CP-7(4): Preparation for Use

CP-7(4): Preparation for Use requires you to ready your alternate processing site so it can actually run essential mission and business functions during a disruption, not just exist on paper. Operationalize it by defining what “ready” means for your services, preparing the facility and technical stack, and proving readiness through repeatable tests and evidence. ¹

Key takeaways:

• “Alternate site” must be operationally capable, with dependencies, access, and configurations in place, not a contracted address.
• Define readiness criteria tied to essential functions, then validate those criteria through exercises and technical testing.
• Keep assessor-ready artifacts: runbooks, inventories, access lists, test results, and issue remediation records mapped to CP-7(4).

CP-7(4): preparation for use requirement is one of the easiest continuity controls to “claim” and one of the easiest to fail in an assessment. Many organizations have an alternate processing site in name only: a cloud region they have not configured, a colocation contract without network paths, or a warm site missing identity, encryption keys, and operational access. CP-7(4) closes that gap by requiring that the alternate site be prepared to serve as the operational site for essential mission and business functions. ¹

For a Compliance Officer, CCO, or GRC lead, the fastest path to implementation is to treat CP-7(4) as an operational readiness requirement with measurable acceptance criteria. You should be able to answer, with evidence: which functions fail over, what the alternate site needs to run them, who can access it during an incident, and what proof shows it worked during a test. This page gives you a practical control-owner playbook: applicability, steps, artifacts, audit questions, common mistakes, and a phased execution plan you can assign and track.

Regulatory text

Text (excerpt): “Prepare the alternate processing site so that the site can serve as the operational site supporting essential mission and business functions.” ¹

What the operator must do:
You must make the alternate processing site “ready to run” the essential functions you depend on during disruption. “Ready” is an engineering and operations state: capacity exists, dependencies are reachable, security controls and access work, data and configurations are available, and staff can execute the cutover/failover procedures under stress.

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Plain-English interpretation (what CP-7(4) really asks)

CP-7(4) expects more than procurement and diagrams. You need a prepared alternate environment that can become your production environment (or sustain production-like operations) for pre-identified essential mission and business functions.

In practice, that means:

• The alternate site is provisioned to the required baseline (compute, network, storage, identity, monitoring).
• The essential systems can run there (applications, databases, queues, secrets, certificates, encryption keys, CI/CD and configuration management).
• Your people can access and operate it during an incident (accounts, MFA, break-glass, privileged access, on-call runbooks).
• You can show repeatable evidence that it works (tests, exercises, cutover validation, and remediation tracking).

This control pairs naturally with business impact analysis outputs and disaster recovery planning, but it stands on its own as “preparedness” rather than “planning.”

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Who it applies to (entity and operational context)

Entity types commonly in scope:

• Federal information systems and programs implementing NIST SP 800-53 controls. ²
• Contractor systems handling federal data where NIST SP 800-53 is required by contract, authorization boundary, or assessment scope. ²

Operational contexts where CP-7(4) is assessed hard:

• Systems supporting mission-essential services (public-facing services, identity, finance, case management, operational technology support systems).
• Environments with strict availability expectations, especially where downtime impacts safety, payments, regulated reporting, or critical customer workflows.
• Hybrid architectures where “alternate site” includes cloud regions plus on-prem dependencies (DNS, IAM, HSM/KMS, connectivity to third parties).

Typical control owners (you need named accountability):

• Business continuity / IT service continuity owner (program accountability).
• Infrastructure/Platform engineering (build and config).
• Network and IAM teams (connectivity and access).
• Application owners/SRE (service readiness and runbooks).
• Security operations (logging, monitoring, incident access).

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

Use this as an operator checklist you can assign in tickets.

1) Define “essential mission and business functions” in scope

• Confirm the list of essential functions and the services/systems that enable them.
• Identify which functions must operate from the alternate site versus which can be temporarily degraded or paused.
• Record the minimum service level required during disruption (qualitative is acceptable if your program does not define numeric targets).

Output: Essential functions-to-services mapping.

