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Vulnerability Management Procedure

Use this free template to write your agency's Vulnerability Management Procedure. It maps to National Institute of Standards and Technology (NIST) Special Publication (SP) 800-53 Revision 5, and it sits with the Risk Assessment (RA) family. This copy follows the Moderate baseline with the High Value Asset (HVA) overlay from the Cybersecurity and Infrastructure Security Agency (CISA). It names 13 controls. It calls the agency that adopts it "the Organization", and it names each person by role and each tool by its function. It cites 21 federal sources.

Approved by: Chief Information Security Officer (CISO)

From the document: Use this procedure to find vulnerabilities, set a due date for each one, fix or isolate it, confirm the fix, and report to CISA.

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Controls covered

  • CA-05
  • CA-06
  • IR-06
  • RA-05
  • RA-05(2)
  • RA-05(3)
  • RA-05(5)
  • RA-05(11)
  • RA-07
  • SA-09
  • SI-02
  • SI-02(2)
  • SI-02(3)

Every Risk Assessment (RA) template

The text of the Vulnerability Management Procedure

Approval #

Role Name Signature
Chief Information Security Officer (CISO)

Revision History #

Date Version Description Reviewer
2026-10-31 1.0 Initial issuance [Reviewer name]

Review cycle: Every year, and when the Cybersecurity and Infrastructure Security Agency (CISA) changes Binding Operational Directive (BOD) 26-04.

Mandate. The CISO issues this procedure to carry out the Vulnerability Management Policy (POL-VM-001). The vulnerability management team runs it. The requirements behind it are:

  • Cybersecurity and Infrastructure Security Agency (CISA) Binding Operational Directive (BOD) 26-04, Prioritizing Security Updates Based on Risk, and CISA’s Implementation Guidance for Prioritizing Security Updates Based on Risk.
  • BOD 23-01, on asset discovery and vulnerability detection.
  • BOD 23-02, on management interfaces that can be reached from the internet.
  • BOD 25-01, on secure cloud configurations.
  • BOD 26-02, on edge devices that no longer receive vendor support.
  • National Institute of Standards and Technology (NIST) Special Publication (SP) 800-53 controls RA-5, RA-5(2), RA-5(3), RA-5(5), RA-5(11), SI-2, SI-2(2), and SI-2(3).

BOD 26-04 required agencies to revise their procedures to its risk model by August 9, 2026. Its remediation deadlines and asset tags become mandatory on December 7, 2026.

1. Purpose and Scope #

Use this procedure to find vulnerabilities, set a due date for each one, fix or isolate it, confirm the fix, and report to CISA. The people who use it are the vulnerability management team, system and platform administrators, System Owners, Information System Security Officers (ISSOs), the Security Operations Center (SOC), and the incident response team.

In scope:

  • Every Internet Protocol (IP) addressable asset that is not ephemeral, on a network that the Organization operates or that a provider operates for it. This includes servers, workstations, laptops (including laptops used off the network), virtual machines, network devices, printers, IP telephones, and cameras, on premises or in the cloud.
  • Mobile devices, where the vulnerability scanner can examine them.
  • Cloud infrastructure that the Organization controls, and the Organization’s share of platform and software services under the shared responsibility model.
  • Container images, in the build pipeline and the registry.
  • Weaknesses without a Common Vulnerabilities and Exposures (CVE) ID, such as misconfigurations, web application flaws, and weak identity settings. BOD 26-04 Table 1 covers only findings with a CVE ID. The Organization’s own timeframes cover the rest.

Out of scope: systems that are physically air-gapped (a logically separated network is in scope), guest wireless networks that are physically separate from Organization networks, and national security systems.

2. Roles and Responsibilities #

Role Responsibilities
CISO Approves this procedure and the coverage definition. Reviews the measures. Escalates missed due dates to the Authorizing Official. Signs attestations and reports to CISA.
Vulnerability management team Runs the vulnerability scanner and keeps its detection content current. Reconciles coverage. Reviews the decision-point answers and due dates. Tracks remediation, confirms each fix, and prepares the reports to CISA.
System Owners Keep every asset of their systems in the inventory with correct exposure tags. Authorize scanning accounts. Fund and schedule remediation. Own the plan of action and milestones (POA&M) items for their systems.
ISSOs Review findings for their systems. Document false positives with evidence. Report scans that cannot log in and gaps in coverage. Open POA&M items before a finding misses its due date.
System and platform administrators Apply fixes and mitigations through change management by the due date. Record what they did on the ticket.
SOC Watches the security information and event management (SIEM) system and endpoint data for attacks on open vulnerabilities. Reports confirmed exploitation as an incident.
Incident response team Leads forensic triage. Handles confirmed compromise under the Incident Response Plan (PLAN-IR-001).
Configuration Control Board Approves the normal and emergency changes that deliver fixes.
Chief Information Officer (CIO), as Authorizing Official Decides risk acceptances. Approves the plans that let High Value Assets (HVAs) and mission-critical systems meet the deadlines.
Contracting Officers and Contracting Officer’s Representatives Make sure contracts and service agreements require providers to meet these deadlines and report vulnerability status.

