PM-7(1): Offloading

PM-7(1): Offloading requires you to move designated mission/business support functions (the PM-7 organizationally defined parameter) off a primary system by shifting them to other systems, system components, or an external provider, with defined boundaries and proof the offload works as intended ¹. Operationalize it by deciding what gets offloaded, selecting an approved target, engineering secure connectivity, and retaining evidence.

Key takeaways:

• Define exactly what “offload” means in your environment (functions, services, workloads) and document the decision criteria ¹.
• Treat offloading as a third-party risk and shared-responsibility change when an external provider is involved, and capture contracts, SLAs, and security responsibilities as evidence ².
• Build assessor-ready artifacts: architecture, control mappings, test results, and ongoing monitoring that show the offload is real, governed, and repeatable ¹.

Compliance teams usually stumble on PM-7(1) for one reason: it’s short, but it reaches across architecture, vendor management, and operations. “Offloading” can mean shifting batch processing to a separate compute tier, moving identity functions to a managed service, routing DDoS protection to a specialized provider, or relocating logging/analytics to a different platform. The control does not tell you what to offload; it tells you to offload whatever your organization has defined for PM-7(1) and to do so to an approved destination (internal components or external providers) ¹.

For a CCO, GRC lead, or security compliance operator, the fast path is: (1) lock down the organizationally defined parameter (ODP) so everyone agrees what must be offloaded, (2) implement a governed technical pattern for offloading, and (3) keep evidence that ties the business decision to the technical implementation and ongoing oversight. This page gives requirement-level, step-by-step guidance you can hand to architecture, engineering, and third-party risk owners and then assess against.

Regulatory text

Requirement (verbatim): “Offload {{ insert: param, pm-07.01_odp }} to other systems, system components, or an external provider.” ¹

What the operator must do:

1. Define the “{{ pm-07.01_odp }}” parameter in your control implementation (the specific capability, function, or workload you will offload).
2. Implement the offload by moving that defined capability to (a) another system, (b) a system component, or (c) an external provider.
3. Prove it’s implemented and governed through documentation, change records, and operational monitoring evidence that an assessor can trace end-to-end ¹.

Practical interpretation: PM-7(1) is satisfied only when the offloaded function is clearly identified, actually runs somewhere else, and the move is controlled (security, availability, and accountability do not fall into a gap).

Plain-English interpretation (pm-7(1): offloading requirement)

PM-7(1) asks you to reduce risk or improve resilience by shifting selected functions away from a primary system. The “why” is typically one of these:

• isolate high-risk functions (internet-facing, high-volume, high-privilege);
• improve survivability (failover, redundancy, blast-radius reduction);
• increase specialization (security controls run by a provider or a dedicated platform);
• manage capacity (bursty workloads handled outside the core environment).

Because the text includes “external provider,” PM-7(1) often becomes a shared-responsibility control. Your implementation must show who runs the service, who secures it, and how you oversee it ².

Who it applies to (entity and operational context)

PM-7(1) commonly applies to:

• Federal information systems implementing NIST SP 800-53 control baselines ².
• Contractor systems handling federal data (including cloud and SaaS stacks) where NIST SP 800-53 is contractually flowed down or used for authorization/assessment ².

Operational contexts where assessors expect a real PM-7(1) story:

• major platform modernization (data center to cloud, monolith to microservices);
• outsourcing security or operational functions (managed detection, DDoS, email security);
• segmentation initiatives (separating admin planes, logging planes, control planes);
• contingency planning and high availability designs.

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

Use this as an execution checklist. Keep each step traceable to an artifact.

1) Define the ODP: what exactly are you offloading?

Create a short, unambiguous statement for the parameter in your control implementation:

• Function(s) to be offloaded: e.g., “edge traffic filtering,” “centralized audit log storage,” “batch analytics processing,” “key management operations.”
• Scope boundaries: which environments (prod/non-prod), which systems, which data types.
• Decision rationale: risk reduction, resiliency, performance isolation, compliance constraints.

