PM-31: Continuous Monitoring Strategy

PM-31 requires you to define an organization-wide continuous monitoring strategy and run continuous monitoring programs that produce timely, repeatable security status information for decision-makers. To operationalize it, assign ownership, inventory what you will monitor, set monitoring frequencies and thresholds, automate collection where possible, and retain evidence that monitoring occurs and drives remediation ¹.

Key takeaways:

• Write a single enterprise strategy that governs monitoring across systems, not tool-by-tool documentation ¹.
• Tie monitoring outputs to decisions: risk acceptance, prioritization, POA&M updates, and authorizing official briefings.
• Evidence must show ongoing operation: schedules, dashboards, tickets, and management reporting, not just a policy.

The pm-31: continuous monitoring strategy requirement is easy to “say yes” to and still fail in an assessment. Auditors rarely challenge whether you own a scanner or have a SIEM; they challenge whether you have an organization-wide strategy that drives consistent monitoring outcomes, with defined cadence, accountable owners, and proof that findings result in tracked remediation. PM-31 sits at the program-management layer in NIST SP 800-53 Rev. 5, so the expectation is enterprise governance: common definitions, common measures, and consistent reporting across the portfolio ².

For a CCO, GRC lead, or security compliance operator, the fastest path is to treat PM-31 as a “monitoring operating model” requirement. Your deliverable is a strategy document plus an operational program: what gets monitored, by whom, how often, with what tools, what thresholds trigger action, how exceptions are handled, and how results roll up to risk governance. If you already run vulnerability management, logging/alerting, and configuration monitoring, PM-31 is the glue that makes those activities assessable and decision-grade.

Regulatory text

Requirement excerpt: “Develop an organization-wide continuous monitoring strategy and implement continuous monitoring programs that include:” ¹

Operator meaning: PM-31 expects (1) a documented, enterprise strategy and (2) implemented monitoring programs aligned to that strategy. An assessor will look for governance-level design decisions (scope, roles, cadence, reporting) and operational proof (recurring monitoring outputs and follow-through) ¹.

What to do with the trailing “include:” language: treat it as a prompt that your strategy must enumerate the core elements of your program. If your strategy is a two-page memo without operational specifics, you will struggle to demonstrate implementation.

Plain-English interpretation

PM-31 requires you to run security monitoring as a managed program, not a set of disconnected tool outputs. You must be able to answer, consistently across the organization:

• What are we monitoring (assets, controls, and risk signals)?
• How do we monitor (methods and tools)?
• How often do we monitor (cadence by risk)?
• Who acts on the results (owners and escalation)?
• How do results change risk decisions (accept, mitigate, transfer, stop)?
• How do we prove it happened (evidence trail)?

Who it applies to (entity and operational context)

PM-31 commonly applies where NIST SP 800-53 is the governing control baseline, including:

• Federal information systems operating under NIST SP 800-53 expectations ².
• Contractor systems handling federal data where 800-53 controls are flowed down contractually or used for authorization packages ².

Operationally, PM-31 is owned by a GRC program in partnership with Security Operations, IT operations, and system owners. If your environment includes major SaaS dependencies, treat key third parties as monitoring inputs as well (for example: uptime/status events, security advisories, and evidence of patch cadence), but keep the PM-31 strategy focused on your organization’s monitoring program and governance.

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

1) Name a PM-31 owner and define program governance

• Assign a single accountable owner (often GRC or security program management).
• Define RACI for: asset owners, tool owners (SIEM/EDR/scanners), remediation owners, and approvers for risk acceptance.
• Set the management forum where monitoring results are reviewed (security steering, risk committee, ATO governance).

Fast check: If you cannot identify who approves monitoring scope changes, you do not yet have an “organization-wide strategy.”