3. Definitions #

Term Meaning in this procedure
Asset A hardware or software item in an information system. NIST SP 800-40 Rev. 4 treats the asset as the unit of work for patching.
Finding One vulnerability on one asset, identified by its CVE ID or by a scanner detection.
In the KEV Listed in CISA’s Known Exploited Vulnerabilities (KEV) catalog.
Publicly exposed Unauthenticated or untrusted parties can reach the asset over a public network, such as the internet, wherever the asset is hosted. If any source shows the asset as exposed, the team treats it as exposed.
Automatable An attacker can automate every step needed to exploit the vulnerability. A public proof-of-concept that reliably runs remote code makes a vulnerability automatable.
Total technical impact Exploitation gives the attacker total control of the vulnerable software. Examples are running any code, gaining administrator or root access, and reliably getting login credentials. Common Vulnerability Scoring System (CVSS) ratings of High for both confidentiality and integrity also show total impact.
Partial technical impact Any lesser control, including a denial of service.
Remediation Removing the vulnerability by patching, by decommissioning the asset, or by another action that eliminates it.
Mitigation An action that reduces exposure but leaves the vulnerability in place, such as isolating the asset or removing it from the internet. A mitigation can change a decision point, and so the due date.
Forensic triage A structured check of whether an attacker compromised an asset. Each “3 days and forensic triage” finding requires one.
Fix on system upgrade Remediate at the asset’s next scheduled major upgrade or rebuild.
Due date The last day to remediate the finding, set as described in Set Each Finding’s Due Date.
Potential Agency Impact N-rating (PAIN) The Federal Risk and Authorization Management Program (FedRAMP) rating, from N0 to N5, of how much exploiting a vulnerability in a cloud service could harm the agencies that use it. A cloud provider assigns it. N5 means a debilitating effect on more than one agency.
Internet-reachable vulnerability In FedRAMP’s rules, a vulnerability a payload from the public internet might trigger.
Likely exploitable vulnerability In FedRAMP’s rules, a vulnerability a likely threat actor can reach and would likely use to cause harm.
Accepted vulnerability In FedRAMP’s rules, a vulnerability the provider will not fully mitigate, or will not fix within 192 days of evaluation.
Overdue vulnerability In FedRAMP’s rules, a vulnerability the provider means to fix but will not fix within FedRAMP’s timeframes.

4. Tools and Systems of Record #

Tool or system Use in this procedure Records it holds
The vulnerability scanner The vulnerability management platform: continuous detection through agents, authenticated network scanning, asset discovery, prioritization, remediation checks, and compliance scanning Findings, first-detected and fixed dates, coverage and authentication results
The endpoint detection and response (EDR) tools Endpoint detection and response on every endpoint, evidence of exploitation, and endpoint vulnerability data where the product provides it Endpoint telemetry and detections
The mobile device management (MDM) tool Endpoint update deployment in rings, and each endpoint’s update state Deployment and compliance records
The SIEM system Alerts on signs of exploitation across log sources Alerts and investigations
The ticketing system Remediation tickets, change requests, coverage-gap tickets, and disclosure reports Ticket and change records
The governance, risk, and compliance (GRC) system POA&M items and risk acceptances POA&M and risk-acceptance records
CISA Continuous Diagnostics and Mitigation (CDM) Agency Dashboard Federal reporting of assets, vulnerabilities, and exposure tags CDM records
CISA KEV catalog and CVE records KEV status, and the Automatable and Technical impact values that CISA’s Vulnrichment Program publishes for each CVE ID Not applicable
CISA Cyber Hygiene CISA’s external scanning of the Organization’s public address space, with weekly reports Weekly reports and scope attestations

5. Detect Vulnerabilities on Every Asset #

The vulnerability management team runs scanner agents on every server, workstation, and laptop. The agents report installed software and vulnerabilities continuously, so the team sees a new vulnerability without waiting for a scan. For assets that cannot run an agent, the team runs authenticated network scans. The team meets the minimum in this table for each activity. Continuous agent detection exceeds the BOD 23-01 minimums, but the minimums still apply to every asset without an agent.

Activity Method Minimum Required by
Asset discovery Scanner discovery scans across all IPv4 and IPv6 address space in use Continuous, with a full sweep at least every 7 days BOD 23-01
Vulnerability detection on managed endpoints and servers Scanner agents with privileged access Continuous, with enumeration started at least every 14 days BOD 23-01; RA-5
Operating system scans of assets without an agent, such as network devices, appliances, printers, and IP telephones Authenticated scanner network scans Monthly Organization RA-5 parameter
Database scans Authenticated scanner database scans Monthly Organization RA-5 parameter
Web application scans Authenticated scanner web application scans Monthly, and after each significant change Organization RA-5 parameter
Missing-update check The vulnerability scanner At least weekly Organization SI-2(2) parameter
Detection content Scanner content updates Within 24 hours of the vendor’s release, and before each scan BOD 23-01; RA-5(2)
Results to CDM Automated feed Within 72 hours of the end of each discovery cycle BOD 23-01
Container images Image scanning in the build pipeline and the registry At build, and whenever detection content changes RA-5
Cloud tenants in BOD 25-01 scope CISA Secure Cloud Business Applications (SCuBA) assessment tools Continuous reporting to CISA, or quarterly by hand BOD 25-01
Discovery or enumeration that CISA requests The vulnerability scanner Start within 72 hours of the request. Send available results within 7 days. BOD 23-01

To find assets that a discovery scan misses, the team also uses the EDR tools, the MDM tool, passive network discovery, and the inventories of the Organization’s cloud accounts.

