RA-5(6): Automated Trend Analyses

RA-5(6): automated trend analyses requirement is a vulnerability management maturity control. Many programs can run scanners; fewer can prove they consistently compare scan results over time in a way that management can act on. This enhancement closes that gap by pushing you from “we scanned” to “we can measure whether risk is improving or drifting.”

For a CCO, GRC lead, or security compliance owner, the fastest path is to treat RA-5(6) as a data and reporting control: normalize scan data, maintain history, automate comparisons, and operationalize outputs into tickets, SLAs, and executive risk reporting. You do not need perfect analytics on day one. You need a repeatable pipeline that creates credible trend evidence and drives decisions (for example, identifying recurring criticals on the same asset class, or vulnerability age increasing in a particular environment).

This page gives you requirement-level steps, the minimum artifact set to retain, and the audit questions that typically surface, so you can implement quickly and defend it during assessment.

Regulatory text

Requirement excerpt: “Compare the results of multiple vulnerability scans using {{ insert: param, ra-05.06_odp }}.” ¹

What the operator must do: You need a mechanism (normally your vuln management platform, SIEM, or GRC reporting layer) that automatically compares outputs from more than one scan run to identify trends. “Compare” is the operative word: the assessor will expect you to show what changed between scans and what the changes mean for risk and remediation. ¹

Plain-English interpretation

RA-5(6) means your organization must:

1. retain results from multiple vulnerability scans,
2. automatically compare them, and
3. produce trend insights you can use to manage risk.

Trend analysis can be as simple as “new vs. closed vs. recurring findings by severity over time,” as long as it is automated and repeatable. The output should let a reviewer see whether exposure is improving, degrading, or stuck, and where to intervene.

Who it applies to (entity and operational context)

This control enhancement commonly applies where NIST SP 800-53 is the governing framework, including:

• Federal information systems implementing NIST SP 800-53 controls. ²
• Contractor systems handling federal data, where contract terms flow down NIST SP 800-53 expectations (often via agency overlays and system security plans). ²

Operationally, RA-5(6) applies anywhere you run vulnerability scanning, including:

• Servers, endpoints, network devices, databases
• Cloud workloads and container images
• External attack surface and internet-facing assets
• Third-party-hosted environments that are in your authorization boundary or contractual scope

If your boundary includes third parties (managed service providers, SaaS platforms with scanning rights, hosting providers), RA-5(6) becomes a shared-responsibility execution problem. Your contracts and technical access determine whether you can capture scan history and compare results consistently.

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

1) Define the comparison unit and scope

Pick the units you will trend, then keep them stable:

• Asset identity: hostname, instance ID, device ID, or cloud resource ID
• Finding identity: scanner plugin ID/CVE, package name+version, or rule identifier
• Environment tags: prod/non-prod, business unit, system, boundary, owner

Decision point: if your asset inventory is unreliable, your trends will be noise. Establish the “source of truth” asset identifiers you will use in scan exports and reports.

2) Standardize scan configurations so results are comparable

Comparisons fail when scans differ. Lock down:

• Scan policy templates (auth vs. unauth, port ranges, checks enabled)
• Credential strategy (where permitted)
• Exclusion rules (and the approval path for exclusions)
• Tagging conventions (so “prod” means the same thing every time)

Keep a controlled change process for scan templates. If you change templates, note it in the trend report so a spike in findings is not misread as deteriorating security posture.

3) Centralize and retain scan results with history

You need historical scan data to compare. Do one of the following:

• Use a vuln management tool that stores scan history and supports trending, or
• Export scan results after each run to a centralized repository (data lake, SIEM index, or ticketing data warehouse) with immutable retention controls.

Minimum data elements to retain per scan run:

• Scan date/time, target scope, scanner/policy version
• Asset identifiers and tags
• Finding identifiers (CVE/plugin/rule), severity, status, detection proof
• Exception status (accepted risk, false positive, compensating control reference)

4) Implement automated comparisons (“diff”) across scans

Automation means the comparison happens without manual spreadsheet stitching. Typical automated comparisons:

• New findings: not present in prior scan for that asset
• Closed findings: present prior, absent now
• Recurring findings: present across multiple scans
• Reopened findings: closed previously, now detected again
• Aging: time since first detected (requires history)

A practical implementation: scheduled jobs that generate weekly/monthly trend outputs and push them to a report repository and to stakeholders (security leads, system owners). The key is repeatability and auditability.

5) Translate trend outputs into action

RA-5(6) is weak if trends do not change behavior. Wire trends into:

• Ticket creation and prioritization (new criticals, aging high findings)
• “Top recurring vulnerabilities” root cause work (patch process gaps, hardening drift)
• Exception governance (expiring accepted risks, repeated false positives)
• Management reporting (risk posture movement by system/owner/environment)

Document who reviews trend reports, how often, and what decisions are expected (approve remediation plan, accept risk, escalate).

6) Handle third-party and boundary constraints explicitly

If a third party runs scans or controls key systems:

• Require delivery of scan outputs in a consistent format, on a consistent cadence
• Require enough metadata to trend (asset IDs, timestamps, rule/CVE identifiers)
• Define dispute handling (false positives, compensating controls)
• Record when scanning is not possible and what alternative evidence you use

This is a common audit hangup: “We can’t scan that environment” is acceptable only if you can show a documented boundary decision and a compensating process for risk visibility.

