CM.L2-3.4.1: System Baselining Assessment Guide

Official reference

The requirement

Establish and maintain baseline configurations and inventories of organizational systems (including hardware, software, firmware, and documentation) throughout the respective system development life cycles.

DoD CMMC Assessment Guide, Level 2, version 2.13. CM.L2-3.4.1; requirement and objectives, printed page 91 ↗

Assessment objectives

What must be established

Determine if each applicable objective is satisfied. The labels below follow the cited DoD assessment guide.

[a]
a baseline configuration is established;
[b]
the baseline configuration includes hardware, software, firmware, and documentation;
[c]
the baseline configuration is maintained (reviewed and updated) throughout the system development life cycle;
[d]
a system inventory is established;
[e]
the system inventory includes hardware, software, firmware, and documentation; and
[f]
the inventory is maintained (reviewed and updated) throughout the system development life cycle.

MET requires evidence that all applicable objectives are satisfied. Final, approved evidence is needed. A NOT APPLICABLE determination needs a scope-based basis and is equivalent to MET for scoring. Enduring exceptions and temporary deficiencies have specific conditions under 32 CFR 170.24; they are not a general permission to defer implementation.

GAVII Cybersecurity assessment approach

Connect the objective to the evidence

Reconcile hardware, software, firmware, and relevant documentation across the system life cycle. A discovery export is useful, but it needs ownership and a defined relationship to the approved baseline.

Assessment focus: objectives [a], [b], [c], [d], [e], [f]. Use the methods together; a single example does not establish every objective.

Examine

Inspect approved baselines, asset inventories, version records, and evidence of updates after system changes.

Interview

How is an asset added, changed, and retired without leaving the inventory or baseline inaccurate?

Demonstrate or test

Select representative assets and compare their current configuration and software with the recorded baseline.

Evidence gaps to look for

The inventory is an old spreadsheet.
Hosted services, firmware, or supporting documentation are missing.

GAVII Cybersecurity’s examples illustrate ways to examine, interview, and test. They are not a mandatory artifact list or a guarantee of an assessment result. Combine methods and address every applicable objective in the actual scope.

Assessment constraints

Scoring and POA&M eligibility

Score: 5

If this requirement is NOT MET, deduct 5 points from the Level 2 maximum of 110. The deduction applies to the requirement, not separately to each objective.

Scoring rule ↗

POA&M: Not eligible

This requirement has a deduction greater than 1 point and does not qualify for the limited encryption exception. It cannot be deferred on the POA&M used for Conditional Level 2 status.

POA&M rule ↗

Conditional Level 2 requires a score of at least 88 out of 110 and satisfaction of every eligibility condition. A 1-point requirement is not automatically eligible. The permitted POA&M must be closed through the appropriate closeout assessment within 180 days of the Conditional CMMC Status Date. An operational remediation plan does not confer Conditional Status.

Assessment planning

Location and observation

Not specifically listed in CAP P.11

This requirement is not specifically listed in CAP P.11. That does not establish that remote assessment is sufficient: the Lead CCA and C3PAO determine an adequate approach for the actual scope and evidence.

CAP §P.11, pages 10–11 ↗

Check the source

References and related requirements

DoD CMMC Assessment Guide, Level 2 ↗CM.L2-3.4.1; requirement and objectives, printed page 91. 2.13, September 2024.
32 CFR 170.24: Assessment findings and scoring ↗170.24(b) and (c)(2). Current electronic Code of Federal Regulations.
32 CFR 170.21: POA&M eligibility and closeout ↗170.21(a)(2) and (b). Current electronic Code of Federal Regulations.
NIST SP 800-171 Rev. 2 ↗Requirement 3.4.1. February 2020, updated January 2021.
NIST SP 800-171A ↗Assessment procedure 3.4.1. June 2018.
Cyber AB CMMC Assessment Process (CAP) ↗P.11, printed pages 10-11; Level 2 certification assessment-location planning. 2.0, December 2024.

Program timing and contract applicability can change independently of these requirements. Check current DoD program notices and your solicitation or contract before making a compliance decision. Open the official DoD resource hub.

System Baselining