CP-8(2): Single Points of Failure

To meet the cp-8(2): single points of failure requirement, you must procure and configure alternate telecommunications services so your backup connectivity does not share the same physical, logical, or provider-level failure point as your primary connectivity ¹. Operationally, that means documenting telecom dependency paths, selecting truly diverse secondary services, and proving failover works under realistic outage scenarios.

Key takeaways:

• CP-8(2) is about telecom path diversity, not just “a second circuit.” ¹
• You must reduce shared failure domains across carrier, last-mile, POP, conduit, and routing.
• Auditors will look for evidence of diversity plus tested failover, not purchase orders alone.

CP-8(2) is a continuity and resilience requirement that focuses on a very specific failure mode: losing connectivity because your “backup” telecommunications service depends on the same underlying infrastructure as the primary. The control text is short, but the operational expectation is not. If both circuits ride the same conduit, terminate in the same central office, or depend on the same upstream provider relationship, you still have a single point of failure.

For a Compliance Officer, CCO, or GRC lead, the fastest path to operationalizing CP-8(2) is to treat it as a targeted engineering and third-party dependency exercise: map telecommunications dependencies, define what “alternate” must mean for your system’s availability needs, procure diverse services, and retain evidence that diversity is real and tested.

This page gives requirement-level implementation guidance you can hand to Network/Infrastructure, Cloud Ops, and Procurement. It also flags common audit hangups, the artifacts assessors usually request, and a practical execution plan you can run as a control owner.

Regulatory text

Requirement (excerpt): “Obtain alternate telecommunications services to reduce the likelihood of sharing a single point of failure with primary telecommunications services.” ¹

Operator meaning: You need alternate telecom service(s) that are credibly independent from your primary service’s failure domains. “Alternate” is not satisfied by a second contract that still rides the same last-mile plant, the same carrier core, the same building entry, or the same upstream peering path. The goal is risk reduction: a single outage event should not reasonably take out both primary and alternate connectivity ¹.

Plain-English interpretation

CP-8(2) requires telecommunications redundancy without common-mode failure. If a backhoe cut, carrier POP outage, regional fiber incident, misconfiguration by one provider, or a building entry fire can drop both “primary” and “backup,” you have not met the intent.

Think in terms of failure domains:

• Provider domain: same carrier or same parent/subsidiary network.
• Physical path domain: same conduit, pole route, building entry, riser, MDF/IDF, demarc room.
• Facility domain: same central office/POP, same meet-me room, same campus aggregation.
• Logical/routing domain: same BGP upstreams, same SD-WAN controller dependency, same DNS dependency if telecom authentication requires it.

Who it applies to

Entity scope

• Federal information systems and contractor systems handling federal data that have adopted NIST SP 800-53 Rev. 5 controls as system requirements ².
• Any organization using 800-53 as its control baseline for regulated customers (common for government contractors and critical service providers).

Operational context (where auditors expect CP-8(2))

Apply CP-8(2) anywhere loss of telecom would materially impact:

• User access to mission systems (VPN/ZTNA, VDI, SaaS access paths).
• Data center or colocation external connectivity.
• Cloud connectivity (Direct Connect/ExpressRoute-type connections, internet egress, SD-WAN hubs).
• Security dependencies (SIEM ingestion, EDR cloud connectivity, MFA/IdP reachability).
• Voice and emergency communications, if in system scope.

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

1) Assign ownership and define the “in scope” service boundary

• Name a control owner (often Network Engineering or Infrastructure) and a GRC accountable for evidence quality.
• List in-scope locations and services: HQ, data center, colos, critical branch sites, cloud connectivity components, and security service dependencies.
• Define what “telecommunications services” means for your environment: internet transit, private WAN, MPLS, SD-WAN underlay(s), carrier Ethernet, LTE/5G failover.

Deliverable: CP-8(2) control implementation statement tied to system boundary ².