2) Define monitoring scope using an asset-and-risk lens

Create a monitored population definition that is consistent across the enterprise:

• Systems in scope (production, corporate IT, cloud accounts, enclaves)
• Asset classes (endpoints, servers, identities, network devices, containers, SaaS admin consoles)
• High-value assets and mission-critical services (if applicable)

Then map “what we monitor” to control-relevant signals, such as:

• Vulnerability exposure (scan results, missing patches)
• Secure configuration drift (benchmarks, policy-as-code results)
• Identity risk (privileged access changes, MFA coverage, dormant accounts)
• Logging/alerting health (log sources connected, gaps, alert backlog)
• Backup/restore signals (job failures, restore tests where applicable)
• Change management signals (unauthorized changes, emergency changes)

3) Set cadences, thresholds, and triggers

Your strategy needs operational decision rules. Document:

• Monitoring frequency by asset criticality (e.g., “higher-criticality assets monitored more frequently” rather than one-size-fits-all).
• Thresholds that trigger action (e.g., “critical vulnerabilities require expedited remediation or documented risk acceptance”).
• “Break-glass” events that force immediate review (e.g., active exploitation advisories affecting in-scope tech stacks).

Avoid over-promising. If you document a cadence you cannot meet, PM-31 becomes a self-inflicted finding.

4) Standardize data flow from tools to issues to risk decisions

PM-31 assessments often fail at the handoff points. Build a simple pipeline:

• Collect: scanners/EDR/SIEM/config tools and service management exports
• Normalize: consistent severity taxonomy and asset identifiers
• Route: tickets to remediation owners with due dates or SLAs (your internal targets)
• Decide: exceptions handled through risk acceptance with documented rationale
• Report: rollups by system, business unit, and enterprise

If you use Daydream, this is where it fits cleanly: map PM-31 to control owners, implementation procedures, and recurring evidence artifacts so your “monitoring operating model” is always assessment-ready and not rebuilt during audit season ¹.

5) Implement continuous monitoring programs per system (and tie them back to the enterprise strategy)

You need two layers of implementation:

• Enterprise strategy: the common rules of the road.
• System-level continuous monitoring plan: what this system monitors, which tools apply, the system owner’s review cadence, and the system’s reporting path.

This prevents the common gap where security operations monitors “everything,” but system owners cannot demonstrate their review and response responsibilities.

6) Prove it works: recurring review, metrics, and corrective actions

Operate the program:

• Hold recurring triage and remediation meetings.
• Produce periodic status reports to leadership.
• Track remediation progress and aging.
• Update POA&Ms (or equivalent corrective action registers) based on monitoring outputs.
• Adjust monitoring when the environment changes (new cloud accounts, new SaaS, M&A).

Required evidence and artifacts to retain

Keep evidence in a way that is easy to sample. A strong PM-31 evidence set usually includes:

Artifact	What an auditor expects to see	Owner
Continuous Monitoring Strategy (enterprise)	Scope, roles, cadence model, thresholds, reporting, exception handling 1	GRC/Security Program
System-level monitoring plans	System-specific sources, reviews, and escalation	System Owner
Monitoring schedules/calendars	Proof the cadence is planned and repeatable	Program Owner
Tool outputs (exports/screenshots)	Scan runs, SIEM health, EDR coverage, config drift summaries	Tool Owner
Ticket samples	Findings routed, assigned, tracked, closed	IT/SecOps
Exception/risk acceptance records	Rationale, approver, expiry/review date	Risk/GRC
Management reporting	Dashboards/briefings showing trend and action	CISO/GRC
Change records for monitoring	Adding/removing log sources, tuning rules, new scan scopes	SecOps

Common exam/audit questions and hangups

Assessors tend to probe these areas:

1. “Show me the strategy.” They want an organization-wide document, not a tool admin guide ¹.
2. “How do you decide what gets monitored more often?” You need a risk-based rationale (criticality tiers, data sensitivity, exposure).
3. “Prove it’s continuous.” They will sample dates. One quarterly report with no intermediate evidence reads as ad hoc.
4. “What happens when you can’t remediate?” You need an exception path with approval and review.
5. “Do system owners review results?” Central SecOps outputs alone are not enough if governance assigns responsibility elsewhere.
6. “How do monitoring results affect risk posture?” Point to POA&M updates, risk register entries, and leadership reporting.

