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Requirements 3.4

3.4 Configuration Management: the NIST SP 800-171 requirements

The 9 requirements of family 3.4, Configuration Management, in NIST SP 800-171 Rev 2, worth 33 points of a SPRS score under 32 CFR 170.24. For each: NIST's text, what it costs when not met, the objectives an assessor determines under NIST SP 800-171A, and how to meet it. To mark each one and work out your score, use the free calculator.

3.4.1 Baseline Configuration

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

Points: 5 points.

Assessment objectives (NIST SP 800-171A)

  • [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.
  • [f]The inventory is maintained (reviewed and updated) throughout the system development life cycle.
How to meet it

Stand up a hardware and software inventory (an RMM tool, Intune, or PDQ can auto-populate it) and document baseline configurations for each system type: OS version, required agents, key security settings. Capture golden images or configuration profiles so rebuilds match the baseline. Keep the inventory current through automated discovery rather than spreadsheets. Evidence: the inventory export, baseline documents per system type, and the imaging/profile artifacts.

3.4.2 Security Configuration Settings

Establish and enforce security configuration settings for information technology products employed in organizational systems.

Points: 5 points.

Assessment objectives (NIST SP 800-171A)

  • [a]Security configuration settings for information technology products employed in the system are established and included in the baseline configuration.
  • [b]Security configuration settings for information technology products employed in the system are enforced.
How to meet it

Adopt a recognized hardening benchmark (CIS Benchmarks or DISA STIGs) and apply it via GPO, Intune security baselines, or configuration scripts, documenting any deviations with justification. Start with Windows endpoints and domain controllers, then firewalls and servers. Run a CIS-CAT or similar scan to measure conformance. Evidence: the applied baseline policies, deviation register, and scan results.

3.4.3 System Change Tracking

Track, review, approve or disapprove, and log changes to organizational systems.

Points: 1 point.

Assessment objectives (NIST SP 800-171A)

  • [a]Changes to the system are tracked.
  • [b]Changes to the system are reviewed.
  • [c]Changes to the system are approved or disapproved.
  • [d]Changes to the system are logged.
How to meet it

Implement lightweight change control: changes to servers, network gear, and security settings get a ticket describing the change, an approval by someone other than the implementer, and a record of the result. A shared ticketing tool or even a structured change log works at small scale: the key is that undocumented changes stop. Evidence: the change procedure and a sample of completed change tickets with approvals.

3.4.4 Security Impact Analysis

Analyze the security impact of changes prior to implementation.

Points: 1 point.

Assessment objectives (NIST SP 800-171A)

  • [a]The security impact of changes to the system is analyzed prior to implementation.
How to meet it

Add a required "security impact" field to your change process where the requester answers whether the change affects CUI protection, opens ports, alters access, or touches security tooling, with the approver reviewing that analysis before sign-off. This costs nothing beyond a template update. Evidence: the change template showing the impact analysis section and completed examples.

3.4.5 Access Restrictions for Change

Define, document, approve, and enforce physical and logical access restrictions associated with changes to organizational systems.

Points: 5 points.

Assessment objectives (NIST SP 800-171A)

  • [a]Physical access restrictions associated with changes to the system are defined.
  • [b]Physical access restrictions associated with changes to the system are documented.
  • [c]Physical access restrictions associated with changes to the system are approved.
  • [d]Physical access restrictions associated with changes to the system are enforced.
  • [e]Logical access restrictions associated with changes to the system are defined.
  • [f]Logical access restrictions associated with changes to the system are documented.
  • [g]Logical access restrictions associated with changes to the system are approved.
  • [h]Logical access restrictions associated with changes to the system are enforced.
How to meet it

Restrict who can push changes: lock server room and network closet access physically, limit GPO/Intune/firewall admin roles to named change-authorized personnel, and remove developer or vendor write access to production. Document these restrictions in your change policy. Evidence: admin role membership exports, physical access lists, and the documented restrictions.