  1. Keep coverage complete. Each week, the vulnerability management team compares the assets in the vulnerability scanner with the authoritative inventory and the CDM asset list. For each asset with no detection method, the ISSO opens a ticketing system gap ticket. The ISSO keeps the ticket open until the team covers the asset or the System Owner accepts the gap in writing.
  2. Keep agents reporting. Administrators include the scanner agent in every standard server image and endpoint build, so each new asset reports from its first start. An agent that has not reported for more than 7 days is a coverage gap, and the ISSO opens a gap ticket for it.
  3. Cover cloud workloads through their images. Administrators build cloud workloads from images that include the agent, and the team scans each image before use. For a workload too short-lived to scan, the team relies on the scan of its image.
  4. Make every scan authenticated. System Owners authorize dedicated scanning accounts for their components. Administrators use these accounts for scanning only and protect them as privileged accounts. When a scan cannot log in, the ISSO opens a ticketing system ticket. The team scans the asset again after administrators fix the access problem. An unauthenticated result does not count as coverage.
  5. Use only approved methods. For specialized equipment that cannot take an agent or credentials, the team uses another method only after CISA approves it, as BOD 23-01 requires.
  6. Keep detection content current. Each day, the team confirms that the scanner detection content is no more than 24 hours behind the vendor’s latest release. The team repeats any scan that ran on outdated content.
  7. Keep CDM current. After each discovery cycle, the team confirms that results reach the CDM Agency Dashboard within 72 hours of the end of the cycle. The team investigates any break in the feed as soon as it finds one.

Evidence: the scanner coverage and authentication reports, the daily content checks, the weekly coverage reconciliation, the gap tickets in the ticketing system, and the CDM feed status.

6. Take In New Vulnerability Information #

6.1 Act on each KEV catalog addition #

CISA aims to add a vulnerability to the KEV catalog within 24 hours of confirming that it meets the catalog’s criteria. CISA can also add an older CVE at any time. These targets match the first step of CISA’s forensic triage guidance.

Step Who Action Target
1 The vulnerability scanner Matches the new entry to every asset, flags each affected finding, and applies the due-date rule. On publication
2 Vulnerability management team Reviews the affected assets and the decision-point answers and due dates for each. Corrects any that are wrong. Within 2 hours of the addition
3 Vulnerability management team Opens or updates the remediation ticket for each affected system. Notifies the System Owner, the ISSO, and the SOC. Within 2 hours
4 Incident response team Starts forensic triage for each finding that requires it. Within 2 hours
5 Vulnerability management team Reads the entry’s notes for CISA’s triage steps and indicators of compromise. Sends them to the SOC and the incident response team. Within 2 hours

6.2 Add CISA’s enrichment data to each CVE #

The vulnerability management team runs automation that reads two values for each CVE ID from the CVE record: Automatable and Technical impact. CISA’s Vulnrichment Program publishes these values. The automation applies them to the findings in the vulnerability scanner. CISA always publishes the values for a CVE ID in the KEV catalog. Until CISA publishes them for any other CVE ID, the team treats Automatable as no and Technical impact as total, as CISA does. CISA updates CDM within three business days after it completes its enrichment. The team then re-checks the due date.

6.3 Act on Emergency Directives #

CISA sets the actions, deadlines, and reports in each Emergency Directive, and every Emergency Directive is mandatory. The CISO assigns an owner on the day CISA issues it. When the directive’s deadline is earlier than the due date this procedure gives, the directive’s deadline applies. The owner reports to CISA exactly as the directive specifies.

Each Emergency Directive (ED) below was on CISA’s list of active directives on October 21, 2026. Each owner keeps the directive’s required actions in place for the affected products until CISA closes it.

Directive Subject Issued
ED 24-01 Vulnerabilities in certain remote-access gateway products, with two supplemental directions January 19, 2024
ED 25-02 A vulnerability in hybrid deployments of an on-premises email server August 7, 2025
ED 25-03 Possible compromise of certain firewall devices, with a supplemental direction and a first revision September 25, 2025
ED 26-01 Vulnerabilities in certain application delivery devices after a theft of the vendor’s source code October 15, 2025
ED 26-03 Vulnerabilities in certain software-defined wide-area network systems, with a first revision of March 11, 2026 February 25, 2026

The CISO checks CISA’s directives page each month and updates this table when CISA issues or closes a directive. Executive Order 14409 of June 2, 2026 directs CISA to issue directives that speed the cyber defense of civilian federal systems. The CISO adds each new directive to this procedure.

6.4 Work with CISA Cyber Hygiene #

  • CISA scans the Organization’s public addresses through its Cyber Hygiene service, as an attacker would see them. Administrators must not block its source addresses, add them to an allow list, or open ports for them.
  • The SOC may suppress SIEM alerts from the published Cyber Hygiene source addresses. The addresses change without notice, so the SOC checks the list in each weekly report against its suppression rules.
  • If any system blocks a Cyber Hygiene address, administrators remove the block. The vulnerability management team tells CISA which addresses the system blocked, at vulnerability@cisa.dhs.gov, so CISA can restart scanning.
  • The vulnerability management team loads each weekly report into the vulnerability scanner and reconciles every finding. The team marks any asset with a Cyber Hygiene finding as publicly exposed.
  • Each quarter, and whenever CISA asks, the CISO attests the Organization’s publicly exposed IP addresses and domain names. The CISO uses CISA’s Cyber Hygiene scope-change process and lists every addition and removal since the previous quarter.
  • The CISO submits updated Cyber Hygiene acceptance letters when CISA asks for them.
  • Cyber Hygiene also checks the settings that CISA BOD 18-01 requires. Administrators serve every public website and web service over Hypertext Transfer Protocol Secure (HTTPS) only, with Hypertext Transfer Protocol (HTTP) Strict Transport Security (HSTS).
  • Administrators turn off SSLv2, SSLv3, 3DES, and the Rivest Cipher 4 (RC4) cipher on web and mail servers. They set mail servers to offer encryption through the Start Transport Layer Security (STARTTLS) command.
  • For every second-level domain, administrators publish a Sender Policy Framework (SPF) record. They also publish a Domain-based Message Authentication, Reporting, and Conformance (DMARC) policy of “reject”.
  • The vulnerability management team records each missing BOD 18-01 setting as a finding in the vulnerability scanner. The team rates its severity and gives it the Organization’s timeframe for that severity, as for any weakness without a CVE ID. The System Owner fixes it by the due date.

