Level 2 · Maintenance
MA.L2-3.7.2
System Maintenance Control
Maintenance controls must cover the people and the means used to change or repair a system.
Official reference
The requirement
Provide controls on the tools, techniques, mechanisms, and personnel used to conduct system maintenance.
DoD CMMC Assessment Guide, Level 2, version 2.13. MA.L2-3.7.2; requirement and objectives, printed page 146 ↗
Assessment objectives
What must be established
Determine if each applicable objective is satisfied. The labels below follow the cited DoD assessment guide.
- [a]
tools used to conduct system maintenance are controlled;
- [b]
techniques used to conduct system maintenance are controlled;
- [c]
mechanisms used to conduct system maintenance are controlled; and
- [d]
personnel used to conduct system maintenance are controlled.
CAP location planning flagged ↓
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
Inventory relevant tools, techniques, mechanisms, and personnel. Supplier ownership of a tool does not remove the need to understand how its use is controlled.
Assessment focus: objectives [a], [b], [c], [d]. Use the methods together; a single example does not establish every objective.
Examine
Review maintenance authorizations, approved tools and methods, personnel access, and supplier work procedures.
Interview
Who approves a technician and their tools before maintenance begins?
Demonstrate or test
Walk through a representative maintenance activity and show how tool use and personnel access are controlled, with location planning for personnel observation.
Evidence gaps to look for
- A vendor is approved generally but individual maintenance access is uncontrolled.
- Tools enter the environment without review.
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
Location planning flagged
CAP P.11 specifically highlights the marked objectives for assessment-location planning. Agree with the C3PAO how the environment can be adequately observed, including any scope-specific need for on-site activity. These markers do not establish a universal in-person requirement.
Flagged objectives: [d].
CAP §P.11, pages 10–11 ↗Check the source
References and related requirements
- DoD CMMC Assessment Guide, Level 2 ↗MA.L2-3.7.2; requirement and objectives, printed page 146. 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 3.7.2. February 2020, updated January 2021.
- NIST SP 800-171A ↗Assessment procedure 3.7.2. 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.