CP-8(5): Alternate Telecommunication Service Testing

CP-8(5) sits in the Contingency Planning (CP) family of NIST SP 800-53 Rev. 5 and focuses on a narrow but failure-prone dependency: communications during an incident. Most continuity plans assume network connectivity will “just be there” via an alternate circuit, carrier, or routing design. CP-8(5) forces you to prove that assumption with testing and evidence.

For a Compliance Officer, CCO, or GRC lead, the fastest path to operationalizing CP-8(5) is to treat it like a production change-and-test routine tied to defined systems and sites. You need three things: (1) an inventory of alternate telecom services mapped to mission/business functions, (2) a repeatable test procedure that exercises failover in a controlled way, and (3) durable evidence that shows tests occurred, issues were tracked, and fixes were verified.

If you support federal information systems or contractor systems handling federal data, CP-8(5) is also an assessment-readiness item. Assessors commonly look for proof that failover was actually executed, not just planned. Your goal is simple: demonstrate that alternate telecommunication services are tested, results are recorded, and the control stays in a steady operational rhythm. ¹

Regulatory text

Control requirement (excerpt): “Test alternate telecommunication services {{ insert: param, cp-08.05_odp }}.” ²

What the operator must do:

• Identify which telecommunication services are “alternate” for your environment (secondary ISP, alternate carrier, redundant MPLS/SD-WAN links, LTE/5G failover, alternate voice trunks, out-of-band management circuits, satellite links, etc.).
• Perform tests that demonstrate these alternates function as intended when primary communications are unavailable.
• Keep records that show the test occurred, what was tested, what the result was, what failed, and how you fixed it.

Because the excerpt includes an organization-defined parameter (“cp-08.05_odp”), you must define the missing specifics in your control statement (for example, what gets tested, how often, and what constitutes “success”) and then execute to that definition. ²

Plain-English interpretation

If you claim you have backup communications for continuity, you must prove they work. “Prove” means a real test that routes traffic over the alternate path (or exercises the alternate voice/data service), not a diagram review. The output must be auditable: repeatable procedure, dated results, and remediation evidence.

A good mental model: CP-8(5) is the telecom equivalent of generator testing. Having the generator is not enough; you test-start it, you confirm load transfer, and you keep the maintenance log.

Who it applies to (entity and operational context)

Typical in-scope entities

• Federal information systems and programs aligning to NIST SP 800-53 Rev. 5. ¹
• Contractors and other third parties operating systems that handle federal data and are required to implement NIST controls by contract, authorization boundary, or customer flow-down. ¹

Operational contexts where CP-8(5) matters most

• Multi-site organizations where sites depend on WAN connectivity for identity, apps, and voice.
• Cloud-heavy environments with dedicated connectivity (for example, direct connectivity circuits) plus VPN/Internet backup.
• Call centers, SOCs, and incident response functions that require voice and data during disruptive events.
• OT/ICS environments that depend on out-of-band access for recovery activities.

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

1) Define “alternate telecommunication services” for your boundary

Create a scoped inventory. For each site/system, list:

• Primary telecom path(s): carrier, circuit ID, termination, routing.
• Alternate telecom path(s): carrier, technology (fiber, coax, LTE/5G, satellite), termination, routing, failover method.
• What the alternate supports: critical applications, VPN, DNS, voice/SIP, management plane access.

Operator tip: include “supporting services” that break failover in practice, such as DNS resolvers, certificate validation, or IP allowlists that only include primary egress addresses.

2) Map alternates to mission/business functions and recovery needs

Tie each alternate service to:

• The business process it supports during disruption.
• The dependency chain (network → identity → application → communications).
• Any declared recovery approach in your contingency plan.

This mapping is what lets you defend scope decisions during assessment: why you tested these links and not others.

3) Write a test procedure that reflects real failover

Your procedure should specify:

• Preconditions (maintenance window approval, stakeholders present, rollback plan).
• Exact failover action (disable primary interface, withdraw routes, force SD-WAN policy, trigger voice trunk failover).
• Success criteria (what traffic must pass, what services must be reachable, what monitoring must show).
• Evidence to capture (screenshots, routing tables, controller events, call test results, synthetic checks).

Keep it simple enough that an on-call network engineer can run it without rewriting it each time.

4) Execute tests with change control and safety rails

Run controlled tests. Use your normal operational governance:

• Open a change ticket with scope, steps, rollback, approvals.
• Notify impacted teams (help desk, SOC, application owners).
• Monitor in real time (network telemetry, synthetic transactions, voice call paths).
• Record start/stop times, commands issued, and observed outcomes.

Practical example test cases

• WAN failover: Shut the primary circuit or logically disable it, confirm routing converges to backup, confirm critical apps and authentication still function.
• Remote access continuity: Force VPN traffic through backup ISP, validate MFA, session establishment, and key administrative functions.
• Voice continuity: Place inbound/outbound test calls and validate call quality, routing, and logging during trunk failover.
• Out-of-band management: Validate you can reach critical network gear via OOB path when production WAN is down.

5) Document results and defects as first-class audit artifacts

For each test, capture:

• What was tested (systems/sites/circuits).
• How it was tested (commands, steps, tools).
• Results (pass/fail per success criterion).
• Issues found and risk impact (what would fail during an outage).
• Corrective actions (config changes, carrier tickets, runbook updates).
• Retest results after fixes.

Auditors reward disciplined defect closure. A “failed test with tracked remediation” is usually safer than “no evidence of testing.”