6.5 Act on Ransomware Vulnerability Warning Pilot notices #

CISA notifies agencies of internet-facing systems with vulnerabilities or misconfigurations that ransomware actors commonly use. The team treats the named asset as publicly exposed and sets its due date in the usual way. The SOC checks the asset for signs of compromise the same day.

6.6 Take in vulnerability disclosure reports #

The vulnerability management team logs each report received under the Vulnerability Disclosure Policy (POL-VDP-001) in the ticketing system and validates it. The team records each valid report as a finding under this procedure. A finding without a CVE ID gets the Organization’s timeframe for its severity.

6.7 Watch vendor advisories and exploitation inside the Organization #

The team follows the vendors’ security advisories for every product in the inventory. If the SOC sees an attacker exploiting an open vulnerability in the Organization’s environment, the SOC reports an incident under the Incident Response Plan (PLAN-IR-001). The team then handles each affected asset as a “3 days and forensic triage” finding, even if Table 1 gives a longer timeline.

Evidence: the ticket times for each KEV addition, the Cyber Hygiene weekly reports and scope attestations, the Emergency Directive reports, and the disclosure reports in the ticketing system.

7. Set Each Finding’s Due Date #

7.1 Answer the four decision points #

Each finding with a CVE ID has four answers in the vulnerability scanner. The platform sets them automatically from the sources below, and the team’s automation loads any value the platform does not take directly. Each working day, the vulnerability management team reviews the answers on new findings and corrects any that are wrong. The team records the reason for each correction on the finding.

  1. In the KEV? From the KEV catalog.
  2. Publicly exposed? From the asset’s exposure tag, scanner external scanning, CDM, and Cyber Hygiene, judged under CISA’s Internet Exposure Reduction Guidance. If any source shows the asset as exposed, the answer is yes. The team treats an asset of unknown exposure as exposed, which is stricter than CISA’s default.
  3. Automatable? From the CVE record. The answer is no until CISA publishes a value.
  4. Technical impact? From the CVE record. The answer is total until CISA publishes a value.

7.2 Read the timeline from Table 1 #

In Table 1 of BOD 26-04, CISA sets the longest time allowed for each combination of answers. Days are calendar days.

In the KEV Publicly exposed Automatable Technical impact Remediate within
Yes Yes Yes Total 3 days and forensic triage
Yes Yes Yes Partial 3 days
Yes Yes No Total 3 days and forensic triage
Yes Yes No Partial 14 days
Yes No Yes Total 3 days and forensic triage
Yes No Yes Partial 14 days
Yes No No Total 14 days
Yes No No Partial 14 days
No Yes Yes Total 3 days
No Yes Yes Partial 14 days
No Yes No Total 14 days
No Yes No Partial 60 days
No No Yes Total 60 days
No No Yes Partial 60 days
No No No Total Fix on system upgrade
No No No Partial Fix on system upgrade

7.3 Read the Organization’s timeframe #

Under its RA-5 parameters, the Organization sets a timeframe for every finding, with or without a CVE ID. The timeframe depends on the severity that the vulnerability scanner assigns.

Severity assigned by the platform Remediate within (calendar days from first detection)
Critical 30 days
High 30 days
Moderate 90 days
Low 180 days

7.4 Take the earliest deadline #

The due date is the start date plus the shortest of these deadlines:

  • The Table 1 timeline, for a finding with a CVE ID.
  • The Organization’s timeframe for the finding’s severity.
  • Any deadline in an Emergency Directive or other CISA direction.

The start date is the earlier of two dates: the date the vulnerability scanner first detected the finding, and the date CISA added its CVE ID to the KEV catalog.

“Fix on system upgrade” never extends an Organization timeframe. For example, a critical finding that Table 1 places at “fix on system upgrade” is still due in 30 days. CISA allows any agency to remediate faster than Table 1 requires, and the Organization’s timeframes are faster for many findings.

Within a timeline, the team may order the work using other exploitation data from the vulnerability scanner, such as the Exploit Prediction Scoring System (EPSS). The team never uses that data to move a due date later.

7.5 Re-check the due date when the facts change #

  • When CISA adds a finding’s CVE ID to the KEV catalog, the team moves the due date to the earlier of the current due date and the due date in the KEV catalog entry.
  • When the team learns that an asset is publicly exposed, it re-checks the due date, which usually becomes earlier.
  • When a mitigation changes a decision point, for example by removing the asset from the internet, the Table 1 timeline can become longer. The Organization’s timeframe stays the same.
  • The team records each due-date change on the ticket with the fact that changed. No one may move a due date later for any other reason.

