MA-2(2): Automated Maintenance Activities

MA-2(2) sits in the NIST SP 800-53 Maintenance (MA) family and targets a common assessment failure: teams perform maintenance, but cannot prove it was planned, executed consistently, and recorded in a way that stands up to scrutiny. For federal information systems and contractor systems handling federal data, “maintenance” includes routine patching, break/fix repair, firmware updates, component replacements, and lifecycle refresh actions that can change system behavior or availability.

This enhancement is specifically about automation. The control language requires that you schedule, conduct, and document maintenance, repair, and replacement using an automated mechanism, which means the system of record should create a durable trail without relying on technicians to write manual notes after the fact. You do not need to automate every maintenance task end-to-end, but you do need automation in the workflow so scheduling and documentation are systematic, consistent, and reviewable.

This page translates MA-2(2) into implementable steps a Compliance Officer, CCO, or GRC lead can assign, test, and defend in an audit, using NIST SP 800-53 Rev. 5 as the governing reference. ¹

Regulatory text

Excerpt (verbatim): “Schedule, conduct, and document maintenance, repair, and replacement actions for the system using {{ insert: param, ma-2.2_prm_1 }} ; and” ²

What the operator must do from this text

• Schedule maintenance actions through an automated mechanism (the “{{ insert: param, ma-2.2_prm_1 }}” placeholder in OSCAL indicates your organization defines the specific automated mechanism).
• Conduct the maintenance actions in a controlled way that ties execution back to the schedule (for example, a maintenance window and an approved work item).
• Document what happened using automation so records are generated and retained reliably (tickets, job run output, patch/management logs, configuration management records), not reconstructed later from memory.

Plain-English interpretation

MA-2(2) requires you to run maintenance like a production control process:

1. maintenance work is planned and placed on a calendar, 2) execution is performed through managed tooling, and 3) documentation is automatically captured so you can prove the work occurred and identify the affected assets and changes.

A practical test: if an auditor asks, “Show me all maintenance performed on this production server (or SaaS tenant) over a period,” you should be able to pull a report from your tools and show the schedule, associated tickets/approvals, and system-generated evidence of the work performed.

Who it applies to (entity and operational context)

Entities: Federal information systems and contractor systems handling federal data. ³

Operational contexts where MA-2(2) matters most:

• Environments with formal authorization boundaries (ATO packages), system security plans, or inherited controls.
• Hybrid estates where maintenance spans endpoints, servers, network devices, hypervisors, cloud infrastructure, and managed platforms.
• High-change operational teams (DevOps/SRE/IT Ops) where maintenance overlaps with change management and incident response.

Assets in scope (typical):

• Production system components (compute, network, storage), security tooling supporting the system, and management planes used to administer it.
• Third-party managed components when the system owner remains accountable (for example, managed hosting or managed security services). Treat these as third-party maintenance obligations with evidence expectations.

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

Step 1: Name the automated mechanism(s) and make them the system of record

Define what tools satisfy “automated mechanism” for:

• Scheduling (examples: ITSM change calendar, patch orchestration scheduler, maintenance windows in cloud management tools).
• Execution (examples: patch management platform, configuration management/orchestration, endpoint management, network automation).
• Documentation (examples: ITSM tickets with required fields, automated job/run logs, CMDB updates, asset lifecycle records).

Write this down as the MA-2(2) implementation statement and map each tool to an evidence output.

Step 2: Define the maintenance taxonomy and minimum required fields

Create a small set of maintenance categories and make them selectable in the tool:

• Routine maintenance (patching, signature updates, certificate renewals)
• Repair/break-fix
• Replacement (hardware refresh, component swap, image rebuild)
• Emergency maintenance (expedited work)

Configure required fields for each work item:

• Asset identifier(s) (CMDB CI, hostname, cloud resource ID)
• Maintenance type
• Planned start/end window
• Executor (person/team) and method (tool/runbook)
• Outcome (success/partial/fail) and rollback notes if applicable
• Links/attachments to machine-generated logs (job ID, command output, vendor patch report)

Step 3: Enforce ticket-based execution for in-scope maintenance

Operational rule: “If it’s maintenance on an in-scope system, it happens under an ITSM work item (change/request/maintenance ticket) or an automatically generated work record.”

Implementation patterns that work:

• Auto-create tickets from patch campaigns or scheduled jobs.
• Require a ticket reference in automation runs (for example, as a parameter, tag, or change ID).
• Block “direct-to-prod” maintenance that leaves no trace (shared admin accounts, undocumented console work).

Step 4: Automate documentation capture and retention

You want evidence that is:

• Generated by the system (job run logs, patch compliance reports, device management logs, cloud audit trails).
• Linked to the ticket and the asset.
• Retained per your audit retention policy.

Minimum automation goals:

• Job IDs and timestamps recorded automatically.
• Asset scope recorded automatically (target groups, device lists, resource tags).
• Output stored centrally (log platform, ITSM attachments, or controlled repository).

Step 5: Add governance checks (review, exceptions, and trending)

Define who reviews and how often:

• A control owner reviews a maintenance report (scheduled vs completed, failures, overdue items).
• Exceptions (missed windows, repeated failures, unsupported assets) trigger remediation work items.

If you need a lightweight operating rhythm: make the review part of existing change advisory board (CAB) or operational risk reviews, but keep the output audit-ready.

Step 6: Extend to third parties where you rely on them for maintenance

For managed services or SaaS:

• Contractually require maintenance records (or exported reports) that show schedule and completion.
• Require notification and change records when maintenance can affect your system boundary.
• Store third-party attestations and maintenance reports alongside internal evidence.