6) Operationalize recurrence (don’t let it become annual theater)

Because CP-8(5) uses an organization-defined parameter, you must set and follow a cadence. Put it on a calendar with owners, and tie it to:

• Major network changes (carrier cutovers, SD-WAN redesigns).
• Site openings/closures.
• Significant application migrations that change network dependencies.

Daydream fit (earned, not forced): teams often lose evidence across tools (change management, monitoring, carrier portals). Daydream can act as the system of record for CP-8(5) by mapping the control to an owner, a standard test procedure, and a recurring evidence checklist so assessments don’t become archaeology.

Required evidence and artifacts to retain

Use an “evidence bundle” per test event. Minimum set:

• Control statement / control narrative for CP-8(5) with your defined parameter (scope, frequency, success criteria). ²
• Network/service inventory showing primary and alternate telecom services, with boundary mapping.
• Test plan / runbook (steps, prerequisites, rollback).
• Change ticket(s) covering the execution and approvals.
• Objective technical outputs: routing tables, SD-WAN event logs, firewall logs, monitoring graphs, synthetic check reports, voice test records.
• Results report with pass/fail against defined criteria.
• Remediation tickets (carrier tickets, internal engineering work items), plus closure evidence and retest proof.
• Exception/risk acceptance memos if a test cannot be performed, with compensating controls and a dated plan to close the gap.

Retention period is typically driven by your overall GRC retention schedule and contractual obligations; document what you chose and apply it consistently.

Common exam/audit questions and hangups

Assessors and auditors usually drill on these points:

• “Show me the last test.” They want timestamps, artifacts, and proof the alternate path carried real traffic.
• “What exactly is ‘alternate’ here?” If you can’t point to circuits/services and their roles, the control sounds aspirational.
• “Was this a tabletop or a technical test?” CP-8(5) expects testing of services, not discussion about them. ²
• “What failed, and what did you do about it?” Remediation and retesting separate mature programs from checkbox programs.
• “Is the test representative?” A test that only pings a single IP may not prove authentication, DNS, voice, or critical apps.

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails CP-8(5)	How to avoid
Counting a carrier SLA as “testing”	SLAs don’t prove your routing, firewall rules, or app dependencies	Execute your own failover and validate end-to-end services
Only testing data, not voice or management paths	Outages often require coordination and admin access	Include voice and OOB tests where those are part of your continuity design
No success criteria	Auditors can’t tell what “worked” means	Define explicit pass/fail checks tied to business functions
Testing once, never retesting after changes	Network changes silently break failover	Trigger tests after significant changes and keep a schedule
Evidence scattered across tools	You can’t prove operation under audit pressure	Centralize an evidence checklist and store artifacts consistently (Daydream can help)

Risk implications (why operators care)

Untested alternate telecom services create a predictable failure mode: the outage happens, failover doesn’t, and recovery actions stall because teams cannot reach systems, identity services, or each other. The compliance risk is equally practical: inability to produce evidence that CP-8(5) is operating as defined can drive control findings, POA&Ms, and customer confidence issues in federal assessments. ¹

Practical 30/60/90-day execution plan

First 30 days (stand up the control)

• Assign a single accountable owner (usually Network Engineering with GRC oversight).
• Build the in-scope inventory: sites, circuits, carriers, SD-WAN policies, voice trunks, OOB paths.
• Write the CP-8(5) control statement with your defined parameters (what gets tested, what “pass” means, where evidence lives). ²
• Draft a standard test runbook template and an evidence checklist.

Next 60 days (run initial tests and close obvious gaps)

• Execute tests for the highest-impact sites/systems first (where outage impact is highest).
• Create defects for every failure, assign remediation owners, and track to closure.
• Update diagrams, runbooks, and monitoring based on what the tests revealed.
• Normalize evidence storage so each test produces a complete bundle.

By 90 days (stabilize operations and assessment readiness)

• Expand testing coverage to remaining in-scope alternates.
• Add “test after major network change” as a required step in change management.
• Run a mini internal review: pick a test at random and validate the evidence bundle is complete.
• Implement a recurring schedule and owner reminders (Daydream is useful here if you want control-to-evidence automation and ready-to-export audit packets).

Frequently Asked Questions

What counts as an “alternate telecommunication service” under CP-8(5)?

Any backup communications path you expect to use during a disruption, such as a secondary ISP, alternate carrier circuit, LTE/5G failover, alternate voice trunking, or out-of-band access. Document the alternates explicitly in your inventory and control statement. ²

Do tabletop exercises satisfy CP-8(5)?

Tabletop exercises help readiness, but CP-8(5) is about testing the alternate telecommunication services themselves. Run a technical test that forces failover and confirms services work over the alternate path. ²

How do we set the testing frequency if the control leaves it as an organization-defined parameter?

Define a cadence based on risk and change velocity, then execute consistently and record evidence. Auditors care less about the exact number and more about whether your defined approach is followed and produces meaningful results. ²

What evidence is strongest for auditors?

A change ticket tied to a dated test report plus objective logs showing traffic shifted to the alternate path. Add remediation tickets and retest proof if anything failed.

We can’t fully fail over production without risk. What do we do?

Use controlled maintenance windows, partial failovers, or segmented testing that still proves the alternate path carries real workloads for critical services. If a path truly cannot be tested, document a time-bound exception and compensating controls, then track remediation.

How does this differ from broader contingency planning testing?

CP-8(5) is narrowly focused on telecom alternates, while broader contingency testing may cover backups, recovery procedures, and incident roles. Treat CP-8(5) as a network/telecom operational control with repeatable technical evidence. ¹

Footnotes

1. NIST SP 800-53 Rev. 5

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