7.6 Worked examples #

Situation Decision points Table 1 Organization timeframe Due in
Internet-facing firewall; CISA just added the flaw to the KEV catalog KEV: yes; exposed: yes; automatable: yes; impact: total 3 days and forensic triage Critical: 30 days 3 days and forensic triage
Internal file server; a KEV flaw KEV: yes; exposed: no; automatable: no; impact: partial 14 days High: 30 days 14 days
Web browser on laptops KEV: no; exposed: no; automatable: yes; impact: total 60 days Critical: 30 days 30 days
Internal database server KEV: no; exposed: no; automatable: no; impact: total Fix on system upgrade Moderate: 90 days 90 days
Public website KEV: no; exposed: yes; automatable: no; impact: partial 60 days Moderate: 90 days 60 days
Web application misconfiguration reported through the disclosure program No CVE ID Not applicable High: 30 days 30 days

Evidence: the decision-point answers and due date on each finding in the vulnerability scanner, and the due-date changes recorded on each ticket.

8. Triage Assets for Compromise #

The incident response team must triage every “3 days and forensic triage” finding and every asset where the SOC has seen exploitation. Administrators must remediate or mitigate the asset within 3 days. The incident response team must decide whether an attacker compromised it. The targets below are CISA’s recommended times, counted from the KEV addition (Implementation Guidance for Prioritizing Security Updates Based on Risk). CISA requires an adequate triage, and the targets are guidance. When the KEV entry gives its own triage steps, the team follows them.

Step Who Action Target
1. Scope Incident response team lead Activate the triage team. Identify the affected systems and services. Set up an out-of-band channel that does not use possibly compromised systems. Within 2 hours
2. Preserve and collect evidence Incident response team Capture volatile data, such as memory and network connections, first. Then collect persistent data from the systems in scope only. Where possible, change nothing before collection. Keep an evidence log of each item, its source system, the date and time, and the collector. 2 to 24 hours
3. Patch and stabilize Administrators, with the incident response team Apply the fix after evidence collection. Restore any critical business process that the patch disrupts. 2 to 24 hours
4. Contain and control Incident response team, with administrators Isolate affected and suspected systems without alerting the attacker. Coordinate containment with evidence collection. Record every action. 6 to 24 hours
5. Analyze Incident response team, with the SOC Look for unauthorized access, attacker presence, lateral movement, persistence, and data staging or theft. Verify each indicator of compromise and search for it elsewhere with the SIEM system and the EDR tools. 24 to 48 hours
6. Decide on escalation Incident response team lead and the CISO Write the forensic triage report and decide the outcome. 48 to 72 hours

The incident response team writes a forensic triage report with these parts:

  • The incident timeline.
  • The timeline of response actions.
  • The technical findings: who did what, where, and when.
  • The containment and mitigation done so far.
  • The recommended next steps.

The team keeps the report as a record with the incident. The team preserves logs as the Agency Logging Plan (PLAN-LOG-001) requires.

Triage result Required action
No evidence of compromise Administrators complete remediation within the timeline. The SOC increases monitoring of the asset in the SIEM system. The CISO reports as the directive requires. The incident response team runs the lessons-learned review.
Compromise suspected but not confirmed The incident response team keeps analyzing indicators and anomalies, decides whether to start full incident response, and coordinates with CISA.
Compromise confirmed The SOC Manager reports the incident to CISA within 1 hour through the CISA Incident Reporting Form, following the Federal Incident Notification Guidelines and the Incident Response Plan. The incident response team then starts full incident response.

High Value Assets and mission-critical systems. The System Owner of each HVA and mission-critical system keeps a plan for triaging and patching that system within 3 days. The Authorizing Official approves the plan. In it, the System Owner records an advance decision between keeping the system available and isolating it to protect its integrity.

Evidence: the forensic triage report, the evidence log, the incident record, and each approved HVA plan.

9. Fix or Mitigate Each Finding #

9.1 Open the remediation ticket #

For each vulnerability, or group with the same fix on the same system, the vulnerability scanner opens a remediation ticket in the ticketing system. On each ticket, the team records the CVE ID, the affected assets, the four decision-point answers, the due date, and the owning team.

9.2 Deliver fixes due in more than 3 days #

  • Endpoints: administrators release the update through the MDM tool deployment rings, first to a pilot group and then to everyone else. They confirm each endpoint’s update state in the MDM tool.
  • Servers, network devices, and cloud workloads: administrators test the update before production. They deploy it through a normal change that the Configuration Control Board approves.
  • Administrators record the change number and the completion on the ticket.
  • If an update fails or breaks a system, administrators roll it back under the change, apply a mitigation, and record both on the ticket. The original due date still applies.

9.3 Deliver fixes due in 3 days #

  • Administrators use the emergency change process in the Configuration Management Procedures (PROC-CM).
  • Administrators shorten the deployment rings so the pilot and the full release happen on the same day.
  • For a mission-critical system, administrators follow the plan that the Authorizing Official approved. They test critical systems by hand where needed and patch the rest through automation, so staff time goes to the critical systems.

9.4 Mitigate when a fix is not available in time #

  • For a vulnerability in the KEV catalog, the only accepted mitigation is the required action in its catalog entry. If administrators cannot complete that action by the due date, they must remove the asset from the network.
  • For any other vulnerability, administrators isolate it. They decommission the asset, remove the vulnerable software, segment or isolate the asset, or place it behind a software-defined perimeter or a proxy.
  • Administrators record the mitigation on the ticket, and the team re-checks the due date if a decision point changed. The team closes a finding only after remediation, so the finding stays open while a mitigation is in place.
  • When the flaw is in a component built into another vendor’s product, the System Owner gets the fix from the vendor that supplied the product.
  • Interim protections, such as EDR prevention rules, SIEM detections, or web application firewall rules, reduce risk while a fix is pending. They do not count as the KEV catalog’s required action. They change a due date only if they change a decision point.

