CM-1: Policy and Procedures

To meet the cm-1: policy and procedures requirement, you must create, approve, and distribute a configuration management (CM) policy and supporting procedures to the right audiences, then keep them current and provably followed. Operationalize CM-1 by assigning an owner, mapping procedures to the CM control set, and collecting recurring evidence that staff can execute CM consistently. ¹

Key takeaways:

• CM-1 is a documentation-and-dissemination control: auditors expect written policy, working procedures, and proof people received and follow them.
• “Done” means governed: named owners, approval records, version control, and a refresh cadence tied to system and risk changes.
• Build an evidence map early (owner → procedure → artifacts) so CM-1 doesn’t fail for “missing proof.” ²

CM-1 sits in the Configuration Management family of NIST SP 800-53 Rev. 5 and acts as the anchor for everything else you do in CM. If you cannot show a documented policy, documented procedures, and dissemination to the right stakeholders, assessors commonly treat the rest of your CM controls as fragile because your program lacks governance. CM-1 is also one of the fastest controls to “paper pass” and still fail in an exam: teams produce a policy PDF but cannot show who owns it, what procedures implement it, where exceptions are approved, and what evidence proves the procedures actually run.

For a CCO, Compliance Officer, or GRC lead, the fastest path is to treat CM-1 as a requirement to build an operating system for CM documentation: a single authoritative policy, a small set of role-based procedures, and an evidence plan that generates artifacts during normal work (change tickets, baselines, approvals, communications). If you track third parties that manage infrastructure or deploy code, CM-1 also becomes the place where you clarify what parts of CM are outsourced and what evidence you still must retain.

Daydream (used well) helps by turning CM-1 into a mapped control record with a named owner, linked procedures, and a recurring evidence checklist you can assign and collect on schedule.

Regulatory text

Requirement excerpt: “Develop, document, and disseminate to {{ insert: param, cm-1_prm_1 }}:” ²

What the operator must do with that text

CM-1 is telling you to do three things, and all three must be verifiable:

1. Develop: Decide what your organization’s CM program requires (scope, roles, approvals, enforcement points).
2. Document: Write it down as a policy and as step-by-step procedures people can follow.
3. Disseminate: Deliver those documents to the defined audience (typically: system owners, admins, engineers, change managers, security, and any third party operators), then keep proof you did so.

The “{{ insert: param, cm-1_prm_1 }}” placeholder in the OSCAL excerpt signals that the control expects you to specify who receives the policy and procedures in your implementation. Your job is to name that audience in your CM documentation and show dissemination records. ²

Plain-English interpretation (what CM-1 really demands)

CM-1 requires a CM policy that sets mandatory rules and a set of CM procedures that convert those rules into repeatable actions. Assessors will look for consistency: what the policy says should match what the procedures instruct, and both should match what happens in tickets, repos, and tooling.

Think of CM-1 as the “constitution” and “playbooks” for:

• how you control configuration changes,
• how you define and protect baselines,
• how you track and approve deviations,
• how you document responsibilities across internal teams and third parties.

If your policy and procedures are generic templates with no ties to your systems, roles, tools, or approval paths, CM-1 will be treated as weak even if the document exists.

Who it applies to (entity and operational context)

CM-1 applies anywhere you claim alignment to NIST SP 800-53 Rev. 5, especially in:

• Federal information systems, and
• Contractor systems handling federal data ²

Operationally, CM-1 applies to:

• engineering and IT operations teams that implement changes,
• security teams that set CM guardrails and review high-risk changes,
• GRC teams that govern the documentation, exceptions, and evidence,
• third parties that administer, host, develop, or deploy your systems (you still own the requirement, even if execution is outsourced).

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

Use this sequence to operationalize the cm-1: policy and procedures requirement quickly and in an audit-ready way.

Step 1: Assign ownership and scope (write it down)

• Name a CM Policy Owner (accountable) and Procedure Owners (responsible by domain: infrastructure, application, endpoint, network, cloud).
• Define scope: which environments and system types are covered (production, corporate IT, lab, regulated enclaves).
• Define which third parties are in-scope and what CM evidence they must provide to you.

