverage:

• Containment actions: isolate endpoints, disable accounts, revoke tokens/keys, block IOCs, suspend integrations.
• Evidence preservation: log retention, snapshots, chain-of-custody steps, protected storage for artifacts.
• Investigation support: log retrieval, endpoint triage, cloud audit queries, correlation support from SIEM/MDR.
• Coordination: clear handoffs among IT, security, cloud ops, app owners, and third parties (MSSP, IR firm, hosting provider).

Deliverable: RACI for incident response assistance tasks.

5) Test the workflow and capture evidence

• Run a tabletop exercise that includes CUI systems, a third-party dependency, and an external notification decision.
• Run at least one technical test of evidence collection (pull endpoint triage package, export cloud audit logs, capture firewall events).
• Track corrective actions to closure.

Deliverables: exercise plan, attendance, scenario, results, corrective action log.

6) Operationalize ongoing control operation and evidence collection

• Set a recurring cadence to review:
  • monitoring coverage changes (new SaaS, new network segment, new identity flows)
  • alert tuning outcomes and missed detections
  • incident trends and closure quality
• Keep evidence organized by incident and by period for assessment readiness.

How Daydream fits without adding process drag: teams commonly use Daydream to map 03.06.02 to owned controls, assign operators, and collect recurring evidence (alerts, tickets, exercises, and post-incident reviews) in one place so assessments don’t turn into a scavenger hunt.

Required evidence and artifacts to retain

Keep artifacts that prove monitoring, reporting, and assistance happened in practice:

Monitoring

• Log source inventory for CUI boundary
• SIEM/MDR onboarding proof (screenshots, config exports, or service tickets)
• Sample alerts and analyst notes showing review/triage
• Monitoring SOP and on-call schedule

Reporting

• Incident intake form/template and completed examples (sanitized)
• Escalation matrix and contact lists (with review dates)
• Copies of notifications (internal emails, customer notifications) with timestamps

Response assistance

• Incident tickets with timeline, containment steps, and approvals
• Forensic/evidence collection records (exports, hashes where applicable, chain-of-custody if used)
• Post-incident report with root cause and corrective actions
• Proof of third-party coordination (MSSP case notes, hosting provider tickets)

Common exam/audit questions and hangups

Expect questions like:

• “Show monitoring coverage for all in-scope CUI systems.” Hangup: you show a tool list, not a scoped telemetry map.
• “Walk me through your last incident from detection to closure.” Hangup: no timestamps, no decision record, no containment evidence.
• “How do you ensure third parties assist with response?” Hangup: contracts lack incident cooperation language, or you can’t show a tested escalation path.
• “How do you decide when to notify a customer?” Hangup: notification criteria exist only in someone’s head.

Frequent implementation mistakes and how to avoid them

• Mistake: treating ‘monitoring’ as ‘we have antivirus.’
  Fix: document log sources, alert rules, and review ownership for the CUI boundary.
• Mistake: MDR/SOC is outsourced, so you assume compliance transfers.
  Fix: require alert review records, escalation SLAs, and evidence access in the SOW; test retrieval during an exercise.
• Mistake: response plan exists, but IT can’t execute containment fast.
  Fix: pre-authorize containment actions by severity and define who can disable accounts, quarantine endpoints, and revoke sessions.
• Mistake: no evidence retention strategy.
  Fix: create an incident evidence checklist and store artifacts in a controlled repository tied to each ticket.

Enforcement context and risk implications

Public enforcement case references were not provided in the source catalog for this requirement, so this page does not list specific cases. Practically, failures in monitoring and reporting increase customer impact, contractual breach risk, and the chance that an incident becomes a reportable event without a defensible timeline. Under NIST SP 800-171 Rev. 3, assessors commonly treat missing operational evidence as a control failure even if policies are well-written. (NIST SP 800-171 Rev. 3)

A practical execution plan (30/60/90)

Use phased execution without pretending every environment can change overnight.

First 30 days (stabilize and document)

• Confirm CUI boundary and systems list; identify monitoring gaps.
• Publish incident severity definitions and a one-page reporting/escalation matrix.
• Create a single incident ticket template with required fields and timestamps.
• Validate access: who can pull cloud audit logs, EDR telemetry, and identity logs on demand.

Days 31–60 (implement and integrate)

• Turn the telemetry map into real ingestion and alerting (SIEM/MDR), focused on CUI systems first.
• Put third-party response assistance into writing: escalation paths, evidence access, and cooperation expectations.
• Run a tabletop that forces an external notification decision and third-party coordination.

Days 61–90 (prove operation and readiness)

• Execute a technical evidence-collection drill and store artifacts in the incident record.
• Tune alerts based on false positives and missed detections; document changes.
• Produce an assessment-ready evidence packet: monitoring coverage, one completed incident example (sanitized), and exercise results with closed corrective actions.

Frequently Asked Questions

Does 03.06.02 require a SIEM?

NIST SP 800-171 Rev. 3 does not prescribe specific tools in the excerpt provided. You need demonstrable monitoring, reporting, and response assistance across the CUI boundary, and many teams use a SIEM or MDR to meet that operational need. (NIST SP 800-171 Rev. 3)

If we outsource monitoring to an MSSP, are we still responsible?

Yes. You still need to show defined reporting paths, response assistance tasks, and retained evidence that monitoring and escalation occurred for CUI systems. Contracts should support evidence access and timely coordination. (NIST SP 800-171 Rev. 3)

What counts as “response assistance” in practice?

Concrete actions: containment authority, log retrieval, evidence preservation, coordination with IT/app owners and third parties, and documented closure with corrective actions. If you cannot execute these steps quickly, the requirement is effectively unmet even if you have a plan. (NIST SP 800-171 Rev. 3)

How do we handle incidents that start outside the CUI enclave but may affect it?

Treat them as in-scope until you can prove they are isolated. Your triage should explicitly document whether CUI systems, identities, or repositories were touched and what evidence supports that conclusion. (NIST SP 800-171 Rev. 3)

What evidence is most persuasive to an assessor?

Time-stamped artifacts tied to a real workflow: alert or user report, ticket creation, triage notes, containment actions, notifications, and a post-incident report with corrective actions. Policies help, but operational records carry the assessment. (NIST SP 800-171 Rev. 3)

We haven’t had an incident. How do we show compliance?

Use exercised evidence: tabletop results, technical drills for log retrieval and containment actions, and monitoring review records that show analysts investigate alerts even when they are benign. Keep the artifacts as if they were incident records. (NIST SP 800-171 Rev. 3)