9.5 Replace or isolate end-of-support software and devices #

Vendors no longer release security updates for end-of-support software and devices, so patching cannot fix them.

  • System Owners decommission end-of-support edge devices under the End-of-Support Edge Device Plan (PLAN-EOS-001) and BOD 26-02. The deadlines are:
    • By February 5, 2027: each device on CISA’s end-of-support list whose support ended on or before that date.
    • By August 5, 2027: every identified end-of-support edge device.
    • From February 5, 2028: each edge device on or before its end-of-support date.
  • System Owners replace or isolate other end-of-support software. The ISSO tracks it as a POA&M item until it is gone.
  • The CISO reports these counts in the Federal Information Security Modernization Act (FISMA) CIO metrics on end-of-life and end-of-support assets.

9.6 Secure management interfaces exposed to the internet #

BOD 23-02 covers management interfaces that anyone can reach from the internet, over the web, Secure Shell (SSH), Remote Desktop Protocol (RDP), Telnet, or another management protocol. Within 14 days of finding such an interface, or of a CISA report about it, the System Owner must take one of these two actions.

  • Take the interface off the internet, so that only an internal network can reach it. CISA recommends an isolated management network.
  • Protect the interface with zero trust access control, through a policy enforcement point separate from the interface. CISA prefers this action.

System Owners must make new devices meet this rule before they connect. BOD 23-02 does not cover the management portals of cloud service offerings.

9.7 Meet the cloud configuration baselines #

For cloud tenants in BOD 25-01 scope, administrators implement every mandatory SCuBA policy and report the SCuBA results to CISA. They meet each new mandatory policy by the date CISA sets. Administrators bring a new tenant up to the baselines and under continuous monitoring before it receives an authorization. The Authorizing Official may accept the risk of a deviation. Administrators explain each deviation in the results they report to CISA.

9.8 Fix weaknesses without a CVE ID #

The team gives misconfigurations, web application flaws, and weak identity settings the Organization’s timeframe for their severity. Administrators and ISSOs handle them with the same ticket, verification, and POA&M steps as every other finding.

Evidence: the remediation tickets with their change numbers and completion dates, the deployment records in the MDM tool, the mitigation records, and the end-of-support inventory.

10. Verify and Close Findings #

  1. The team closes a finding only after the vulnerability scanner stops detecting it, on the agent’s next report or a follow-up authenticated scan. For a decommissioned asset, the team closes the finding once the asset is gone from the inventory and from CDM.
  2. The team does not close a finding because an administrator marked its ticket done. If the vulnerability scanner still detects the vulnerability, the team reopens the ticket, and the original due date still applies.
  3. False positives. The ISSO documents why a finding is not real, with evidence such as the installed version or a configuration export. The vulnerability management team approves the exception in the vulnerability scanner, which suppresses the finding. The ISSO re-validates each suppression at the system’s annual assessment.
  4. Recurrence. The team treats a vulnerability that returns after closure as a new finding with a new due date. The ISSO records the cause, for example an image rebuilt from an old template, and opens a corrective ticket.
  5. The team measures the time from first detection to confirmed fix for every finding, using the dates in the vulnerability scanner, and compares it with the timeframes.

Evidence: the detection history in the vulnerability scanner for each closed finding, the reopened tickets, the approved false-positive exceptions with their evidence, and the corrective tickets for recurrences.

11. Handle Missed Due Dates and Risk Acceptance #

  1. When a finding will miss its due date, the ISSO opens a POA&M item in the GRC system no later than the due date. The ISSO follows the POA&M Management Procedure (PROC-POAM-001) and records the reason, the interim mitigation, and the completion date in the item.
  2. Each week, the CISO reviews past-due findings with System Owners. The CISO escalates any past-due finding with a directive deadline to the Authorizing Official at once.
  3. Risk acceptance. Only the CIO, as Authorizing Official, may accept the risk of an unremediated finding. The CIO records the acceptance in the GRC system, with the compensating controls and an expiration date.
  4. No extension of directive deadlines. The CIO cannot use a risk acceptance to extend a directive deadline, and CISA grants no waivers for directive actions. If administrators cannot remediate a KEV finding in time, they must apply the catalog’s required action or remove the asset from the network. For a special case, the CISO asks CISA for help and an agreed time frame at CyberDirectives@cisa.dhs.gov.
  5. The team keeps accepted and past-due findings visible in the vulnerability scanner. The team reports them to CISA where a directive’s reporting template requires it.

Evidence: the POA&M items, the signed risk acceptances in the GRC system, the weekly past-due review notes, and any correspondence with CISA.

12. Manage Vulnerabilities in Third-Party and Cloud Services #

  • The vulnerability management team keeps an inventory of the Organization’s systems that third parties host. This includes services authorized under the Federal Risk and Authorization Management Program (FedRAMP). The team gets vulnerability status from each provider through collaborative continuous monitoring.
  • FedRAMP-authorized services: the team works through the FedRAMP Program Management Office. FedRAMP requires providers to follow its Vulnerability Detection and Response (VDR) and Vulnerability Evaluation and Reporting (VER) rules, which carry out BOD 26-04, from December 7, 2026, with a grace period to March 7, 2027. The team reads the provider reports as described in Read FedRAMP Provider Vulnerability Reports.
  • Services without FedRAMP authorization: the System Owner works directly with the provider. The System Owner requires the provider to meet the same requirements and to document and report every deviation to the Organization.
  • Reporting: a commercial provider reports its outstanding vulnerabilities to the Organization, and the Organization reports them to CISA. When another federal agency provides the service, that agency reports to CISA.
  • Contracts: Contracting Officers review the contracts for systems in scope. They add the remediation deadlines and status reporting to service agreements that lack them.

