MA-1: Policy and Procedures

To meet the ma-1: policy and procedures requirement, you must create a formal maintenance (MA) policy and supporting procedures, then distribute them to the right audiences so maintenance is performed consistently and is auditable. Operationally, that means defining scope, roles, workflows, and evidence for all maintenance activities affecting in-scope systems, and proving staff follow them. ¹

Key takeaways:

• You need two layers: an MA policy (management intent) and MA procedures (how work gets done), both documented and disseminated. ¹
• “Disseminated” means assigned, accessible, and acknowledged, not just stored in a folder.
• Your fastest path to readiness is a control-to-owner mapping plus a recurring evidence schedule tied to real maintenance tickets and change records.

MA-1 is a foundational control in the NIST SP 800-53 Maintenance (MA) family. It is not a “paperwork” requirement; it is the control that lets assessors—and your own leadership—see that maintenance work is governed, repeatable, and producing the right records. If you run federal information systems or you are a contractor handling federal data, MA-1 is often scrutinized early because weak policy/procedure hygiene creates downstream failures across maintenance authorization, tool control, remote maintenance, and post-maintenance verification.

In practice, teams stumble on MA-1 for two reasons. First, they write a broad IT policy that never describes maintenance activities (patching, break/fix, firmware updates, field service, third-party support, emergency repairs). Second, they cannot show dissemination and operating evidence: who follows the procedure, where it lives, and what artifacts prove the process runs.

This page gives requirement-level guidance you can implement quickly: what to write, who must approve it, how to roll it out, what evidence to retain, and what auditors ask. It also includes a 30/60/90-day execution plan you can hand to a control owner.

Regulatory text

Excerpt (provided): “Develop, document, and disseminate to {{ insert: param, ma-1_prm_1 }}:” ²

Operator interpretation of the excerpt: MA-1 requires you to (1) develop and (2) document maintenance policy and procedures, then (3) disseminate them to defined audiences (the parameter placeholder indicates the audience is defined in the control’s full specification). ²

What an assessor expects you to demonstrate

• A written Maintenance Policy that sets intent, scope, roles, and governance for maintenance activities on in-scope systems. ¹
• Written Maintenance Procedures that operational teams can follow, covering common maintenance scenarios and required records. ¹
• Evidence the policy/procedures are distributed and known by the teams who execute or oversee maintenance. ¹

Plain-English requirement interpretation (what MA-1 “really” means)

You must be able to answer, consistently and with proof:

1. What maintenance is allowed, on what systems, and under what rules?
2. Who can do maintenance, and how do they get authorized?
3. How do you record and verify maintenance work?
4. How do you ensure the rules are communicated and followed across employees and third parties?

MA-1 is the “instruction manual” control. If maintenance is happening without clear written rules and repeatable steps, you will struggle to show compliance across the rest of the MA family.

Who it applies to

Entity types (typical):

• Federal information systems operated by agencies. ¹
• Contractor systems handling federal data (including cloud/SaaS environments supporting federal programs). ¹

Operational contexts where MA-1 becomes real

• Infrastructure maintenance (servers, endpoints, network gear, appliances).
• Cloud operations (IaaS/PaaS configuration changes, platform patching coordination, image management).
• Application/platform maintenance (hotfixes, dependency upgrades, database tuning).
• Facilities-adjacent maintenance that touches systems (physical access by repair technicians, component replacement).
• Third-party support and field service where an external party performs maintenance actions.

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

Step 1: Set MA-1 scope and boundaries

• Define the system boundary (which systems are in-scope for NIST 800-53 assessment).
• Define what counts as maintenance in your environment (patching, break/fix, upgrades, component replacement, remote support sessions, diagnostics).
• Document exclusions explicitly (for example, end-user self-service that does not change configurations), and tie them to your system boundary statement.

Output: MA scope statement embedded in policy + referenced in procedures.