Practical tip: If you can’t name procedure owners, your procedures won’t stay current. Auditors interpret stale procedures as “not implemented.”

Step 2: Draft the CM policy (what must be true)

Your CM policy should state, in mandatory language (“must”), at minimum:

• the purpose and scope of CM;
• roles and responsibilities (RACI-style);
• what constitutes a configuration item (CI) and what must be controlled;
• baseline expectations (what is baselined, where stored, who approves changes);
• change authorization requirements (standard vs. normal vs. emergency changes);
• exception handling (how deviations are requested, approved, time-bounded, and reviewed);
• record retention expectations for CM artifacts.

Keep it short enough that operators will read it, but specific enough that it constrains behavior.

Step 3: Write procedures that match how work actually happens

Procedures are the “how,” and they must map to your tools. Write separate procedures when processes differ materially:

• Change control procedure (ticketing workflow, approvals, testing evidence, rollback plans).
• Baseline management procedure (creating, storing, reviewing baselines; handling drift).
• Configuration settings procedure (secure configuration standards references; how to implement and verify).
• Emergency change procedure (who can declare, required after-action review, retrospective approvals).
• Third-party operated change procedure (how vendor/third party changes are requested, approved, and evidenced).

Each procedure should include:

• triggers (what starts the process),
• required inputs,
• steps with responsible roles,
• required outputs/evidence,
• where records live (ticket system, CMDB, repo, cloud audit logs).

Step 4: Define the dissemination plan and make it provable

Dissemination must be auditable. Pick at least two mechanisms:

• policy portal with acknowledgment workflow,
• onboarding/training module assignment,
• change-management playbook embedded in engineering docs,
• targeted comms to privileged admin groups.

Then define who must receive it (the “cm-1_prm_1” audience in practice) and how you prove it (exportable acknowledgment report, training completion report, email distribution list archive). ²

Step 5: Map CM-1 to recurring evidence (avoid the “missing proof” failure)

Create a CM-1 evidence map: control → owner → procedure → artifacts → frequency/trigger → system of record. This aligns with the recommended practice to “map CM-1 to control owner, implementation procedure, and recurring evidence artifacts.” ²

Example artifact set (adapt to your environment):

• CM policy document with version history and approvals
• CM procedures with version history and approvals
• dissemination evidence (acknowledgment or training completion)
• samples of change tickets showing approvals, testing, and rollback notes
• baseline definitions and periodic review records
• exception register with approvals and expirations
• third-party change records and approval evidence (where applicable)

Daydream fits here as the system to register CM-1 ownership, attach procedures, and run recurring evidence tasks so collection does not rely on memory or heroics.

Step 6: Implement a review-and-update trigger model

CM-1 breaks when documents don’t match current operations. Set clear triggers for review:

• major platform/tooling changes (new CI/CD, new ticketing tool),
• material incidents tied to change or misconfiguration,
• onboarding a new third party operator,
• major system boundary or authorization changes.

Use lightweight versioning: change log entry, approver, effective date, and dissemination re-run when changes are material.

Required evidence and artifacts to retain (audit-ready list)

Retain these artifacts in a controlled repository with access controls and an audit trail:

Artifact	What auditors look for	Owner
CM Policy (approved)	Scope, roles, mandatory requirements, approval signature/record	CM Policy Owner
CM Procedures (approved)	Step-by-step actions tied to tools and records	Procedure Owners
Version history / change log	Proof documents are maintained and updated	GRC / Doc Owner
Dissemination records	Who received it, when, and acknowledgment evidence	GRC / Training Owner
Change record samples	Approvals, testing, implementation notes, rollback plan	Change Manager / Eng
Baseline records	What is baselined, review records, drift handling	System Owners
Exception register	Approvals, time bounds, compensating controls	Security / GRC
Third-party CM evidence	Proof the third party followed your CM expectations	TP Owner / Vendor Manager

Common exam/audit questions and hangups

Expect these questions and pre-build answers:

1. “Who is the defined audience for CM policy and procedures?”
   Hangup: you can’t point to a named list of roles/groups. Fix: embed the audience list in the policy and tie it to access groups.

2. “Show evidence dissemination occurred.”
   Hangup: “It’s on Confluence” is not evidence. Fix: keep exportable acknowledgments or training completion records.