Output: PM-7(1) control statement with the filled-in ODP and scope notes ¹.

2) Choose the offload destination and model

Pick one of three destinations, then document why it’s appropriate:

• Other systems: a separate platform with its own boundary (good for segmentation).
• System components: separate compute tiers, appliances, or dedicated clusters (good for isolation without changing system boundary).
• External provider: cloud service, managed security service, SaaS (good for specialization, but adds third-party risk).

Operator tip: If you claim “external provider,” expect questions about contract terms, SLAs, incident handling, and audit rights ².

Output: Architecture decision record (ADR) or equivalent, tied to the PM-7(1) scope.

3) Define security and operational requirements for the offload

Write requirements that engineering can implement and auditors can test:

• Data protection: encryption in transit, encryption at rest (if applicable), key ownership model.
• Identity and access: admin access controls, least privilege, privileged access workflow.
• Logging and monitoring: what telemetry is generated, where it lands, retention and access.
• Resilience: failover behavior, dependency mapping, service limits.
• Change control: how changes are approved, tested, and rolled back.

Output: A requirements section in your system design doc or a control implementation procedure mapped to PM-7(1) ².

4) Implement the offload with a controlled change

Treat this as a production change with compliance checkpoints:

• update diagrams and inventories (what moved, where it lives now);
• configure secure connectivity (network paths, private links, firewall rules);
• migrate the function (deploy, reroute, cutover);
• validate behavior (functional testing plus security checks);
• implement monitoring and alerting.

Output: Change tickets, implementation runbooks, test results, and updated architecture diagrams.

5) If an external provider is involved, run third-party due diligence that matches the offload risk

Minimum expectations you should meet and document:

• Shared responsibility matrix: who owns what control outcomes (security, availability, backup, logging).
• Contract/SLA alignment: uptime and support expectations, incident notification, subcontractor controls.
• Assessment evidence: assurance reports or attestations accepted by your program, plus your review notes.
• Exit strategy: how you migrate away, recover data, and decommission access.

How Daydream fits: Daydream can track the PM-7(1) control owner, link the offloaded function to the third party record, and schedule recurring evidence requests so PM-7(1) stays “operating,” not just “designed.”

Output: Completed third-party review package tied to the PM-7(1) implementation record.

6) Prove ongoing operation (not a one-time project)

Assessors will test whether the offload stays in place and remains controlled:

• recurring review of architecture changes that could “pull” the function back into the primary system;
• periodic access reviews for the offloaded environment/provider;
• monitoring review evidence (alerts handled, incident tickets, trend reports).

Output: Operating evidence collected on a recurring cadence and stored with the PM-7(1) control record.

Required evidence and artifacts to retain

Keep artifacts in a single control evidence folder or GRC record so you can answer “show me” requests quickly.

Evidence item	What it should show	Owner
PM-7(1) control implementation statement with ODP filled in	What is offloaded and why 1	GRC / Control owner
Architecture diagrams (before/after)	The function moved to another system/component/provider	Architecture
ADR / design decision	Why this offload model was chosen	Architecture / Security
Change tickets + approvals	Controlled implementation and sign-offs	IT Ops / Engineering
Configuration evidence	Routing, IAM roles, network segmentation, logging destinations	Engineering
Test results	Offload works; security requirements validated	Engineering / Security
Third-party due diligence package (if external)	Shared responsibility, contractual coverage, assurance review	TPRM / Procurement
Monitoring + incident evidence	Ongoing oversight of the offloaded function	SecOps / SRE

Common exam/audit questions and hangups

Expect these, and pre-wire your evidence to answer them:

1. “What exactly is the pm-07.01_odp in your environment?”
   If you cannot name it precisely, you will fail the basics of the pm-7(1): offloading requirement ¹.

2. “Show me that it’s offloaded in production, not just planned.”
   Auditors look for current diagrams, live config snippets, and change records.

3. “Why is this offload secure?”
   Have your security requirements and validation results ready.

