Requirement
FAR 52.204-21 / CMMC 2.0 Level 1 - Control - SI.L1-B.1.XII – Identify, report, and correct information and information system flaws in a timely manner.
Understanding the Requirement
This control (FAR 52.204-21 / CMMC 2.0 Level 1) requires an SMB to have a repeatable patching and vulnerability remediation practice so software and firmware flaws are identified, reported, and corrected within defined time frames. Practically, that means maintaining visibility of vulnerabilities across workstations, servers, and network devices; specifying the maximum allowable time to identify, report, and remediate each severity level; and making sure fixes (patches, configuration changes, or compensating controls) are applied and validated. Because vendors publish vulnerability information and updates, your process must include monitoring vendor notifications, testing updates, and a mechanism to track that remediation happened within the stated SLA.
Technical Implementation
- Asset inventory and visibility: Maintain an up-to-date inventory of endpoints, servers, virtual machines, containers, and network devices. Use a simple asset register or a lightweight discovery tool so every system that needs updates is known and assigned an owner.
- Automated scanning and prioritization: Run regular vulnerability scans (weekly or at least monthly) and subscribe to vendor/security advisories. Map vulnerabilities to severity (critical/high/medium/low) and define SLAs, for example: critical = 48 hours, high = 7 days, medium = 30 days, low = maintenance window.
- Patch management process: Establish a documented patch workflow: intake (vendor advisory), risk review, test on a pilot group, schedule deployment, deploy, and verify. Use central management tools where possible (WSUS/Intune for Windows, yum/apt automation for Linux, vendor tools for network devices) to push updates and log results.
- Reporting and ticketing: Use your helpdesk or issue tracker to create and route tickets for each identified flaw with severity, owner, due date, and remediation steps. Configure alerts for overdue remediation and require closure notes that include evidence (patch log, version change, or configuration snapshot).
- Testing, backups, and rollback: Always test updates in a small staging group before wide deployment; maintain backups or snapshots to allow quick rollback if an update breaks business services. Document test results and any exceptions approved by management.
- Verification and continuous improvement: After remediation, re-scan affected systems to validate closure. Keep metrics (time to identify, time to report, time to remediate, percent remediated within SLA) and review them monthly to tighten processes and identify recurring problem areas.
Example in a Small or Medium Business
Acme Engineering, a 60-person firm, maintains a mixed environment of Windows desktops, a couple of Linux servers, and Cisco switches. The IT manager creates an asset list and runs a weekly vulnerability scan that flags missing updates and known CVEs. They define SLAs: critical fixes within 48 hours, high within 7 days, and medium within 30 days. When Microsoft releases a critical patch, the IT manager opens a ticket, assigns it to the system administrator, and tests the patch on five non-critical machines the same day. After successful testing, the team deploys the patch overnight using their management tool and records the deployment IDs and reboot logs in the ticket. For a router firmware update, the network admin schedules a maintenance window, applies the update, and documents configuration backups and rollback steps. Each completed remediation is re-scanned the following day to confirm the vulnerability is closed; overdue tickets generate an escalated alert to the operations lead. Over time Acme uses remediation metrics to justify investing in a managed endpoint tool that automates most of these steps and reduces the mean time to remediate.
Summary
By combining a documented policy that sets clear SLAs for identifying, reporting, and correcting flaws with practical technical controls—asset inventory, scheduled scanning, a formal patch management workflow, ticketing and verification, and testing/rollback capabilities—SMBs can meet the requirement to remediate system vulnerabilities in a timely manner. These measures create repeatable, auditable evidence that flaws are found, communicated to the right people, and corrected within defined time frames, which reduces exposure and supports compliance.
