PL-1: Policy and Procedures

PL-1 requires you to create, document, and distribute a program-level policy and supporting procedures for the Planning (PL) control family, then prove they are current, approved, and communicated to the right audiences. To operationalize it fast, assign an owner, define scope and applicability, publish a controlled policy/procedure set, and run a simple maintenance cadence with retained evidence.

Key takeaways:

• Write one PL policy and a small set of enforceable procedures, scoped to your system boundary and control applicability.
• Make dissemination auditable: defined audiences, delivery method, acknowledgement where appropriate, and version control.
• Map PL-1 to control owners, implementation procedures, and recurring evidence artifacts to stay assessment-ready (NIST SP 800-53 Rev. 5 OSCAL JSON).

The pl-1: policy and procedures requirement is a “control-foundation” expectation: assessors will look for written direction (policy), operational how-to (procedures), and proof that the organization actually put those documents in front of the people who must follow them. In NIST SP 800-53 programs, PL-1 is commonly treated as the administrative control that anchors the entire Planning (PL) family, which includes items like security plans and rules of behavior.

Operationally, PL-1 fails in predictable ways: policies exist but are generic and not tied to the system boundary; procedures are missing or buried in tribal knowledge; documents are not approved, versioned, or distributed; and nobody can show evidence that staff received and understood them. The result is an audit finding that often cascades into multiple control gaps because other PL controls depend on having a policy and procedural backbone.

This page gives you requirement-level implementation guidance you can execute quickly: who should own PL-1, what artifacts to produce, how to disseminate them in an auditable way, what evidence to keep, and the exam questions you should expect. Source references are limited to NIST SP 800-53 Rev. 5 materials provided (NIST SP 800-53 Rev. 5; NIST SP 800-53 Rev. 5 OSCAL JSON).

Regulatory text

Excerpt (as provided): “Develop, document, and disseminate to {{ insert: param, pl-1_prm_1 }}:” (NIST SP 800-53 Rev. 5 OSCAL JSON)

What an operator must do with this text

• Develop: decide what your Planning (PL) policy and procedures are, for your organization and for the system(s) in scope.
• Document: put them in controlled documents (not just tickets, emails, or wiki notes without change control).
• Disseminate: distribute them to a defined audience (the parameter placeholder indicates the audience is configurable by the organization/system). Your job is to name that audience, deliver the materials, and be able to prove it later (NIST SP 800-53 Rev. 5 OSCAL JSON).

Because the excerpt includes a parameter for the recipient audience, your implementation must explicitly define:

1. who receives the PL policy/procedures, and
2. how you prove dissemination happened.

Plain-English interpretation (what PL-1 really expects)

PL-1 expects a small, coherent set of “rules and runbooks” for the Planning control family:

• A policy that states management intent, scope, roles, and minimum requirements.
• Procedures that translate the policy into repeatable steps someone can execute and an assessor can test.

If your PL documentation cannot answer “who does what, when, with what approvals, and what evidence is produced,” it will not hold up well in an assessment, even if it reads nicely.

Who it applies to (entity and operational context)

PL-1 is used in NIST SP 800-53 Rev. 5 security programs, commonly for:

• Federal information systems
• Contractor systems handling federal data (NIST SP 800-53 Rev. 5 OSCAL JSON)

Typical operational contexts where PL-1 shows up:

• ATO / authorization packages for federal systems.
• Shared services where one PL policy must cover multiple environments, with procedures that vary by platform.
• Regulated environments where your SSP and planning artifacts are reviewed by external assessors.

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

Step 1: Name a control owner and lock scope

1. Assign a PL-1 control owner (often GRC lead, ISSO, or security governance).
2. Define the system boundary or program boundary the PL policy covers.
3. Define the audience for dissemination (the placeholder in the requirement). Use a short list tied to responsibilities, for example:
   • System owners and service owners
   • GRC/security staff who maintain the SSP and planning artifacts
   • Engineering/IT staff with planning responsibilities
   • Third parties who must follow your rules of behavior (if applicable to your environment)

Operator tip: Keep the audience list role-based, not named individuals, and tie it to job functions that auditors recognize.

