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How Do I Implement NIST 800-171 R3 03.11.02 Vulnerability Monitoring and Scanning?

NIST 800-171 R3 03.11.02 Vulnerability Monitoring and Scanning at a Glance

  • Family: 03.11 Risk Assessment (RA)
  • Requirement ID: 03.11.02 Vulnerability Monitoring and Scanning
  • Assessment Objectives (AOs): Eleven (11) total, including the four (4) Organization-Defined Parameters (ODPs) below and seven (7) determination statements
  • Organization-Defined Parameters (ODPs): Three (3), specified by the Department of Defense (DoD) for the Defense Industrial Base (DIB)
  • Source NIST 800-53 R5 Controls: RA-05, RA-05(02)
  • NIST 800-171 R3 Kill Chain Phase: Phase 15, Attack Surface Management (ASM)

Vulnerability Monitoring and Scanning is the operational engine of the Risk Assessment (03.11) family. Where Risk Assessment (03.11.01) sets the strategic risk picture, Vulnerability Monitoring and Scanning (03.11.02) finds specific weaknesses and drives them to remediation on a clock. It has three (3) parts: monitor and scan the system for vulnerabilities on a defined frequency and when new vulnerabilities are identified, remediate vulnerabilities within defined response times, and update the set of vulnerabilities to scan for on a defined frequency and when new vulnerabilities are reported. Per the NIST discussion, organizations should not overlook sources such as networked printers, scanners, and copiers, custom software may need static, dynamic, or binary analysis, and scanning tools should express vulnerabilities using the Common Vulnerabilities and Exposures (CVE) naming convention and the Common Vulnerability Scoring System (CVSS).

A common difficulty with this requirement is scanning without a remediation clock. Finding vulnerabilities is only half the requirement; R3 ties remediation to defined response times, and for Department of Defense (DoD) contractors those times are specific and tiered by severity. It also expects monitoring in addition to scanning and a process to keep the scan definitions current, which are new obligations for many programs.

Where things stand for companies facing the transition from NIST 800-171 R2 to R3:

  • The National Institute of Standards and Technology (NIST) withdrew R2 on May 14, 2024, the same day R3 was published. The withdrawal notice states that R2 "has been withdrawn (archived), and is provided solely for historical purposes," so it will never receive another correction or clarification from NIST.
  • R2 remains the contractual standard for the Department of Defense (DoD) and the Defense Industrial Base (DIB). Cybersecurity Maturity Model Certification (CMMC) assessments reference it directly: per Title 32 of the Code of Federal Regulations (CFR), section 170.14(c)(3), "the security requirements in CMMC Level 2 are identical to the requirements in NIST SP 800-171 R2."
  • The rulemaking points the other direction. The proposed Controlled Unclassified Information (CUI) rule for the Federal Acquisition Regulation (FAR), published June 23, 2026 as part of the Revolutionary FAR Overhaul, would apply CUI safeguarding requirements government wide rather than only to DoD contracts, and it sets the baseline at R3. That rule is not final, and DoD has separately signaled an interim rule to move CMMC to R3.

What Does NIST 800-171 R3 03.11.02 Actually Require?

The following is reproduced verbatim from NIST 800-171 R3, requirement 03.11.02 Vulnerability Monitoring and Scanning. Only the formatting has been adjusted for readability. This requirement has three (3) lettered parts:

  • a. Monitor and scan the system for vulnerabilities [Assignment: organization-defined frequency] and when new vulnerabilities affecting the system are identified.
  • b. Remediate system vulnerabilities within [Assignment: organization-defined response times].
  • c. Update system vulnerabilities to be scanned [Assignment: organization-defined frequency] and when new vulnerabilities are identified and reported.

The source controls are RA-05 and RA-05(02) from NIST 800-53. The bracketed assignments are the Organization-Defined Parameters (ODPs): the monitoring and scanning frequency, the remediation response times, and the scan-update frequency. Per the NIST discussion, vulnerability scanning includes scanning for patch levels and for functions, ports, protocols, and services that should not be accessible, and sources of vulnerability information include the Common Weakness Enumeration (CWE) listing and the National Vulnerability Database (NVD). You can read the requirement directly at NIST 800-171 R3, 03.11.02 (p. 54).

What Are the Organization-Defined Parameters (ODPs) Associated with NIST 800-171 R3 03.11.02?

Three (3) values sit inside this requirement. Depending on your contract, your organization may be permitted to define them. Organizations in the DIB subject to CMMC are not, because the DoD has defined them as policy.