2) Declare alternate site readiness criteria (acceptance criteria)

Write criteria that an engineer can verify. Examples:

• Identity: administrators can authenticate with MFA; break-glass works; privileged roles are defined.
• Data: backups/replicas available; restore procedures validated; encryption keys accessible.
• Network: routing/DNS cutover steps documented; third-party connectivity paths validated.
• Ops: monitoring/alerts active; logs centralized; runbooks stored in a resilient location.

Output: CP-7(4) readiness criteria document, approved by system owner.

3) Build or configure the alternate processing site to the baseline

Depending on your architecture, “alternate site” can be:

• A second cloud region/account/subscription.
• A second data center/colo.
• A separate hosted environment provided by a third party.

Tasks to assign:

• Provision infrastructure to meet readiness criteria (IaC where possible).
• Establish secure network connectivity and segmentation.
• Deploy supporting services (directory/IAM integrations, KMS/HSM, patching, config management).
• Validate operational access paths for incident response and recovery staff.

Output: Baseline configuration and build records (change tickets, IaC repos, approved architecture diagrams).

4) Prepare the service stack (applications + dependencies)

Alternate site readiness fails most often due to dependencies:

• Licensing and activation services.
• Secrets/certificates rotation and distribution.
• External APIs and third-party allowlists.
• Batch jobs and schedulers.
• Data pipelines and downstream reporting.

Tasks to assign:

• Document dependencies per essential service.
• Pre-stage images, artifacts, and deployment pipelines.
• Confirm data replication/restore paths and permissions.
• Confirm critical third-party connections can operate from the alternate site (or document compensating procedures).

Output: Service dependency register and updated runbooks.

5) Validate readiness through tests and exercises

You need proof the site can serve as the operational site. Evidence usually comes from:

• Tabletop exercises (process validation).
• Technical recovery tests (restore, boot, deploy).
• Cutover/failover tests (partial or full, as feasible).

Define pass/fail criteria aligned to your readiness criteria. Track issues to remediation.

Output: Test plans, results, after-action reports, and remediation tickets.

6) Operationalize as a recurring control (keep it from drifting)

Preparedness decays as production changes. Add:

• A change-management trigger: material production changes require alternate site updates.
• A recurring review: confirm configs, access lists, contact rosters, and runbooks stay current.
• Ownership and escalation: a named person signs off on readiness status.

Output: Recurring control procedure and evidence calendar.

Practical tip: In Daydream, map CP-7(4) to a control owner, an implementation procedure, and a set of recurring evidence artifacts so the readiness story is consistent across audits and internal reporting. ¹

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Required evidence and artifacts to retain (assessor-ready)

Maintain a single “CP-7(4) evidence packet” per system boundary. Minimum artifacts:

Governance and scope

• Essential functions-to-services mapping
• Alternate processing site description and boundary diagram
• Readiness criteria / acceptance criteria approved by the system owner

Technical preparedness

• Architecture diagrams (production vs alternate)
• Build/configuration evidence (IaC references, change records, configuration baselines)
• Inventory of critical components prepared in alternate site (compute, storage, network, IAM, security tooling)
• Access control evidence (admin groups, break-glass procedure, MFA enforcement, privileged access approvals)

Operational readiness

• Recovery and cutover runbooks (who does what, in what order, with prerequisites)
• Dependency register (internal and third party dependencies)
• Monitoring/logging configuration evidence for the alternate site

Validation and maintenance

• Exercise/test plans and results
• After-action reports and remediation tracking (tickets, closure evidence)
• Review attestations that readiness remains current after major changes

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Common exam/audit questions and hangups

Assessors tend to probe for “paper site” risk. Expect questions like:

• “Show me evidence the alternate site can run your essential functions.” Bring test results, not only architecture.
• “What does ‘prepared’ mean here?” Point to explicit readiness criteria and who approved them.
• “How do you ensure the alternate site stays current?” Show your change trigger and recurring review records.
• “What dependencies break at the alternate site?” Produce the dependency register and documented workarounds.
• “Who can access the alternate site during an incident?” Provide access lists and break-glass evidence.