Step 2: Draft the PL policy (minimum viable but testable)

Your PL policy should fit on a few pages and include:

• Purpose and scope (what systems/data it covers)
• Roles and responsibilities (who maintains the SSP, who approves changes, who reviews)
• Required planning artifacts (for example: security plan, planning updates, rules of behavior as applicable to your program)
• Approval authority and exception process
• Review/update expectations (define a cadence your team can sustain)
• References to procedures that implement the policy

Step 3: Write procedures that produce evidence

Procedures should be task-focused. Common procedure components:

• Trigger events (new system, major change, periodic review, incident-driven update)
• Inputs (architecture diagrams, asset inventory references, change requests)
• Steps (who drafts, who reviews, who approves, where stored)
• Outputs/evidence (approved document, change log, training/acknowledgement record)
• Tools/systems of record (GRC platform, document repository, ticketing)

Minimum set to pass the smell test: one procedure for document control and one for maintaining planning artifacts tied to PL. If you already have document control elsewhere, reference it and make the PL procedure explicitly point to it.

Step 4: Implement document control (versioning + approvals)

Auditors rarely accept “it’s in a wiki” without controls. Put in place:

• Version history
• Approval workflow (even a simple e-sign or change ticket approval)
• Effective date, next review date, owner, and approver fields
• A single authoritative location (“system of record”) for the current version

Step 5: Disseminate in an auditable way

Define dissemination channels per audience:

• HR/LMS assignment for staff training (where applicable)
• Email distribution with read-receipt logging (if your environment supports it)
• GRC portal acknowledgement workflow
• Vendor/third-party onboarding packet (if third parties must follow rules)

Then, record:

• Who was targeted (roles or lists)
• What was sent (document title and version)
• When it was sent
• Completion/acknowledgement results where appropriate

Step 6: Map PL-1 to owners, procedures, and recurring evidence

Create a simple control mapping table. This is explicitly aligned to the recommended control approach: “Map PL-1 to control owner, implementation procedure, and recurring evidence artifacts” (NIST SP 800-53 Rev. 5 OSCAL JSON).

A practical format:

Item	What to define	Example (adapt to your org)
Control owner	Accountable role	GRC Lead (accountable), ISSO (responsible)
Policy artifact	Name + location	“PL Policy,” stored in controlled repository
Procedures	Names + links	“PL Document Control Procedure,” “SSP Maintenance Procedure”
Evidence	What you retain	Approval record, dissemination log, review meeting minutes
Cadence	How you keep it current	Periodic review aligned to governance cycle

Step 7: Operationalize maintenance (don’t let it rot)

Create a lightweight mechanism:

• A recurring governance agenda item for PL documentation currency
• A change trigger checklist tied to your change management process
• A “last reviewed” and “next review” field that is actually updated

Required evidence and artifacts to retain

Keep evidence that proves three verbs: develop, document, disseminate (NIST SP 800-53 Rev. 5 OSCAL JSON).

Core artifacts

• PL policy (current approved version)
• PL procedures (current approved versions)
• Document control records (version history, change log, approvals)

Operational evidence

• Dissemination records (distribution list or role mapping, date sent, content/version)
• Acknowledgements or training completion records (if you require them)
• Review records (meeting notes, annual/periodic review ticket, sign-off)
• Exceptions/waivers and compensating controls (if applicable)

Assessment-ready packaging

• A one-page PL-1 control implementation statement summarizing how the policy/procedures are managed and disseminated
• A “last 1–2 cycles” evidence bundle (most recent approvals + most recent dissemination event)

Common exam/audit questions and hangups

Expect these questions:

• “Show me the approved PL policy and the procedures that implement it.”
• “Who is the defined dissemination audience (the parameter in the control) and how did you determine it?” (NIST SP 800-53 Rev. 5 OSCAL JSON)
• “Prove dissemination. Who received version X and when?”
• “How do you ensure procedures are followed, not just written?”
• “What triggers an update to planning documentation after a major system change?”

Common hangups:

• Policy exists but no procedures, or procedures exist but no formal policy.
• Dissemination is informal (“it’s on SharePoint”) with no record of who was notified.
• Multiple conflicting “current” versions across teams.

