RA-5: Vulnerability Monitoring and Scanning

RA-5: vulnerability monitoring and scanning requirement means you must continuously monitor and scan your systems and hosted applications for vulnerabilities, and run targeted scanning when new vulnerabilities are identified that could affect you. To operationalize it fast, define scan scope and cadence, integrate threat/vuln intelligence triggers, enforce remediation SLAs, and retain scan-to-fix evidence for audits. ¹

Key takeaways:

• Define a complete, owned scan scope (assets + hosted applications) and prove coverage with inventories and scan logs.
• Treat “newly identified vulnerabilities” as a trigger for out-of-cycle scanning, not just a weekly/monthly routine.
• Evidence is the control: auditors will ask for scan outputs, exception handling, and remediation verification tied to tickets.

A RA-5 program fails in predictable ways: scanners run, but critical assets are missing; findings exist, but remediation is informal; “we scan monthly” is true, but there is no response when a high-profile vulnerability drops. RA-5: vulnerability monitoring and scanning requirement is designed to close those gaps by forcing two operational motions: (1) routine monitoring/scanning across the environment and hosted applications, and (2) event-driven scanning when new vulnerabilities are reported that may apply to you. ¹

For a Compliance Officer, CCO, or GRC lead, the fastest path to readiness is to treat RA-5 as a workflow and evidence problem, not a tooling problem. You need a named control owner, an implementation procedure people can follow, and recurring artifacts that show the procedure ran, found issues, and drove fixes. NIST’s control language is short; your job is to translate it into a repeatable operating model that survives audits, staff turnover, and platform changes. ²

Regulatory text

Requirement (excerpt): “Monitor and scan for vulnerabilities in the system and hosted applications … and when new vulnerabilities potentially affecting the system are identified and reported.” ¹

Operator interpretation (what you must do):

1. Establish ongoing vulnerability monitoring and scanning across your system boundary, including hosted applications (your apps running on-prem, in cloud, and in third-party-hosted environments where you have responsibility). ¹
2. Add an event-driven trigger: when credible sources report a new vulnerability that may affect your technology stack, you must evaluate applicability and, if relevant, scan or otherwise assess exposure promptly rather than waiting for the next scheduled scan. ¹
3. Prove it happened: retain evidence that scans covered the defined scope, findings were tracked, remediation was verified, and exceptions were approved and time-bounded.

Plain-English interpretation (what RA-5 is really asking)

RA-5 expects you to run vulnerability scanning as an operational control with three properties:

• Coverage: you know what assets and applications exist, and scanning reaches them.
• Cadence plus triggers: scans run on a defined schedule, and you have a “break glass” process for newly reported vulnerabilities.
• Closure: you track findings to remediation (or formal risk acceptance) and confirm fixes worked.

If your team can’t answer “what was scanned, what was found, what did we fix, and what remains open (with approval)?” you will struggle to demonstrate RA-5.

Who it applies to (entity + operational context)

RA-5 applies wherever you implement NIST SP 800-53 controls, including:

• Federal information systems.
• Contractor systems handling federal data, including environments used to process, store, or transmit federal information. ¹

Operationally, it touches multiple teams and environments:

• Infrastructure: endpoints, servers, network devices, containers, and cloud resources.
• Application owners: hosted applications, supporting services, and dependencies.
• Security operations / vulnerability management: scanner operations, triage, and reporting.
• IT operations / engineering: patching, configuration changes, and change management.
• Third party owners: where hosted applications or infrastructure are operated by a third party, your RA-5 approach must specify responsibility splits and evidence collection expectations.

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

Use this as a requirement-level implementation checklist. Write it into a procedure and assign owners.

1) Assign ownership and define the control boundary

• Name a control owner (often Vulnerability Management lead) and supporting owners (Cloud, Infra, AppSec, IT Ops).
• Define the system boundary in plain terms (environments, accounts/subscriptions, VPC/VNet ranges, SaaS components that host your application, CI/CD tooling that can introduce vulnerable code).
• Confirm hosted application responsibility: identify what you can scan directly vs. what you must obtain from a third party (attestations, scan reports, pen test summaries).

