PM-14: Testing, Training, and Monitoring

PM-14: Testing, Training, and Monitoring requires you to run a documented, repeatable process that ensures your security and privacy testing, training, and continuous monitoring plans exist, stay current, and actually get executed across your systems. Operationalize it by assigning ownership, publishing an integrated calendar, tracking completion, and retaining evidence that plans drove real activities. ¹

Key takeaways:

• PM-14 is a governance control: it checks whether your org can plan, execute, and prove security/privacy testing, training, and monitoring. ¹
• Your fastest path is a single program-level process that ties system plans to a master schedule with named owners and recurring evidence. ²
• Audits typically fail PM-14 on missing artifacts and missed cadence, not on tooling sophistication. ¹

“pm-14: testing, training, and monitoring requirement” sits in the Program Management (PM) family in NIST SP 800-53 Rev. 5 and reads deceptively short. The practical expectation is not. You must show that your organization has a process that forces security and privacy testing, training, and monitoring work to be planned, scheduled, performed, and checked for completion across the systems you operate or manage. ¹

For a Compliance Officer, CCO, or GRC lead, PM-14 is about eliminating “we do this ad hoc” risk. If a penetration test slips, if privacy training becomes optional, or if continuous monitoring drifts into a dashboard no one reviews, PM-14 is the control that should catch it early and leave a paper trail. ¹

This page gives you requirement-level guidance to implement PM-14 quickly: who owns what, what to build, what evidence to keep, and how to handle the audit questions that routinely stall teams. Where helpful, it also notes how to structure the work so it can be maintained with normal operating rhythm, not heroic quarterly scrambles. ¹

Regulatory text

Control excerpt (verbatim): “Implement a process for ensuring that organizational plans for conducting security and privacy testing, training, and monitoring activities associated with organizational systems:” ²

Operator meaning: You need a defined process (not a one-time project) that ensures the organization has plans for testing, training, and monitoring tied to organizational systems, and that those plans drive execution. The control is explicitly security and privacy, so your process must cover both domains, even if different teams execute the work. ¹

What an assessor typically looks for under PM-14:

• A documented program-level procedure that governs how plans are created, updated, approved, scheduled, and tracked.
• Evidence that every in-scope system is covered by testing, training, and monitoring plans.
• Proof the plans are actually performed (completion artifacts) and that exceptions are managed. ¹

Plain-English interpretation

PM-14 requires you to run a “planning-to-execution” management loop for three activity types:

1. Testing (security and privacy testing as applicable),
2. Training (role-based and general awareness where relevant),
3. Monitoring (continuous monitoring activities tied to systems).

Your job is to make these activities predictable and auditable: who does them, when they happen, what “done” means, and how gaps get fixed. If you cannot show planning artifacts and completion evidence per system (or per defined system grouping), the control will read as not implemented or not operating effectively. ¹

Who it applies to

Entity scope (typical):

• Federal information systems and organizations implementing NIST SP 800-53 as a required control baseline. ¹
• Contractor systems handling federal data where NIST SP 800-53 controls are flowed down via contract, authorization boundaries, or customer requirements. ¹

Operational scope:

• Applies to the systems in your authorization boundary (or your defined system inventory for a program).
• Applies across IT, cloud, SaaS, OT/ICS where in scope, and shared services that materially support system security/privacy outcomes.
• Touches multiple functions: Security/GRC, Privacy, IT Operations/SRE, Engineering, HR/L&D (training delivery), and Internal Audit/QA for independent checks. ¹

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

Step 1: Name a PM-14 control owner and define the “process spine”

Create a short, enforceable PM-14 procedure that answers:

• Which systems are in scope (source of truth: system inventory).
• Which activity categories you treat as “testing,” “training,” and “monitoring.”
• How plans are created/updated and who approves them.
• How you schedule work (master calendar) and track completion.
• How you handle exceptions, slippage, and overdue work. ¹

Practical tip: put one accountable owner in GRC (or Security Program Management) and require named executors in Security, Privacy, and IT Ops.

Step 2: Build or validate system-level plans (minimum viable set)

For each in-scope system (or system group), ensure you have:

• Security & privacy testing plan: what tests happen, triggers (time-based or change-based), success criteria, and reporting path.
• Training plan: required trainings by role (engineers, admins, incident responders, privacy stakeholders), completion tracking, and enforcement mechanism.
• Monitoring plan: what you monitor (logs, alerts, vulnerabilities, config drift, privacy-relevant events), who reviews, and escalation. ¹

Avoid overproduction. Auditors want coverage and traceability more than a long narrative.

Step 3: Tie plans to an integrated master schedule

Create a single PM-14 schedule view (spreadsheet, GRC workflow, or ticketing calendar) that includes:

• System name / system owner
• Planned activity type (test/train/monitor)
• Planned window and recurrence
• Responsible team
• Evidence artifact expected
• Status (planned, in progress, complete, exception granted) ¹

This is the operational heart of PM-14. If you can show the schedule is reviewed and drives work intake, PM-14 becomes straightforward to defend.

Step 4: Execute and capture “completion proof” as you go

Define what counts as acceptable completion evidence for each activity class:

• Testing: test report, findings log, remediation tickets, retest record.
• Training: roster completion export, LMS certificate logs, manager attestations for role-based coverage.
• Monitoring: screenshots or exports of alert review, weekly/monthly review notes, vulnerability scan results with triage notes, exception records. ¹

Attach artifacts to the schedule item (or cross-reference in a repository) so audits become retrieval, not archaeology.