The values below come from Attachment A of the DoD Chief Information Officer (CIO) memorandum dated 10 April 2025 (signed David W. McKeown). The memo identifies each parameter by requirement sub-part, while NIST 800-171A R3 identifies the same parameter by ODP number. Both identifiers appear below so you can match your System Security Plan (SSP) language to either document.

  • ODP[01] (DoD memo identifier 03.11.02.a). the frequency at which the system is monitored for vulnerabilities is defined. DoD Position: at least monthly, or when there are significant incidents or significant changes to risks.
  • ODP[02] (DoD memo identifier 03.11.02.a). the frequency at which the system is scanned for vulnerabilities is defined. DoD Position: at least monthly, or when there are significant incidents or significant changes to risks.
  • ODP[03] (DoD memo identifier 03.11.02.b). response times to remediate system vulnerabilities are defined. DoD Position: thirty (30) days from date of discovery for high-risk vulnerabilities (including both critical and high); 90 days from date of discovery for moderate-risk vulnerabilities; and 180 days from date of discovery for low-risk vulnerabilities.
  • ODP[04] (DoD memo identifier 03.11.02.c). the frequency at which to update system vulnerabilities to be scanned is defined. DoD Position: no more than 24 hours prior to running the scans.

Note the asymmetry: NIST 800-171A R3 decomposes this requirement into four (4) Organization-Defined Parameters, while the DoD memorandum addresses them with three (3) entries, because a single bracketed assignment in the requirement text covers more than one parameter under assessment. Each ODP still needs its own answer in the System Security Plan (SSP).

The memo states that its values "will be updated as necessary," so confirm against the current version before writing them into policy.

What Are the Assessment Objectives (AOs) For NIST 800-171 R3 03.11.02?

NIST 800-171A R3 breaks 03.11.02 into eleven (11) assessment objectives: four (4) Organization-Defined Parameters (ODPs) and seven (7) determination statements. These AOs are:

  • A.03.11.02.ODP[01]: the frequency at which the system is monitored for vulnerabilities is defined.
  • A.03.11.02.ODP[02]: the frequency at which the system is scanned for vulnerabilities is defined.
  • A.03.11.02.ODP[03]: response times to remediate system vulnerabilities are defined.
  • A.03.11.02.ODP[04]: the frequency at which to update system vulnerabilities to be scanned is defined.
  • A.03.11.02.a[01]: the system is monitored for vulnerabilities <A.03.11.02.ODP[01]: frequency>.
  • A.03.11.02.a[02]: the system is scanned for vulnerabilities <A.03.11.02.ODP[02]: frequency>.
  • A.03.11.02.a[03]: the system is monitored for vulnerabilities when new vulnerabilities that affect the system are identified.
  • A.03.11.02.a[04]: the system is scanned for vulnerabilities when new vulnerabilities that affect the system are identified.
  • A.03.11.02.b: system vulnerabilities are remediated within <A.03.11.02.ODP[03]: response times>.
  • A.03.11.02.c[01]: system vulnerabilities to be scanned are updated <A.03.11.02.ODP[04]: frequency>.
  • A.03.11.02.c[02]: system vulnerabilities to be scanned are updated when new vulnerabilities are identified and reported.

If you are a DoD contractor, the ODPs are specified and concrete. Per the DoD-specified ODP values in ComplianceForge's NIST 800-171 R3 Transition Guide, the monitoring and scanning frequency is at least monthly or on significant incidents or risk changes, the remediation response times are thirty (30) days from discovery for high-risk vulnerabilities (critical and high), ninety (90) days for moderate-risk, and one hundred eighty (180) days for low-risk, and the scan definitions are updated no more than twenty-four (24) hours before running scans. The full guidance on assessment methods and objects, is in NIST 800-171A R3, 03.11.02 (p. 69).

Assessment Methods and Objects for NIST 800-171 R3 03.11.02

Examine: risk assessment policy and procedures; procedures for vulnerability scanning; patch and vulnerability management records; vulnerability scanning tools and configuration documentation; vulnerability scanning results; risk assessment; risk assessment report; system security plan.

Interview: personnel with risk assessment and vulnerability scanning responsibilities; personnel with vulnerability scan analysis responsibilities; personnel with vulnerability remediation responsibilities; personnel with information security responsibilities; system administrators.

Test: processes for vulnerability monitoring, scanning, analysis, and remediation; mechanisms for supporting or implementing vulnerability monitoring, scanning, analysis, and remediation.