Frequent implementation mistakes and how to avoid them

1. Copy-paste policies with no system boundary

   • Fix: add a scope statement tied to the specific system(s) or program boundary.

2. Procedures that read like policy

   • Fix: procedures must produce outputs (tickets, approvals, updated plans) that you can show.

3. No defined dissemination audience

   • Fix: write the audience into the policy. Use role-based categories that match your org chart.

4. No evidence bundle

   • Fix: pre-stage an assessor packet: current docs, last approval, last dissemination proof.

5. Ownership without accountability

   • Fix: name an accountable role, and make them responsible for review scheduling and evidence collection.

Risk implications (why PL-1 findings hurt)

PL-1 gaps create second-order failures:

• Out-of-date planning documents can invalidate what your SSP claims versus what is deployed.
• Undefined responsibilities increase the chance that security planning tasks fall between teams.
• Weak dissemination increases insider-risk and operational error because staff follow inconsistent “rules of the road.”

If you run a third-party-heavy environment, lack of dissemination to relevant third parties (where applicable) also increases contractual and operational risk. The control text allows you to set the audience, but once you set it, you must meet it consistently (NIST SP 800-53 Rev. 5 OSCAL JSON).

Practical execution plan (30/60/90-day)

You asked for speed, so here’s a plan that works even with limited staff time.

First 30 days (stand up the minimum viable PL-1)

• Assign owner and approver; define system/program scope.
• Draft PL policy and 1–2 implementing procedures.
• Put documents into a controlled repository with versioning and an approval record.
• Define the dissemination audience and channels; run the first dissemination event.
• Build the PL-1 mapping table (owner, procedures, evidence artifacts) (NIST SP 800-53 Rev. 5 OSCAL JSON).

By 60 days (make it repeatable)

• Connect update triggers to change management (new major release, architecture change, boundary change).
• Add a standard “evidence checklist” to each procedure (what to save, where).
• Run a tabletop walkthrough: have someone execute the procedure using only the written steps; fix gaps.

By 90 days (make it assessment-ready)

• Run an internal control check: confirm policy/procedures match actual practice and tools.
• Perform a second dissemination touchpoint (for example, new-hire onboarding or quarterly governance note) and file evidence.
• Package an assessor-ready PL-1 binder: current approved docs + dissemination + last review artifacts.

Where Daydream fits naturally If you manage many controls across multiple systems, Daydream can store the PL-1 owner/procedure/evidence mapping and keep recurring evidence artifacts linked to the control, so you can answer assessor requests without rebuilding the story each cycle (NIST SP 800-53 Rev. 5 OSCAL JSON).

Frequently Asked Questions

What counts as “procedures” for PL-1?

Procedures are executable steps that implement the PL policy, with defined inputs, approvals, and outputs you can prove. If the document doesn’t produce evidence (like an updated plan, approval record, or change log), it’s usually not testable as a procedure.

Who should receive dissemination for PL-1?

The control text leaves the audience configurable, so you must define it based on roles that create or maintain planning artifacts and roles that must follow planning-related rules. Document the audience in the policy and keep evidence of each dissemination event (NIST SP 800-53 Rev. 5 OSCAL JSON).

Is posting the policy on an intranet enough?

Usually not by itself. You need a defensible dissemination method plus evidence that the intended audience was notified (and acknowledged if your program requires it).

Can I reuse an enterprise policy across multiple systems?

Yes, if the scope and applicability are clear and each system can point to the same authoritative version. Many teams add a short “system addendum” that lists system-specific roles, repositories, and triggers.

How do I show PL-1 is operating, not just documented?

Keep evidence of maintenance actions: approvals, review tickets, dissemination logs, and at least one example of the procedure being executed after a change. Assessors want to see that the documents are alive.

What’s the fastest way to get audit-ready for PL-1?

Create the owner/procedure/evidence mapping, publish approved documents with version control, and run one documented dissemination cycle. That combination typically answers the first wave of audit requests (NIST SP 800-53 Rev. 5 OSCAL JSON).