Hangups that create findings:

• Alternate site exists but lacks identity integration, monitoring, or key management.
• Tests cover backup restore but not operational cutover steps.
• Evidence scattered across teams with no control narrative tying it to CP-7(4).

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Frequent implementation mistakes (and how to avoid them)

1. Treating a contract as preparedness
   A colo or cloud region agreement is not readiness. Require proof: deployed baseline, access works, and services can start.

2. Ignoring third-party dependencies
   Your app may run, but payments, email, DNS, or allowlists fail. Maintain a dependency register and validate the top dependencies in tests.

3. No owner for “readiness drift”
   Preparedness erodes after releases and staff changes. Put a named owner on the hook for readiness sign-off and evidence refresh.

4. Runbooks that assume perfect conditions
   Recovery docs often assume VPN works, people are available, and credentials are accessible. Include break-glass paths and offline access to runbooks.

5. Testing that cannot fail
   Tabletops alone rarely prove CP-7(4). Pair them with technical validations that generate logs, screenshots, command outputs, and ticket trails.

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Enforcement context and risk implications

No public enforcement cases were provided in the source materials for this requirement, so you should frame risk in operational terms rather than penalty speculation.

Primary risk: inability to continue essential mission and business functions during a disruption because the alternate site is not truly operational. This can cascade into missed contractual commitments, operational downtime, incident response delays, and audit findings that affect authorization decisions in NIST-based programs. ²

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A practical 30/60/90-day execution plan

Use phased execution rather than calendar promises you cannot meet. Adjust scope based on system criticality and architecture complexity.

First 30 days (Immediate)

• Assign a control owner and technical owners for infrastructure, IAM, network, and top essential services.
• Produce essential functions-to-services mapping and alternate site scope statement.
• Draft readiness criteria with clear pass/fail checks.
• Inventory current state of alternate site against readiness criteria; open gaps as tracked remediation items.

Days 31–60 (Near-term)

• Close highest-risk gaps: identity access, networking, key management/secrets, monitoring/logging, and runbook availability.
• Build or update dependency register, including third parties and required allowlists.
• Run a tabletop plus a technical validation (restore/deploy/start critical components) and capture evidence.

Days 61–90 (Operationalize)

• Execute a more realistic recovery exercise that tests cutover steps for at least one essential function end-to-end.
• Document lessons learned and remediate remaining gaps with ticket closure evidence.
• Implement the recurring process: change triggers, review cadence, and evidence collection mapped to CP-7(4) for ongoing assessment readiness.

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Frequently Asked Questions

Does CP-7(4) require a full failover test to the alternate site?

CP-7(4) requires the site to be prepared to serve as the operational site for essential functions. ¹ You should validate preparedness with testing that produces objective evidence; the depth of testing should match your essential function scope and risk.

Can a second cloud region count as the alternate processing site?

Yes, if it is prepared to operate the essential functions, including identity, keys/secrets, network paths, monitoring, and runbooks. ¹ A “configured but unused” region can still fail if dependencies and access are not in place.

What’s the minimum evidence an assessor will accept for “prepared for use”?

Keep a readiness criteria document, proof the alternate site is built to that baseline, and test/exercise results showing the essential functions can run there. ¹ Evidence should be traceable to tickets, configs, and named owners.

How do we handle third-party services that can’t fail over with us?

Document the dependency, the impact during alternate-site operation, and the workaround or compensating procedure in your runbooks. Then validate the workaround during an exercise and retain the evidence.

Who should approve CP-7(4) readiness criteria and test outcomes?

The system owner (or service owner) should approve readiness criteria, and technical owners should attest to implementation and test results. Tie approvals to your change governance so the sign-off is repeatable.

How do we keep the alternate site from drifting out of date?

Add a change trigger so major production changes require an alternate-site update, then run recurring reviews with evidence capture. Store artifacts in a system that supports consistent mapping to CP-7(4), such as Daydream control records. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5