How Does NIST 800-171 R3 03.11.02 Map From NIST 800-171 R2?

03.11.02 maps from NIST 800-171 R2 requirement 3.11.2 (scan for vulnerabilities in organizational systems and applications periodically and when new vulnerabilities are identified), and it draws on R2 requirement 3.11.3 (remediate vulnerabilities in accordance with risk assessments):

  • A.03.11.02.ODP[02], A.03.11.02.a[02], and A.03.11.02.a[04] map directly to R2 3.11.2 (scanning on a frequency and when new vulnerabilities are identified).
  • A.03.11.02.a[03] and A.03.11.02.b map indirectly to elements of R2 3.11.3 (remediation and monitoring).
  • A.03.11.02.c[01] and A.03.11.02.c[02] are net new for R3.
  • A.03.11.02.ODP[01], A.03.11.02.ODP[03], A.03.11.02.ODP[04], and A.03.11.02.a[01] have no clear mapping to any R2 assessment objective.

Mapped against the eleven (11) AOs, three (3) are direct (minimal effort), two (2) are indirect (moderate effort), two (2) are net new, and four (4) have no clear mapping, with the last two (2) categories both counting as significant effort. Scanning carries forward, but continuous monitoring, defined remediation response times, and updating the scan definitions are the new work. Six of the eleven (11) objectives are significant effort, which makes this one of the heavier controls in the family.

How Does NIST 800-171 R3 03.11.02 Map to NIST 800-53 R5 and the SCF?

Source Controls in NIST 800-53 R5:

  • RA-05
  • RA-05(02)

Secure Controls Framework (SCF) Crosswalk

Organizations running a single control set across multiple frameworks can satisfy 03.11.02 through the following SCF controls:

  • RSK-16 Risk Response
  • RSK-17 Risk Remediation
  • RSK-18 Compensating Countermeasures
  • THR-02 Threat Intelligence Program
  • THR-04 Threat Intelligence Feeds
  • VPM-02 Vulnerability & Patch Management Program (VPMP)
  • VPM-03 Attack Surface Scope
  • VPM-05 Vulnerability Ranking
  • VPM-06 Vulnerability Remediation Process
  • VPM-06.2 Continuous Vulnerability Remediation Activities
  • VPM-08 Software & Firmware Patching
  • VPM-12 Vulnerability Scanning
  • VPM-12.1 Update Vulnerability Scanning Tools

The crosswalks from NIST 800-171 R3 and NIST 800-171A R3 to the SCF are available at no cost through the SCF Set Theory Relationship Mapping (STRM): https://securecontrolsframework.com/start-here/set-theory-relationship-mapping-strm. The STRM also carries the relationship type for each mapping (Equal, Subset Of, Intersects With), which tells you whether an SCF control fully satisfies the requirement or only part of it. Mapping above taken from SCF 2026.3.

Common Pitfalls with NIST 800-171 R3 03.11.02

The following are issues teams may encounter rather than certainties. They are about the remediation clock and monitoring, each of which needs documented evidence of due diligence and due care such as policies, standards, procedures, and configuration screenshots:

  • Remediation is on a clock. A.03.11.02.b ties remediation to defined response times. For DoD work that is thirty days for high-risk, ninety for moderate, and one hundred eighty for low, measured from discovery.
  • Monitoring is distinct from scanning. A.03.11.02.a[01] and a[03] require monitoring for vulnerabilities, not only periodic scans, which points to continuous vulnerability awareness.
  • Keep scan definitions current. A.03.11.02.c[01] and c[02] are net new and require updating what you scan for, on a frequency and when new vulnerabilities are reported. For DoD work, update within twenty-four hours before a scan.
  • Do not overlook peripheral devices. Per the NIST discussion, networked printers, scanners, and copiers are common blind spots that must be in scan scope.

What Is Reasonable Evidence For NIST 800-171 R3 03.11.02?

Reasonable objective evidence for an assessment is often subjective. The following examples of evidence to address NIST 800-171 R3 03.11.02 are sourced from the SCF Evidence Request List (ERL), available at https://securecontrolsframework.com/free-content/scf-download. These ERL artifacts are mapped to NIST 800-171 R3 03.11.02 through SCF controls. They establish a starting point for discussions on what an organization needs to have for evidence of due diligence and due care to withstand external scrutiny by an assessor or regulator.