The Organization’s share of vulnerability management depends on the service model:

Service model The Organization is responsible for
On premises, and infrastructure as a service All vulnerability management
Platform as a service Security oversight, identity, operations, access and authentication, guest operating systems, data and content, and audit logging. The provider handles network security.
Software as a service Access and authentication, data and content, and audit logging. The provider handles application security, identity, operations, and network protection.

Evidence: the inventory of systems that third parties host, the provider vulnerability reports, the FedRAMP continuous monitoring deliverables, and the contract clauses.

12.1 Read FedRAMP Provider Vulnerability Reports #

Each FedRAMP provider reports its vulnerability work at least monthly in a human-readable report (FedRAMP Consolidated Rules for 2026, VER-TFR-MHR). Most providers also offer the same data in a machine-readable format for automated retrieval (FedRAMP Consolidated Rules for 2026, VER-TFR-MRH). For each vulnerability, the report gives the PAIN rating, whether it is internet-reachable and likely exploitable, and whether it is overdue or accepted (FedRAMP Consolidated Rules for 2026, VER-RPT-VDT, VER-RPT-AVI).

Actor Action Tool Evidence Controls
Vulnerability management team 1. Retrieve each provider’s report at the interval the system’s authorization sets. Use the provider’s JavaScript Object Notation (JSON) data where offered (FedRAMP Consolidated Rules for 2026, VER-AGM-RVR). The GRC system Retrieved report RA-05, SA-09
Vulnerability management team 2. Filter for overdue and accepted vulnerabilities rated above N2, and for any vulnerability where the provider recommends agency mitigation. FedRAMP recommends starting there (FedRAMP Consolidated Rules for 2026, VER-AGM-RVR). The GRC system Filtered list RA-05
Vulnerability management team 3. Check each filtered vulnerability against the provider’s timeframe in the table below. Mark the ones past due. The GRC system Review record RA-05, SI-02
System Owner 4. Decide whether the Organization must act, such as by changing a setting the Organization controls or limiting its use of the feature. The ticketing system Decision record RA-07
System Owner 5. Open a POA&M item when the Organization mitigates the risk itself, or keeps using the service with an accepted vulnerability that puts its systems at risk (FedRAMP Consolidated Rules for 2026, VER-AGM-MAP). The GRC system POA&M item CA-05
Authorizing Official 6. Decide whether to keep using a service with that accepted vulnerability. Review the decision when it is added, and when the Organization’s use of the service changes (FedRAMP Consolidated Rules for 2026, VER-AGM-RVR). The GRC system Risk decision CA-06, RA-07
Vulnerability management team 7. When a provider treats an internet-reachable, likely exploitable vulnerability rated above N3 as a FedRAMP Reportable Incident, tell the Incident Response Team (FedRAMP Consolidated Rules for 2026, VER-TFR-IRI). The ticketing system Incident record IR-06
Contracting Officer 8. For a provider that misses its timeframes again and again, raise it with the FedRAMP Program Management Office and in the contract review. The ticketing system Escalation record SA-09

The provider’s timeframes run from evaluation and depend on its certification class (FedRAMP Consolidated Rules for 2026, VDR-TFR-PVR). FedRAMP says agencies should not treat the classes as one-for-one replacements for impact levels. Classes B and C cover most moderate systems:

Class PAIN rating Internet-reachable and likely exploitable Likely exploitable, not internet-reachable Not likely exploitable
B N5 4 days 8 days 32 days
B N4 8 days 32 days 64 days
B N3 32 days 64 days 192 days
B N2 96 days 160 days 192 days
C N5 2 days 4 days 16 days
C N4 4 days 8 days 64 days
C N3 16 days 32 days 128 days
C N2 48 days 128 days 192 days

N1 and N0 have no timeframe. The Organization’s own due dates in Set Each Finding’s Due Date apply to the parts of the service the Organization manages, by the service model table above. The same PAIN scale sets how fast a provider reports an incident to the Organization (FedRAMP Consolidated Rules for 2026, IEC-CSO-IIR).

Evidence: the retrieved reports, filtered lists, review records, POA&M items, risk decisions, incident records, and escalations.

13. Follow the Recurring Schedule #

Scanner agents, KEV matching, and SOC monitoring run all the time. Each role also does the following work on a fixed schedule.

When Who Work
Each working day Vulnerability management team Confirm that detection content is no more than 24 hours old and that the CDM feed is current. Review the decision-point answers on new findings. Review each finding due within 3 days with its owner.
Each week Vulnerability management team Reconcile coverage with the inventory and CDM, including agents that stopped reporting. Load and reconcile the Cyber Hygiene report. Run the authenticated scans and the missing-update check that are due.
Each week SOC Check the Cyber Hygiene source addresses in the weekly report against the SIEM system suppression rules.
Each week CISO, with System Owners Review past-due findings. Escalate any that have a directive deadline.
Every two weeks Vulnerability management team Until CISA receives KEV status through CDM automatically, report it by hand. From December 7, 2026, report every 7 days.
Each month, or as the authorization sets Vulnerability management team Read each FedRAMP provider’s vulnerability report, as described in Read FedRAMP Provider Vulnerability Reports.
Each month CISO Review the measures and the open risk acceptances.
Each quarter CISO Attest the Cyber Hygiene scope. Submit the FISMA CIO metrics.
Each year ISSOs, with the vulnerability management team Re-validate false-positive suppressions at each system’s assessment.
Each year System Owners of HVAs and mission-critical systems Review the 3-day triage and patching plan with the Authorizing Official.
Each year CISO Review this procedure and the Vulnerability Management Policy.