Required evidence and artifacts to retain

Auditors want to see operational proof that comparisons occur and drive action. Retain:

Core artifacts (keep current and historical)

• Procedure/SOP: how scans are collected, stored, compared, reported; roles and responsibilities mapped to RA-5(6). ¹
• Tool configuration evidence: scan policy templates, scheduling configs, export jobs, and change history.
• Trend reports: generated outputs showing comparisons across multiple scans (new/closed/recurring, by severity/system/owner).
• Raw scan outputs: at least enough history to demonstrate “multiple” scan comparisons for sampled systems.
• Remediation linkage: tickets, change records, or patch evidence tied back to trends (e.g., “recurring finding category resolved by baseline update”).
• Exceptions register: accepted risks, false-positive determinations, expiration dates, and approvals tied to findings.

Optional but high-value artifacts

• Dashboard screenshots with timestamps
• Metric definitions (what counts as “new,” how duplicates are deduped)
• Data dictionary / mapping logic between scanner IDs and asset inventory

Common exam/audit questions and hangups

Expect these questions in a NIST 800-53 assessment:

• “Show me two or more scan cycles and the automated comparison output for this system.”
• “How do you ensure the scans are comparable? What changes between runs?”
• “How do you deduplicate findings across rescans and asset name changes?”
• “What trends do you review with leadership, and what actions resulted?”
• “How do you incorporate third-party hosted assets or SaaS results into trending?”
• “Where is your evidence that comparisons are automated rather than manual?”

Hangup pattern: teams produce a monthly dashboard but cannot prove underlying scan scope consistency or cannot reproduce the same trend output for an auditor-selected sample.

Frequent implementation mistakes and how to avoid them

1. Manual spreadsheet trending.
   Fix: schedule tool-native trend reports or automated exports plus scripted comparisons, and retain logs of scheduled runs.

2. Changing scope every scan without tracking.
   Fix: version your scan target lists and templates; annotate trend reports when scope changes.

3. No stable asset identifiers.
   Fix: enforce tags/IDs from your CMDB or cloud inventory; normalize hostnames and instance IDs before trending.

4. Trends without decisions.
   Fix: define a standing review meeting or workflow where trend outputs create tickets, escalations, or risk acceptances.

5. Ignoring “reopened” and “recurring” signals.
   Fix: track recurrence as a quality metric for patching and configuration management; require root cause analysis for repeat categories.

Enforcement context and risk implications

No public enforcement cases were provided for this specific enhancement in the supplied source material, so this page does not cite case law or settlements.

Risk-wise, RA-5(6) is often tested as an indicator of whether vulnerability management is operating as a control versus a periodic activity. Weak trending usually correlates with missed systemic issues: patch process breakdowns, unmanaged asset growth, repeated configuration drift, and ineffective exception governance.

Practical 30/60/90-day execution plan

First 30 days (stand up the minimum viable trend pipeline)

• Assign a control owner and document the RA-5(6) procedure and evidence list. ¹
• Freeze or standardize scan templates for core environments.
• Confirm you can retain scan results across runs in one place (tool history or centralized repository).
• Produce your first automated comparison report for a pilot scope (one environment or system group) and store it as evidence.

By 60 days (expand coverage and connect to remediation)

• Expand trending to additional asset classes (endpoints, servers, cloud workloads).
• Implement consistent tagging and asset identifier normalization.
• Connect trend outputs to ticketing and define expected actions for “new critical” and “aging high” categories.
• Add an exceptions workflow aligned to trend outputs (expiring accepted risks, repeated false positives).

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

• Create a repeatable evidence pack per reporting period: raw scans, trend outputs, review notes, remediation linkage.
• Add template change logging and scope-change annotations so trends remain interpretable.
• Test with an internal audit-style sampling exercise: pick systems at random and reproduce the trend story across multiple scans.
• If you use Daydream for compliance operations, map RA-5(6) to the control owner, the procedure, and recurring evidence artifacts so the audit package is consistent period over period. ¹

Frequently Asked Questions

What counts as “automated” for RA-5(6)?

Automated means the comparison is generated by a tool or scheduled process without analysts manually merging files. A human can review and interpret the output, but the “diff” and trend report should be reproducible on demand.

Do we need advanced analytics or machine learning to satisfy RA-5(6)?

No. You need consistent comparisons across multiple scans that show what changed and what persists. Basic trends like new/closed/recurring by severity and system owner are usually defensible if they are automated and tied to action.

How many scans do we need to compare?

The text requires “multiple” scans, so plan to retain and compare at least two sequential scan cycles per in-scope system. Your strongest evidence shows a continuing series of comparisons over time. ¹

What if our scan scope changes (new assets, cloud autoscaling, mergers)?

Keep scope-change records and annotate trend outputs when the denominator changes. Without that, a spike in findings can be misread as control failure rather than scope expansion.

Can we meet RA-5(6) if a third party performs scanning?

Yes, if your contract and operating model give you comparable, repeatable scan outputs with enough metadata to trend. If you cannot get that data, document the limitation, boundary decision, and compensating visibility controls.

What’s the minimum evidence an auditor will accept?

A written procedure mapped to RA-5(6), raw scan outputs from multiple runs, an automated trend report showing comparisons, and proof that someone reviewed the trends and triggered remediation or risk decisions. ¹

Footnotes

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

2. NIST SP 800-53 Rev. 5