Daydream note (earned mention): Many teams lose time proving ownership and recurring evidence. Daydream can help you map RA-5 to an owner, a written procedure, and a recurring evidence checklist so the audit packet is assembled continuously rather than at year-end. ¹

2) Build your scan scope from inventories (not from the scanner)

• Establish/confirm an asset inventory for infrastructure and a service/application inventory for hosted applications.
• Map each inventory item to:
  • environment (prod/non-prod),
  • data sensitivity,
  • owner,
  • scanning method (authenticated scan, agent-based, container image scan, SCA for dependencies, etc.),
  • scan frequency and trigger conditions.

Goal: auditors can compare inventory → scan targets → scan results and see nothing material is missing.

3) Define scanning methods and minimum expectations

Document which techniques you will use and where:

• Authenticated vulnerability scanning for servers where feasible (reduces false positives and improves coverage).
• Endpoint/agent telemetry where network scanning is unreliable (remote workforce, ephemeral assets).
• Web application scanning for externally exposed hosted applications you operate.
• Container image and IaC scanning in CI/CD for modern stacks.
• Dependency scanning (SCA) for application libraries.

RA-5 does not prescribe tools; it requires that monitoring/scanning exists and is repeatable. ¹

4) Set cadence and “new vulnerability” triggers

You need two schedules:

• Routine schedule: your standard recurring scans by asset class and environment.
• Event-driven schedule: explicit triggers, such as:
  • vendor security advisories affecting your products,
  • high-impact vulnerability disclosures relevant to your stack,
  • third party notifications about exposure in hosted components.

Operationalize triggers with a simple decision record:

1. Is the vulnerability applicable (product/version present)?
2. Is the affected component in scope for this system boundary?
3. What is the exposure (internet-facing, privileged, lateral movement)?
4. What action occurs (out-of-cycle scan, configuration review, emergency patch, compensating control)?

Retain the decision record even when you decide “not applicable.” That is exam gold.

5) Triage findings and drive remediation to closure

Define a workflow from scanner output to tickets:

• Ingest findings into a tracking system (ticketing, vulnerability platform, or GRC workflow).
• Assign each finding:
  • asset/application,
  • owner,
  • severity and rationale,
  • due date (your internal SLA),
  • remediation plan.

Require verification:

• Re-scan affected assets or confirm remediation through another reliable method (package version validation, configuration check, image rebuild evidence).
• Mark tickets “done” only with verification evidence attached.

6) Manage exceptions (risk acceptance) with discipline

You will have legitimate constraints (legacy systems, vendor-managed components). Treat exceptions as controlled outcomes:

• Require documented approval (risk owner), business justification, compensating controls, and an expiration/review date.
• Tie exceptions to the specific finding(s) and assets.
• Include exceptions in periodic reporting to avoid “permanent waivers.”

7) Report and govern

Produce a recurring management report that answers:

• What coverage did we achieve vs. inventory?
• What high-risk findings are open, and why?
• What exceptions exist and when do they expire?
• What event-driven scans occurred due to newly reported vulnerabilities?

This makes RA-5 defensible under scrutiny.

Required evidence and artifacts to retain

Auditors test RA-5 by sampling. Keep artifacts that survive sampling.

Core artifacts (minimum viable audit packet):

• Vulnerability management policy and RA-5 procedure (owned, versioned).
• Asset and application inventories with owners and scan methods.
• Scanner configuration/export showing scan targets, schedules, and credentials approach (where appropriate).
• Scan outputs (reports/dashboards) showing dates, scope, and results.
• Tickets/work items for sampled findings with:
  • assignment,
  • remediation actions,
  • verification evidence,
  • closure date.
• Event-driven “new vulnerability” decision records and resulting actions (out-of-cycle scans, emergency changes).
• Exception approvals with compensating controls and review cadence.