Step 5: Run a recurring governance review (make it real)

Hold a periodic PM-14 review (cadence is your design choice) that covers:

• What was scheduled vs. completed
• What is overdue and why
• High-risk exceptions and compensating controls
• Trends: repeated slippage, recurring findings, training non-completion ¹

Document minutes and actions. This becomes strong operational evidence that the process “ensures” plans are carried out, which is the key word in the requirement excerpt. ²

Step 6: Map PM-14 to owner, procedure, and recurring evidence (assessment-ready packaging)

Create a one-page control card (or GRC control record) that states:

• Control statement (PM-14)
• Owner and delegates
• Where the procedure lives
• Where the schedule lives
• Evidence list and retention location
• How exceptions are approved ¹

If you use Daydream, this is where it fits naturally: keep a single system-of-record that ties PM-14 ownership, tasks, and recurring evidence requests to each system and responsible team, so you stop chasing artifacts by email.

Required evidence and artifacts to retain

Keep artifacts that prove design and operation:

Design evidence (what exists):

• PM-14 procedure (approved, versioned)
• System inventory or boundary list used for scope
• Testing plan templates and completed plans per system/group
• Training matrix by role and required courses
• Monitoring plan per system/group ¹

Operating evidence (what happened):

• Master schedule with status history
• Completed test reports and remediation tracking
• Training completion exports/attestations
• Monitoring review records (tickets, review notes, alert triage logs)
• Exception requests/approvals and closure evidence ¹

Retention period is a program decision; pick one and apply it consistently.

Common exam/audit questions and hangups

Expect these questions and prep short, evidence-backed answers:

• “Show me how you ensure every system has testing, training, and monitoring planned.” Provide inventory-to-plan mapping plus the master schedule. ¹
• “How do you know planned activities happened?” Show schedule status changes linked to artifacts. ¹
• “Who approves exceptions and how do you track overdue items?” Show exception workflow and governance minutes. ¹
• “Where is privacy in this process?” Show privacy testing/training/monitoring elements explicitly, not implied under security. ¹

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails PM-14	Fix
Plans exist but no schedule	You cannot show the process “ensures” execution	Publish a master schedule tied to system inventory 1
Schedule exists but no proof	Auditors treat it as intent, not operation	Define evidence per activity and attach it every cycle 1
Security covers everything, privacy absent	Control is explicit on privacy	Add privacy-specific plan elements and reviewers 1
Ownership is “shared”	No accountability for slippage	Name a single control owner and clear RACI 1
Monitoring is a tool, not a process	Dashboards don’t prove review and response	Document review cadence, escalation, and records 1

Enforcement context and risk implications

No public enforcement cases were provided in the supplied source catalog for this requirement, so this page does not cite specific actions or penalties.

Risk implication in plain terms: PM-14 failures usually show up as missed testing windows, incomplete training coverage, or unreviewed monitoring outputs. Those gaps increase the chance that known weaknesses persist and that incidents go undetected or mishandled. From an assessment standpoint, PM-14 gaps also create a “program credibility” problem: assessors may question whether other planned controls are operating if you cannot prove your test/train/monitor machinery works. ¹

Practical 30/60/90-day execution plan

First 30 days (stabilize the process)

• Assign PM-14 owner and backups; document the PM-14 procedure and approval path. ¹
• Confirm in-scope system inventory and identify system owners.
• Create the master schedule structure and required evidence list per activity type.
• Pick the evidence repository model (GRC tool, ticketing attachments, or controlled document store) and enforce naming conventions.

Days 31–60 (complete coverage and start operating)

• Produce or normalize testing/training/monitoring plans for each system or system group. ¹
• Populate the schedule with planned activities and owners.
• Run one governance review cycle; document outcomes and exceptions.
• Start collecting completion artifacts for the first wave of activities.

Days 61–90 (prove repeatability and audit readiness)

• Close gaps: missing systems, missing privacy elements, weak evidence definitions. ¹
• Run a second governance review cycle and demonstrate trend tracking (overdue items, exceptions, recurring findings).
• Perform an internal “PM-14 drill”: select a system and produce end-to-end proof within a single working session (plan → schedule item → evidence → exception handling).
• If you need to scale, configure Daydream (or your GRC system) to issue recurring evidence requests and automate reminders tied to the master schedule.

Frequently Asked Questions

Does PM-14 require penetration testing?

PM-14 requires a process that ensures you have plans for security and privacy testing and that those plans drive execution. The specific tests you include depend on your program decisions and system risk, but you must be able to show planned testing and completion evidence. ¹

Can we satisfy PM-14 with a single enterprise plan, or do we need system-level plans?

You can use an enterprise approach if it clearly covers each in-scope system and you can map activities to systems in a way an auditor can follow. Most teams keep a program-level procedure plus system-level plan elements to preserve traceability. ¹

What counts as “monitoring” evidence for PM-14?

Evidence should show both the monitoring output and that a person or process reviewed it and acted when needed. Tickets, review notes, triage logs, and escalation records usually work better than a dashboard screenshot alone. ¹

Where does privacy fit if we have a separate privacy office?

PM-14 still expects your organization to plan and carry out privacy testing, training, and monitoring activities associated with systems. Treat Privacy as a required stakeholder in the PM-14 process, with explicit plan elements and evidence owners. ¹

How do we handle missed activities without failing the control?

Define an exception process with documented rationale, approval, compensating controls, and a rescheduled date or closure condition. Auditors generally tolerate exceptions that are governed and tracked; they flag silent slippage. ¹

We already have an LMS and SIEM. Why do auditors still flag PM-14?

Tools show capability, not governance. PM-14 expects a process that ties system plans to scheduled activities and produces auditable proof of completion and oversight. Package the process, schedule, and artifacts so the story is easy to verify. ¹

Footnotes

1. NIST SP 800-53 Rev. 5

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