Daydream can help here by mapping MA-2(2) to a named control owner, a written procedure, and a recurring evidence list so you are not rebuilding audit packets each cycle. ²

Required evidence and artifacts to retain

Keep evidence in a way that supports both design (the process exists) and operating effectiveness (it ran as intended).

Control design artifacts

• MA-2(2) procedure: tools used for scheduling/execution/documentation; scope statement; roles and responsibilities.
• Configuration screenshots/exports: required ticket fields, calendar settings, automated job schedules, retention settings.
• RACI or ownership record: named control owner and backups.

Operating effectiveness artifacts

• Maintenance calendar export or ITSM schedule view for the period.
• Sampled maintenance tickets showing required fields, approvals (if required by your process), and completion.
• Automated job/run logs (patch reports, orchestration run results) tied to the ticket and asset list.
• Replacement/repair records (RMA tickets, asset disposal/refresh records) tied to CMDB updates.
• Exception register: missed/failed maintenance items and follow-up tickets.

Common exam/audit questions and hangups

“What is your automated mechanism?”
Have a single sentence answer and point to the tool outputs. Auditors dislike “we email a schedule around.”

“Show me evidence maintenance was documented automatically.”
If your technicians type narrative notes, that is weak. Pair human notes with machine logs.

“How do you know the asset list is complete?”
Expect asset inventory/CMDB questions. If the asset list is wrong, your maintenance schedule is incomplete.

“How do you handle emergency maintenance?”
You need an after-the-fact documentation path that is still ticketed and linked to logs.

“What about third-party managed components?”
Be ready to show contract language, reports, and your internal tracking.

Frequent implementation mistakes and how to avoid them

1. Automation exists, but documentation is manual.
   Fix: require job IDs/log links in the ticket and store logs centrally.

2. Scheduling is informal (spreadsheets, chats).
   Fix: put maintenance windows in the ITSM calendar or the scheduling function of your maintenance tool and export reports.

3. No asset linkage.
   Fix: force CI selection from CMDB, or tag-based targeting with exports that list affected resources.

4. Shared admin accounts and console-only work.
   Fix: require named execution identities and record activity through centralized logging/audit trails.

5. “Maintenance” conflated with “change” without clarity.
   Fix: define what maintenance types require change control vs standard maintenance, but keep MA-2(2) evidence consistent either way.

Enforcement context and risk implications

NIST SP 800-53 is a control framework rather than an enforcement statute. Your exposure typically shows up as audit findings, ATO delays, contractual noncompliance, or customer assurance failures when you cannot prove disciplined maintenance. The practical risk is straightforward: undocumented maintenance hides unauthorized changes, breaks incident timelines, and increases recovery time because teams cannot reconstruct what was done.

Practical 30/60/90-day execution plan

First 30 days (foundation)

• Assign a control owner and write a one-page MA-2(2) procedure referencing your chosen automated mechanisms. ³
• Define in-scope systems/assets and align to your CMDB or asset inventory.
• Configure ITSM ticket fields (maintenance type, CI required, window, outcome, log link).
• Identify where machine logs live and who can export them for an audit sample.

Days 31–60 (operationalize)

• Turn on or formalize maintenance schedules in the selected tools (patch campaigns, maintenance windows, recurring tickets).
• Implement ticket-to-execution linkage (change ID in automation runs, or auto-created tickets from tools).
• Run a pilot on one system boundary and collect an evidence packet (schedule + tickets + logs + exceptions).

Days 61–90 (harden and scale)

• Expand to all in-scope systems and standardize naming conventions for schedules and tickets.
• Build a recurring compliance check: completed vs scheduled maintenance, failures, and overdue actions.
• Add third-party maintenance evidence requests to your third-party governance workflow where applicable.
• Store recurring evidence in a single repository or GRC system, with a clear index. Daydream is a practical place to maintain the owner/procedure/evidence map so audits do not depend on institutional memory. ²

Frequently Asked Questions

What counts as an “automated mechanism” for MA-2(2)?

A tool that systematically schedules and/or records maintenance without relying on technicians to create records from scratch. Common examples are ITSM platforms with calendars and required fields, patch/orchestration tools with job histories, and centralized logging that captures execution details. ²

Do we need to automate the maintenance action itself, or only the documentation?

The requirement text calls for scheduling, conducting, and documenting maintenance using an automated mechanism, so aim for automation across the workflow. If some tasks remain manual (for example, a physical replacement), make the scheduling and documentation automated and attach machine-generated evidence where available. ²

How do we handle emergency maintenance that happens outside the normal schedule?

Use an expedited ticket path that still captures the maintenance window, affected assets, executor, and machine logs. Require after-the-fact completion documentation in the same system of record so the audit trail stays intact.

What evidence is strongest in an assessment?

Machine-generated records tied to an approved work item: job IDs, patch reports, device lists, timestamps, and tool audit logs, all mapped to specific assets. Pair those with a clear schedule export and an exceptions log.

How do we apply MA-2(2) when a third party performs maintenance (managed services or SaaS)?

Add maintenance reporting and notification requirements to the contract or oversight process, then store their reports alongside your internal tracking. If you cannot obtain detailed logs, keep the strongest available evidence (maintenance notices, change records, service reports) and document the limitation and compensating controls.

Can we satisfy MA-2(2) with spreadsheets if we store them in a controlled folder?

Spreadsheets can support planning, but they are weak as an “automated mechanism” because execution and documentation often remain manual and inconsistent. Audits go smoother when the system of record is an operational tool that produces logs and reports directly.

Footnotes

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

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

3. NIST SP 800-53 Rev. 5