Frequent implementation mistakes and how to avoid them

• Mistake: Writing a policy that says “we do continuous monitoring” with no operating details.
  Fix: Add scope, cadence, thresholds, reporting, and exception handling as enforceable program rules.

• Mistake: Treating tool coverage as monitoring.
  Fix: Evidence must include review and action. Keep meeting notes, ticket samples, and approvals.

• Mistake: One cadence for everything.
  Fix: Define tiers. High-risk assets get tighter monitoring and faster response; low-risk assets follow a lighter cadence.

• Mistake: No asset identity consistency across tools.
  Fix: Standardize naming/CMDB identifiers so findings can be routed and aggregated.

• Mistake: Exceptions live in email.
  Fix: Use a tracked workflow with approver, rationale, and re-review triggers.

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat PM-31 primarily as an assessment and authorization readiness requirement rather than a standalone enforcement hook. The risk is practical: weak continuous monitoring leads to delayed detection, unmanaged exposure, and an inability to demonstrate control effectiveness during audits or ATO reviews ².

A practical 30/60/90-day execution plan

First 30 days (stabilize and document)

• Assign PM-31 owner and publish RACI.
• Draft the enterprise continuous monitoring strategy outline (scope, roles, cadence tiers, thresholds, reporting).
• Inventory monitoring inputs and current tooling coverage; list known gaps.
• Define evidence standards (what to save, where, and who is responsible).

Days 31–60 (operationalize and connect the workflow)

• Finalize the strategy and get formal approval.
• Create system-level monitoring plan templates; pilot with a few high-impact systems.
• Connect monitoring outputs to ticketing and risk acceptance workflows.
• Stand up a recurring reporting pack (enterprise and system rollups).

Days 61–90 (prove repeatability and readiness)

• Run at least one full monitoring cycle per cadence tier and retain evidence.
• Validate sampling readiness: pick a system and walk an auditor through end-to-end evidence (signal → ticket → remediation/exception → reporting).
• Tune thresholds and reduce noise; document rationale for changes.
• Use Daydream (or your GRC system) to map PM-31 to control owners, procedures, and recurring evidence artifacts so evidence collection is automatic and consistent ¹.

Frequently Asked Questions

Do we need a separate PM-31 strategy if we already have vulnerability management and SIEM procedures?

Yes. PM-31 expects an organization-wide strategy that governs the overall monitoring program across domains and systems, then implemented monitoring programs aligned to it ¹.

What’s the minimum “proof” that continuous monitoring is operating?

Keep time-stamped monitoring outputs plus evidence of review and action, such as tickets, meeting notes, and exception approvals. Auditors want to see repeatability, not a one-time screenshot.

Who should own PM-31: GRC or SecOps?

GRC typically owns the strategy and evidence model, while SecOps owns many monitoring tools and triage workflows. System owners must be accountable for system-level review and remediation paths.

How do we handle monitoring for SaaS and other third parties?

Treat third-party signals as inputs: security advisories, status events, access logs, and contractually required reports. Document how you ingest those signals and who reviews them, but keep the PM-31 strategy centered on your organization’s monitoring governance.

What if we can’t meet the cadence we want for all assets?

Write a tiered cadence model based on risk and resource constraints, then operate consistently against it. Document exceptions and the plan to expand coverage as capacity improves.

How do we map PM-31 to evidence so we’re ready for audits year-round?

Maintain a control-to-evidence matrix: control owner, procedure, cadence, systems in scope, and required artifacts per cycle. Daydream can maintain this mapping and prompt recurring evidence collection ¹.

Footnotes

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

2. NIST SP 800-53 Rev. 5