4. “If it’s an external provider, who is responsible for incident response, logging, and access control?”
   Bring a shared responsibility matrix plus contract/SLA excerpts and your due diligence notes ².

5. “How do you know the offload hasn’t drifted?”
   Answer with monitoring evidence and an architectural review trigger tied to change management.

Frequent implementation mistakes (and how to avoid them)

• Mistake: Leaving the ODP blank or vague.
  Fix: Put the offloaded function in plain terms, list system names, and define boundaries ¹.

• Mistake: Calling a refactor an “offload” without proving relocation.
  Fix: Show where the function runs now (system/component/provider), with diagrams and configs.

• Mistake: Offloading to a third party without updating risk ownership.
  Fix: Update control mappings, assign a service owner, and document shared responsibility ².

• Mistake: Evidence scattered across teams.
  Fix: Maintain a single PM-7(1) evidence index (Daydream or your GRC) linking tickets, diagrams, contracts, and test results.

• Mistake: No operational monitoring proof.
  Fix: Store monitoring review outputs, incident tickets, and alert routing documentation.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for PM-7(1), so you should treat this as an assessment-readiness and authorization risk rather than a control with a direct “fine-per-violation” pattern in the provided materials. The practical risk is that weak PM-7(1) implementation shows up as:

• architecture that concentrates critical functions in one failure domain;
• unclear accountability when third parties operate key functions;
• inability to demonstrate control operation during an ATO package review or independent assessment ².

Practical 30/60/90-day execution plan

Your fastest path is to align governance, architecture, and evidence in parallel.

First 30 days (Immediate)

• Assign a PM-7(1) control owner and name technical owners for the offloaded function.
• Define and approve the ODP: the exact function(s) to be offloaded and the scope boundary ¹.
• Build an evidence index: where diagrams, tickets, test results, and third-party records will live.
• If using an external provider, open the third-party intake (security review, contract requirements, exit needs).

By 60 days (Near-term)

• Complete the target architecture and ADR.
• Implement the offload in at least one environment (pilot or limited production), with controlled change records.
• Produce initial validation evidence: functional tests, access control checks, logging verification.
• For external providers: complete shared responsibility matrix and store the due diligence package with the control record.

By 90 days (Operationalize)

• Extend implementation to full scope (all in-scope systems/environments defined in the ODP).
• Establish recurring operations: monitoring review, access reviews, change triggers, and periodic evidence capture.
• Run an internal “mock audit” of PM-7(1): confirm traceability from ODP → architecture → config → monitoring.

Frequently Asked Questions

What counts as “offloading” for PM-7(1)?

Offloading means the defined PM-7(1) function runs on other systems, system components, or an external provider rather than the primary system boundary you started with ¹. You must be able to show where it runs now and how it is governed.

Do we have to offload to an external provider to meet the pm-7(1): offloading requirement?

No. The requirement allows offloading to other systems or system components as well as an external provider ¹. Choose the model that fits your architecture and risk rationale, then document it.

What should the organizationally defined parameter (pm-07.01_odp) look like in practice?

It should name the function(s) you will offload and define the scope boundaries clearly enough that an assessor can test implementation ¹. Avoid broad phrases like “critical workloads” without system names or service descriptions.

If we offload logging to a SaaS SIEM, what evidence should we keep?

Keep architecture diagrams showing log flows, configuration evidence for log forwarding, test evidence that logs arrive, and third-party due diligence artifacts for the provider ². Add monitoring evidence that alerts and ingestion health are reviewed.

How do auditors test PM-7(1) beyond documentation?

They usually trace from your PM-7(1) statement and ODP to live architecture/configuration and then to operating evidence (change management and monitoring). If the function still runs on the original system or there’s no proof it moved, the control will not pass ¹.

How can Daydream help without turning PM-7(1) into a paperwork exercise?

Use Daydream to assign ownership, map the offloaded function to the system and third party records, and collect recurring evidence (diagrams, tickets, assurance reports, monitoring reviews) so you can answer assessor requests from one control record.

Footnotes

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

2. NIST SP 800-53 Rev. 5