Step 2: Write the Maintenance (MA) policy (one document, management level)

Include these minimum sections:

• Purpose and scope (systems, environments, maintenance types).
• Roles and responsibilities (system owner, IT operations, security, service desk, third-party support coordinator).
• Governance requirements:
  • When maintenance requires prior approval.
  • When emergency maintenance is allowed and how it is documented after the fact.
  • Required logging/recordkeeping expectations.
• Tooling expectations (ticketing system, change management system, access management).
• Compliance references (map MA policy to NIST SP 800-53 MA family). ¹

Practical tip: Keep the policy short. Put operational detail in procedures so teams can update workflows without re-approving a high-level policy every time.

Step 3: Write the maintenance procedures (how-to workflows)

Create procedures that match how work is executed. At minimum, document:

1. Planned maintenance workflow
   • Intake request → risk/impact review → approval → scheduling → execution → verification → closure.
2. Emergency maintenance workflow
   • Criteria for “emergency,” who can authorize, and required after-action documentation.
3. Third-party maintenance workflow
   • How you approve third-party access, how sessions are monitored/recorded (if applicable), and what evidence you retain.
4. Post-maintenance validation
   • What “done” means: functional testing, security checks, service restoration verification, and rollback criteria.
5. Recordkeeping
   • Minimum ticket fields and attachments (what must be captured every time).

Output: A procedures set that a technician can follow and an auditor can trace from policy to ticket evidence.

Step 4: Define dissemination (don’t treat it as “posted on SharePoint”)

Decide what dissemination means for your org, then document it. Common, defensible options:

• Policy/procedures published in a controlled repository with versioning and access controls.
• Targeted distribution to:
  • Maintenance performers (IT ops, SRE, service desk),
  • Approvers (system owners, CAB or equivalent),
  • Security reviewers,
  • Third-party coordinators.
• Acknowledgement mechanism (policy attestation in GRC tool or HR training platform).
• Operational embedding (links inside ticket templates and change records).

Evidence: screenshots/exports showing publication, audience access, and acknowledgements.

Step 5: Map MA-1 to owners, systems, and recurring evidence

Create a simple mapping table (this is the fastest way to operationalize MA-1):

MA-1 element	Control owner	System(s)	Where it lives	Evidence generated
MA policy	CISO/GRC + IT Ops	In-scope boundary	Policy repository	Approved policy + version history
Planned maintenance procedure	IT Ops lead	Per system	Runbook/KB	Tickets + approvals + validation notes
Emergency maintenance procedure	IT Ops lead	Per system	Runbook/KB	Emergency tickets + after-action notes
Dissemination	GRC lead	Org-wide	GRC/training system	Attestations + access logs

This aligns with the recommended control approach: map MA-1 to a control owner, implementation procedure, and recurring evidence artifacts. ²

Where Daydream fits naturally: Daydream helps you keep this mapping current, assign owners, and maintain a predictable evidence cadence so MA-1 stays “always auditable” instead of a scramble before an assessment.

Step 6: Run an internal “trace test” before an audit

Pick a recent maintenance event and trace it end-to-end:

• Does it have a ticket?
• Was it approved per your procedure?
• Do the ticket notes show what was done and by whom?
• Is post-maintenance validation documented?
• Is the procedure referenced or followed consistently?

Fix gaps by updating the ticket template, not by writing longer policy text.

Required evidence and artifacts to retain

Maintain a clean evidence folder (or GRC evidence object) with:

• Approved MA policy (with approval record, effective date, version history). ¹
• Maintenance procedure documents/runbooks (with version history).
• Dissemination proof:
  • Repository publication record,
  • Access permissions or distribution list,
  • Attestation/training completion records.
• A sampling of maintenance records:
  • Planned maintenance tickets with approvals,
  • Emergency maintenance tickets with after-action justification,
  • Third-party maintenance tickets and access approvals,
  • Post-maintenance verification notes or test results.
• Exception records (if you allow deviations) with compensating controls and approvals.