Common exam/audit questions and hangups

Expect questions like:

• “Show me how you know all in-scope assets are scanned.” (Inventory-to-scan reconciliation)
• “Which hosted applications are covered, and how?” (App inventory + scanning method)
• “What do you do when a new vulnerability is reported?” (Trigger workflow + evidence)
• “Demonstrate remediation verification for this sample of critical findings.” (Proof of fix, not just a ticket status)
• “How do you handle assets that cannot be scanned?” (Exception process + compensating controls)

Hangup: teams present scanner dashboards without proving completeness or closure.

Frequent implementation mistakes (and how to avoid them)

1. Scanning without an inventory. Fix: make inventory the source of truth; reconcile monthly.
2. Uncredentialed scans only. Fix: document where authenticated scanning is required and where agents fill gaps.
3. No event-driven process. Fix: define triggers and keep “not applicable” decisions. ¹
4. Tickets closed without verification. Fix: require re-scan evidence or validated configuration/package proof.
5. Third party hosting treated as out of scope. Fix: document responsibility splits and require evidence from third parties that host components of your application.

Enforcement context and risk implications

No public enforcement cases were provided in the source material for RA-5. Practically, RA-5 failures surface as control deficiencies during assessments because they are easy to test: auditors can compare inventories to scan logs and sample remediation records. The risk is straightforward: unscanned or unremediated vulnerabilities remain exploitable, and your organization lacks proof that it can identify and respond to newly disclosed issues in its environment. ¹

A practical 30/60/90-day execution plan

Use this as an execution plan template; adjust sequencing to your change control realities.

First 30 days (stabilize and prove coverage basics)

• Assign RA-5 owner(s) and publish an RA-5 procedure aligned to your system boundary. ¹
• Build or validate asset + hosted application inventories with owners.
• Document scan methods per asset class and identify “cannot scan” populations.
• Start retaining immutable evidence: scan exports, schedules, and initial findings.

By 60 days (operationalize triggers and remediation workflow)

• Implement event-driven intake for newly reported vulnerabilities (advisory monitoring, internal notification channel, decision record template). ¹
• Integrate findings to tickets with required fields (owner, due date, verification).
• Stand up an exceptions process with approvals, compensating controls, and expirations.
• Produce the first management report that ties coverage, open risk, and exceptions.

By 90 days (make it audit-ready and repeatable)

• Run a self-assessment: sample assets, trace inventory → scan → ticket → verification.
• Fix systematic gaps (credential coverage, missing networks/accounts, app scanning gaps).
• Formalize recurring evidence collection (monthly packet) so RA-5 stays current.

Frequently Asked Questions

What counts as “hosted applications” under RA-5?

Treat it as applications you run that are hosted on-prem, in cloud infrastructure, or in environments operated by a third party where you still own security outcomes. Your procedure should state which parts you scan directly and what evidence you require from third parties. ¹

Do we need continuous scanning, or is periodic scanning enough?

RA-5 requires you to “monitor and scan,” which you can meet with a defined recurring cadence plus monitoring signals that create out-of-cycle actions. The audit risk is claiming monitoring without being able to show events, triggers, and follow-through. ¹

How do we prove we scanned “the system” if assets are ephemeral (autoscaling, containers)?

Prove coverage through inventory and build pipeline evidence: show that new assets inherit agents, baseline configurations, or are discovered and scanned automatically. Retain logs that demonstrate scanning/assessment of the underlying images and runtime instances.

What if a third party refuses to provide scan reports for a hosted component?

Document the responsibility boundary and capture what you can obtain (attestations, SOC reports, contractual security exhibits), then file a risk exception for the missing RA-5 evidence and track it to closure. Put the remediation plan on the relationship owner, not security alone.

Do we have to remediate every vulnerability to satisfy RA-5?

RA-5 is about monitoring and scanning; auditors still expect you to track findings through remediation or formal risk acceptance with compensating controls. Your evidence must show governance over open items, not just raw scan output. ¹

What’s the fastest way to get audit-ready evidence without buying new tools?

Standardize the workflow: inventory → scheduled scans → ticketing → verification → exception handling. Daydream can help you map RA-5 to an owner, a written procedure, and recurring evidence artifacts so you can produce a consistent audit packet on demand. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5