  • E-GOV-20 Compensating Controls. Compensating controls (e.g., countermeasure to reduce risk associated with control deficiencies).
  • E-MNT-03 Patch Management. Maintenance activities for technology assets, applications and/or services (taas) (e.g., patch management).
  • E-RSK-03 Plan of Actions & Milestones (POA&M) / Risk Register. A poa&m, or risk register, that tracks control deficiencies from identification through remediation.
  • E-THR-03 Threat Intelligence Feeds (TIF). Threat intelligence feeds.
  • E-THR-04 Threat Intelligence Program (TIP). A formal capability that intakes and analysis threat information to determine specific threat to the organization and necessary actions to mitigate the threat(s).
  • E-THR-05 Threat Mitigation. Steps taken to mitigate identified threats.
  • E-VPM-01 Vulnerability & Patch Management Program (VPMP). A vulnerability & patch management program (vpmp). this is program-level documentation in the form of a runbook, playbook or a similar format provides guidance on organizational practices that support existing policies and standards.
  • E-VPM-06 Attack Surface Scope. The organization defining its attack surface (e.g., may be in the form of graphical network diagrams or other forms of written documentation).
  • E-VPM-07 Flaw Remediation Change Control. Installation/change control records for security-relevant software and firmware updates.
  • E-VPM-09 Flaw Remediation Actions. List of recent security flaw remediation actions performed on the system (e.g., list of installed patches, service packs, hot fixes, and other software updates to correct system flaws).
  • E-VPM-10 Applicable Flaws & Vulnerabilities. Flaws and vulnerabilities potentially affecting a specific system, application and/or service.
  • E-VPM-11 Vulnerability Scanning. Internal and external vulnerability scans being performed.

Alongside these, keep the System Security Plan (SSP) narrative for 03.11.02 recording the ODP values you adopted.

Timeline Considerations for NIST 800-171 R3 03.11.02

With three (3) AOs mapping directly, two indirectly, two net new, and four with no clear mapping, 03.11.02 is a significant lift. A realistic sequence:

  1. Define the four (4) ODPs: monitoring and scanning frequency, remediation response times, and scan-update frequency, using the DoD-specified values for DoD contracts.
  2. Establish continuous monitoring and scheduled scanning, plus scanning when new vulnerabilities are identified (A.03.11.02.a[01] through a[04]).
  3. Remediate within the defined response times, tracking from date of discovery (A.03.11.02.b).
  4. Keep the scan definitions current on the frequency and when new vulnerabilities are reported (A.03.11.02.c[01] and c[02]).
  5. Collect evidence for all eleven (11) AOs, including scan results, monitoring, remediation records with timelines, and scan-definition updates.

Frequently Asked Questions About NIST 800-171 R3 03.11.02

What value does the DoD require for the first parameter in NIST 800-171 R3 03.11.02? R3 leaves the value to the organization. For the DIB, the DoD set it in the 10 April 2025 memorandum under ODP identifier 03.11.02.a: at least monthly, or when there are significant incidents or significant changes to risks.

How many assessment objectives does NIST 800-171 R3 03.11.02 have? NIST 800-171A R3 breaks 03.11.02 into eleven (11) assessment objectives: four (4) Organization-Defined Parameters (ODPs) and seven (7) determination statements. An assessor works through each one separately, so each needs its own evidence.

Which NIST 800-53 R5 controls does NIST 800-171 R3 03.11.02 come from? RA-05, RA-05(02).

Where does NIST 800-171 R3 03.11.02 sit in the NIST 800-171 R3 Kill Chain? Phase 15, Attack Surface Management (ASM). The Kill Chain is a phased model for sequencing R3 implementation, and it assigns this requirement to that phase.

Bottom Line on NIST 800-171 R3 03.11.02

03.11.02 Vulnerability Monitoring and Scanning monitors and scans for vulnerabilities, remediates them within defined response times, and keeps the scan definitions current. It maps from R2 3.11.2 and draws on 3.11.3, with scanning transitioning directly, while monitoring, defined remediation times, and scan-definition updates are the new work, making six of eleven (11) objectives significant effort. The recurring problem is scanning with no remediation clock. Scan and monitor, remediate on the DoD-tiered timelines (thirty, ninety, and one hundred eighty days), and keep scan definitions current.

Authoritative sources:

Authoritative sources:

This guide reproduces U.S. Government text from NIST 800-171 R3 and NIST 800-171A R3 and references the DoD ODP memorandum of 10 April 2025. It is educational, not legal or assessment advice. Last reviewed: 2026-09-22.