2) Map the current telecom dependency chain (this is where most programs fail)

For each in-scope site/service, document:

• Primary provider, circuit type, bandwidth class (qualitative), demarc location.
• Last-mile path information from the carrier (request diversity letter / route statement where feasible).
• Building entry points (same entry or diverse entry).
• Intermediate facilities: POP/central office/meet-me room dependencies (if the provider will disclose).
• Internal single points: one edge router, one firewall pair, one power feed to demarc, one cross-connect panel.

Practical tip: Treat carriers and colocation providers as third parties with shared-infrastructure risk. Ask directly whether the alternate shares conduit, pole route, building entry, or local POP with the primary.

Deliverable: Telecom dependency map (diagram + table) showing failure domains.

3) Define “alternate” acceptance criteria (make it auditable)

Write criteria that Engineering and Procurement can execute against. Examples:

• Different provider (or at minimum different last-mile network operator).
• Diverse physical entry into the building (separate entry point and riser where possible).
• No shared local aggregation point where a single facility outage would drop both.
• Independent customer premises equipment (CPE) handoff paths to edge (separate ports, separate edge devices where required).
• Documented routing diversity (BGP multi-homing where applicable).

Deliverable: CP-8(2) telecom diversity standard (one page is fine) that can be attached to procurement requests.

4) Procure and implement alternate telecommunications services

Execution patterns that usually satisfy assessors if documented well:

• Dual-carrier internet with distinct demarc and diverse building entry.
• Fiber + fixed wireless or fiber + cellular where physical diversity is hard.
• Cloud connectivity: separate paths for private connectivity and public internet failover (with tested DNS and security policy handling).
• SD-WAN: two underlays from different providers, plus controller availability planning.

What to confirm before sign-off:

• The alternate circuit is installed, live, and monitored.
• Failover routing and security policies are configured (firewall rules, NAT, VPN, ZTNA, DNS).
• Monitoring alerts distinguish primary vs alternate path health.

Deliverable: Implementation records (change tickets, diagrams, monitoring config screenshots).

5) Test failover and document results as continuity evidence

Auditors commonly treat “we have two circuits” as incomplete unless you prove:

• The service actually fails over.
• Key applications remain reachable.
• Security monitoring still works (logs, EDR check-ins, MFA flows).
• The test includes a realistic failure mode (provider down, link down, misroute).

Run at least:

• A controlled primary link-down test at the edge.
• A DNS and application reachability check.
• A security telemetry check.

Deliverable: Failover test plan and test results with timestamps, observers, and issues/closures.

6) Operationalize: monitoring, vendor management, and recurring review

• Add both links to monitoring with alert thresholds and on-call runbooks.
• Track third-party/provider changes that can reintroduce shared failure (carrier acquisitions, route changes, colo cross-connect moves).
• Review telecom diversity whenever you add a new site, new cloud region, or major routing/security change.

Deliverable: Recurring control operation cadence (review checklist + evidence schedule).

Required evidence and artifacts to retain

Assessors want artifacts that show design, implementation, and operation:

Evidence type	What “good” looks like	Owner
Telecom diversity standard	Written criteria for “alternate telecom” and prohibited shared dependencies	GRC + Network
Network/telecom diagrams	Primary and alternate paths, demarc points, building entry, edge devices	Network
Provider documentation	Diversity letter/route statement, service order summaries, demarc details (as available)	Procurement/Network
Contracts/SOWs	Alternate service scope, SLAs where relevant, termination points	Procurement
Change records	Implementation and routing/security changes for failover	Network/SecOps
Monitoring configs	Alerts for both links, dashboards, incident runbooks	NOC/SRE
Failover test results	Test steps, evidence (screenshots/logs), remediation tracking	Network/SRE

Tie these artifacts to the control statement so an auditor can trace requirement → implementation → proof ¹.