Common exam/audit questions and hangups

Assessors commonly press on:

• “Show me where the procedure is.” They want the actual runbook, not a policy paragraph. ¹
• “Who received this?” Dissemination requires an audience definition and proof of distribution/availability. ²
• “Prove it operates.” Expect a request for maintenance ticket samples mapped to procedure steps.
• “How do third parties fit?” If third parties perform maintenance, your procedures must cover authorization and oversight in a concrete way.

Frequent implementation mistakes (and how to avoid them)

1. Mistake: One generic IT policy that never mentions maintenance.
   Fix: Write an MA-specific policy with maintenance scope and governance, then link to procedures.

2. Mistake: Procedures exist but are not the “source of truth.”
   Fix: Embed procedure steps into ticket templates (required fields, required approvals, closure checklist).

3. Mistake: No dissemination proof.
   Fix: Use a formal attestation workflow for relevant teams and keep the export as evidence.

4. Mistake: No distinction between planned vs. emergency maintenance.
   Fix: Define “emergency” criteria and require after-action documentation in the procedure.

5. Mistake: Third-party maintenance handled ad hoc.
   Fix: Add a third-party maintenance procedure with explicit approvals, session controls, and records.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat MA-1 primarily as an assessment readiness and operational control risk area, not a penalty-driven one. The practical risk factor is straightforward: missing MA-1 evidence makes it hard to demonstrate consistent maintenance governance across in-scope systems. ²

A practical 30/60/90-day execution plan

Day 0–30: Establish the minimum viable MA-1 set

• Assign a single accountable owner for MA-1 (often GRC coordinating with IT Ops).
• Draft MA policy and get approvals.
• Draft the planned + emergency maintenance procedures.
• Stand up an evidence folder structure and decide ticketing fields required for maintenance traceability.

Day 31–60: Disseminate and embed into operations

• Publish policy/procedures in a controlled repository with versioning.
• Roll out acknowledgements to in-scope teams.
• Update ticket templates and change records to match procedure steps.
• Run a trace test on a small sample of maintenance events; capture gaps and remediate.

Day 61–90: Prove steady-state operation

• Expand procedures for third-party maintenance and post-maintenance validation specifics.
• Start recurring evidence pulls (policy attestation export, maintenance ticket samples, exception log).
• Hold a tabletop review with IT Ops + Security to confirm emergency workflow works and is understood.
• Prepare an “auditor packet” with policy, procedures, dissemination proof, and maintenance samples mapped to MA-1.

Frequently Asked Questions

Do we need both a policy and procedures for MA-1?

Yes. MA-1 explicitly calls for policy and procedures, and assessors usually expect a management-level policy plus operational runbooks or SOPs. ¹

What counts as “disseminate” for MA-1?

Dissemination means the right audiences can access the current version and you can show they were informed (for example, published in a controlled repository plus attestation or training completion). ²

Can we satisfy MA-1 with our change management policy?

Sometimes it can be part of a broader control set, but MA-1 is easier to defend when you have MA-specific content that addresses maintenance activities directly and points to exact procedures and records. ¹

How do we handle third-party maintenance under MA-1?

Document a third-party maintenance procedure that covers authorization, access method, oversight expectations, and required artifacts (tickets, approvals, session records where applicable). Then retain samples that prove the workflow is used.

What evidence is most persuasive in an audit?

A clean chain from policy → procedure → actual maintenance ticket with approvals and post-maintenance validation. Add dissemination proof (publication + acknowledgement) so the assessor can confirm the documents were not just drafted for the audit.

We have procedures, but engineers don’t follow them consistently. What’s the fastest fix?

Put the procedure into the workflow: update ticket templates, require specific fields, and add closure checklists tied to post-maintenance validation. Then sample tickets regularly and feed misses into coaching or process changes.

Footnotes

1. NIST SP 800-53 Rev. 5

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