3.4.6 Least Functionality

Employ the principle of least functionality by configuring organizational systems to provide only essential capabilities.

Points: 5 points.

Assessment objectives (NIST SP 800-171A)

  • [a]Essential system capabilities are defined based on the principle of least functionality.
  • [b]The system is configured to provide only the defined essential capabilities.
How to meet it

Strip systems down to what the mission needs: uninstall unused software, disable unneeded services and features (SMBv1, legacy protocols, sample applications), and use your hardening baseline as the enforcement mechanism. Reviewing one server and one workstation image for unnecessary services is a productive first afternoon. Evidence: baseline documentation of permitted services and scan output showing nonessential services disabled.

3.4.7 Nonessential Functionality

Restrict, disable, or prevent the use of nonessential programs, functions, ports, protocols, and services.

Points: 5 points.

Assessment objectives (NIST SP 800-171A)

  • [a]Essential programs are defined.
  • [b]The use of nonessential programs is defined.
  • [c]The use of nonessential programs is restricted, disabled, or prevented as defined.
  • [d]Essential functions are defined.
  • [e]The use of nonessential functions is defined.
  • [f]The use of nonessential functions is restricted, disabled, or prevented as defined.
  • [g]Essential ports are defined.
  • [h]The use of nonessential ports is defined.
  • [i]The use of nonessential ports is restricted, disabled, or prevented as defined.
  • [j]Essential protocols are defined.
  • [k]The use of nonessential protocols is defined.
  • [l]The use of nonessential protocols is restricted, disabled, or prevented as defined.
  • [m]Essential services are defined.
  • [n]The use of nonessential services is defined.
  • [o]The use of nonessential services is restricted, disabled, or prevented as defined.
How to meet it

Run an internal port/service scan (Nmap or your vulnerability scanner) to find open ports and running services, then disable or firewall everything without a documented business need: keep a permitted ports/protocols/services list as the reference. Host firewalls (Windows Defender Firewall via GPO) enforce this at the endpoint. Evidence: the permitted list, scan results before/after cleanup, and firewall policy exports.

3.4.8 Application Execution Policy

Apply deny-by-exception (blacklisting) policy to prevent the use of unauthorized software or deny-all, permit-by-exception (whitelisting) policy to allow the execution of authorized software.

Points: 5 points.

Assessment objectives (NIST SP 800-171A)

  • [a]A policy specifying whether whitelisting or blacklisting is to be implemented is specified.
  • [b]The software allowed to execute under whitelisting or denied use under blacklisting is specified.
  • [c]Whitelisting to allow the execution of authorized software or blacklisting to prevent the use of unauthorized software is implemented as specified.
How to meet it

Deploy application control: Windows Defender Application Control or AppLocker in enforcement (or start in audit mode and tighten), or at minimum an EDR-based blocklist of known-unwanted software. Allowlisting by publisher/path is achievable for small fleets with standardized software. Document the policy choice (deny-by-exception or permit-by-exception) and who approves additions. Evidence: the AppLocker/WDAC policy export, approval records, and blocked-execution log samples.

3.4.9 User-Installed Software

Control and monitor user-installed software.

Points: 1 point.

Assessment objectives (NIST SP 800-171A)

  • [a]A policy for controlling the installation of software by users is established.
  • [b]Installation of software by users is controlled based on the established policy.
  • [c]Installation of software by users is monitored.
How to meet it

Remove local admin rights so users cannot install software, and provide a request path (ticket plus approval) for legitimate needs: pair this with an approved software catalog or a self-service portal in your RMM/Intune. Run periodic software inventory reports to catch unauthorized installs. Evidence: the software request procedure, local admin removal policy, and inventory reports showing detection of unapproved software.

Sources

The requirement text and the assessment objectives are NIST's, a work of the U.S. government. The titles and "how to meet it" are Edwards Consulting Group's. None of it is legal advice: the clauses in your contract decide what applies to you.