14. Report to CISA and OMB #

The owners below send these reports to CISA and the Office of Management and Budget (OMB):

Report When How Owner Required by
KEV vulnerability status Continuously Automated through the CDM Agency Dashboard. Until then, by hand every two weeks. From December 7, 2026, every 7 days in a machine-readable format CISA approves. Vulnerability management team BOD 26-04
Exposure tags for assets reachable from outside the network Continuously CDM, using CISA’s BOD 26-04 data schema and the four tags below Vulnerability management team and System Owners BOD 26-04
Cyber Hygiene scope attestation Quarterly, and on request Cyber Hygiene scope-change process, with additions and removals since the previous quarter CISO BOD 26-04
Cyber Hygiene acceptance letter On request The channel CISA names CISO BOD 26-04
Vulnerability management policy and procedures On request A copy to CISA CISO BOD 26-04
Asset discovery and enumeration attestation When CISA issues the tasking CyberScope CISO BOD 23-01
Discovery or enumeration results that CISA requests Within 7 days of the request As CISA directs Vulnerability management team BOD 23-01
End-of-support edge device inventory and decommissioning At each BOD 26-02 milestone CISA’s template System Owners and the CISO BOD 26-02
SCuBA assessment results Continuously, or quarterly Automated feed, or a machine-readable file Cloud administrators BOD 25-01
Emergency Directive status As each directive requires As each directive requires The directive’s owner Each Emergency Directive
Confirmed compromise Within 1 hour of identification, as the Federal Incident Notification Guidelines require CISA Incident Reporting Form at https://myservices.cisa.gov/irf SOC Manager Incident Response Plan
FISMA CIO metrics Quarterly and annually CyberScope. The CISO checks the items that CDM fills in before submission. CISO FISMA CIO metrics, fiscal years 2026 and 2027

Exposure tags. System Owners tag each asset reachable from outside the network with four values. The values are organization and sub-organization, environment (production or development), exposure (public or internal), and asset type (server, application, or network device). System Owners set them as scanner asset tags, and the team sends the same tags to CDM. The team reports every asset to CDM with all its IP addresses, including private ones.

CISA contacts:

  • CyberDirectives@cisa.dhs.gov: directive questions and special cases.
  • central@cisa.dhs.gov: signs of compromise a directive asks for. The incident report itself goes through the CISA Incident Reporting Form.
  • vulnerability@cisa.dhs.gov: Cyber Hygiene.

Evidence: each submitted report with its date, the CDM submission records, and the CISO’s attestations.

15. Measure Performance #

The CISO tracks the program with these measures:

Measure How the team computes it Target Reported
KEV mean time to remediate Average days from the later of first detection or KEV addition to confirmed remediation (CIO-FY26-0121) Every finding within its due date FISMA CIO metrics, from CDM
Findings fixed by their due date Findings closed by their due date, divided by findings due in the period, by Table 1 timeline and by severity 100 percent To the CISO monthly
Past-due findings Open findings past their due date, by timeline, severity, system, and days overdue None with a directive deadline To the CISO weekly
Devices scanned within 7 and 14 days Share of CDM devices with a scan in each window (CIO-FY26-0016 to 0019) 100 percent within 14 days FISMA CIO metrics, from CDM
Authenticated coverage Assets with a successful credentialed scan or agent report, divided by assets in scope 100 percent To the CISO monthly
Detection content age Hours between the vendor’s latest content release and the content in the vulnerability scanner 24 hours or less Checked daily
Exposure tagging Publicly exposed assets with all four tags, divided by publicly exposed assets 100 percent by December 7, 2026 To the CISO monthly
Forensic triage on time “3 days and forensic triage” findings with a finished triage report within 72 hours, divided by all such findings 100 percent To the CISO for each event
HVAs with critical findings past due HVAs with a critical finding past its due date, divided by all HVAs (CIO-FY26-0064) 0 percent FISMA CIO metrics
End-of-support assets Counts of end-of-life and end-of-support software and edge devices (CIO-FY26-0020 to 0024) Zero by the BOD 26-02 dates FISMA CIO metrics
Open risk acceptances Number open, and the age of the oldest None past expiration To the CISO monthly
Recurrence Findings that return after closure, divided by findings closed Falling each quarter To the CISO quarterly

16. Keep Records #

Each record is kept in the system below. The record owners keep records under the Organization’s records schedule.

Record Kept in
Findings; detection and fix dates; coverage and authentication results; false-positive suppressions The vulnerability scanner
Remediation tickets, change records, coverage-gap tickets, and disclosure reports The ticketing system
POA&M items and risk acceptances The GRC system
Forensic triage reports and evidence logs The incident record, under the Incident Response Plan
Directive reports, attestations, CISA correspondence, and the monthly measures report The CISO’s document library in the document management system

18. References #

These are the sources this document cites, with a link to each official text.

Sources on the governance tracker

The FedXchange governance tracker follows each source this document cites and records each change to it.

Change history

  1. : First published in the library. Template version 783d0494946e.