Common exam/audit questions and hangups

1. “How do you know the alternate doesn’t share a single point of failure?” Expect scrutiny of last-mile and building entry diversity. Provide provider statements and diagrams.
2. “Show me a failover test.” Many teams have never failed over intentionally. Produce a dated test record and follow-up remediation.
3. “Is the alternate path sized and permitted for production traffic?” If firewall policies or bandwidth caps make failover unusable, document compensating controls or fix it.
4. “What about cloud dependencies?” If your telecom outage breaks IdP/MFA/DNS, you can lose access even with a second circuit. Show you tested end-to-end flows.
5. “Who reviews this and how often?” Have a named owner and an operations cadence.

Frequent implementation mistakes and how to avoid them

• Mistake: Two circuits from the same carrier brand family. Fix: require proof of independent last-mile operator or contract with a distinct provider.
• Mistake: Diverse providers, same conduit into the building. Fix: add a second building entry, or use wireless for physical diversity.
• Mistake: Redundant telecom, single edge device. Fix: confirm edge device redundancy (or document why it is out of scope and accept residual risk explicitly).
• Mistake: Failover breaks security controls. Fix: pre-stage firewall/NAT policies and confirm logging/telemetry over the alternate route.
• Mistake: Evidence is scattered. Fix: maintain a single CP-8(2) evidence packet per system/site.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for CP-8(2). Treat the risk as availability and continuity exposure that can become a contractual noncompliance finding in federal assessments and customer audits. A single telecom event that drops both “primary” and “backup” often triggers incident response, SLA breaches, and missed mission outcomes. CP-8(2) is designed to prevent that failure mode ¹.

Practical 30/60/90-day execution plan

Use this as an operator’s plan. Adjust sequencing based on procurement lead times.

First 30 days (design + discovery)

• Assign control owner and finalize in-scope sites/services.
• Build telecom dependency maps for each site and critical cloud access path.
• Publish “alternate telecom acceptance criteria” and procurement intake questions.
• Stand up an evidence folder structure and control narrative template.

Next 60 days (procurement + implementation)

• Order alternate service(s) where gaps exist; track dependencies and install dates.
• Implement routing, firewall policies, and monitoring for dual paths.
• Update diagrams and configuration baselines after changes.

By 90 days (testing + steady-state operations)

• Execute failover tests and document results; open remediation items for failures.
• Add CP-8(2) checks to change management for network/colo changes.
• Establish a recurring review trigger (new sites, carrier changes, major incidents).

How Daydream helps (without adding busywork): Daydream can track CP-8(2) ownership, map the requirement to your implementation procedure, and schedule recurring evidence collection so your proof stays current across sites and providers.

Frequently Asked Questions

Does CP-8(2) require two different carriers?

The text requires alternate telecom services that reduce shared single points of failure ¹. In practice, different carriers are the simplest way to show independence, but you still must validate physical and facility diversity.

If I have fiber primary and LTE backup, is that enough?

Often yes, because wireless can avoid shared conduit risk. You still need evidence that failover works for critical applications and that security controls (MFA, logging) remain functional.

What evidence do auditors accept if the carrier won’t provide route details?

Keep what you can get: demarc details, contracts, and written carrier statements about diversity, plus your internal building-entry documentation and diagrams. Pair that with tested failover results to show operational resilience.

How do I handle cloud environments where “telecom” is mostly internet access?

Treat your internet egress and any private cloud connectivity as telecom dependencies. Prove alternate paths exist and that identity, DNS, and security tooling still work during a primary path outage.

Does CP-8(2) apply to every office and branch?

Apply it where telecom loss would materially impact in-scope system availability and mission. Document your scoping decision and keep it consistent with your system boundary and continuity objectives ².

What’s the fastest way to fail an audit on CP-8(2)?

Saying “we have redundant circuits” without showing whether they share the same conduit, POP, or building entry, and without a failover test record. Auditors typically treat that as unproven design.

Footnotes

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

2. NIST SP 800-53 Rev. 5