3. “Show that procedures reflect current tooling.”
   Hangup: procedure references an old ticket workflow. Fix: require procedure updates as part of tool change projects.

4. “How do third parties follow your CM policy?”
   Hangup: contract says “follow best practices” but you can’t produce change records. Fix: define evidence deliverables in third-party SOWs and collect samples.

Frequent implementation mistakes (and how to avoid them)

• Mistake: Policy exists, procedures don’t.
  Avoidance: write at least one procedure per major CM workflow (change, baseline, exceptions).

• Mistake: Procedures are generic and untethered to systems.
  Avoidance: include system-of-record locations and screenshots/fields for ticket evidence.

• Mistake: No dissemination proof.
  Avoidance: route policy through an acknowledgment system and store reports.

• Mistake: CM is “owned by security” but executed by engineering with no buy-in.
  Avoidance: make engineering owners responsible for procedures; security governs requirements and exceptions.

• Mistake: Third-party operated environments are ignored.
  Avoidance: treat third-party change evidence as a standing deliverable; sample it during reviews.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat CM-1 primarily as an assessment readiness and control reliability issue rather than a case-law-driven obligation.

Risk-wise, weak CM-1 increases the chance that technical CM controls (baselines, change approvals, configuration settings) fail in practice because teams make ad hoc changes and cannot reconstruct who approved what. Auditors also use CM-1 failures as a signal that the broader CM family may not be consistently governed. ¹

Practical 30/60/90-day execution plan

First 30 days (establish governance and drafts)

• Assign CM-1 owners (policy and procedures) and document scope.
• Inventory current CM touchpoints: ticketing, CI/CD, IaC repos, CMDB, cloud config tooling, endpoint management.
• Draft the CM policy and the minimum viable procedures (change control + emergency change).
• Stand up an evidence map (owner → procedure → artifacts) in Daydream or your GRC system of record.

Days 31–60 (publish, train, prove dissemination)

• Finalize approvals for policy and procedures; publish to the controlled repository.
• Run dissemination: acknowledgments and/or training assignments to the defined audience.
• Start collecting evidence samples from normal work (tickets, approvals, baselines).
• Add third-party CM expectations to active engagements where feasible (SOW addendum or operating procedure).

Days 61–90 (operational hardening)

• Validate procedures match actual workflows by walking real change tickets end-to-end.
• Implement an exception register and require time-bounded approvals for deviations.
• Run a mini internal assessment: can you produce the full CM-1 evidence packet within a day?
• Set review triggers and assign periodic control check tasks in Daydream to keep CM-1 from going stale.

Frequently Asked Questions

Who should be included in the CM-1 dissemination audience?

Include anyone who requests, approves, implements, or reviews changes, plus system owners and privileged administrators. Add third parties that operate or deploy into your environment, and document the list in the policy to make the “audience” auditable. ²

Can a single CM policy cover both corporate IT and production systems?

Yes, if the policy clearly defines scope and where procedures differ by environment. If workflows or approval thresholds differ materially, keep one policy and maintain separate procedures per environment to avoid conflicts in execution.

What counts as acceptable “dissemination evidence”?

Use records that show who received the documents and when, such as acknowledgment reports, training completion exports, or access-controlled policy portals with attestations. A static link without acknowledgment rarely satisfies assessors.

How do we handle CM-1 if a managed service provider performs most changes?

Keep your CM policy and procedures, then require the third party to follow your change expectations and provide change records on request. Make evidence delivery explicit in the SOW and test it by sampling real change tickets during reviews.

How detailed should CM procedures be?

Detailed enough that a new team member can follow them using your current tools, including required ticket fields and approval steps. If the procedure can’t produce consistent artifacts, it will fail under audit pressure.

What is the fastest way to prevent CM-1 from becoming shelfware?

Bind procedures to operational systems of record (ticketing, repos, CI/CD) and schedule evidence collection tasks. Daydream helps by assigning owners and recurring evidence requests so you can demonstrate ongoing operation without scrambling.

Footnotes

1. NIST SP 800-53 Rev. 5

2. NIST SP 800-53 Rev. 5 OSCAL JSON