TL;DR: Continuous Monitoring in RMF
Continuous monitoring in the Risk Management Framework (RMF) is a recurring process that ensures security and privacy controls remain effective over time. It blends automated tools with manual assessments to verify that controls are correctly implemented, operating as intended, and aligned with evolving threats and system changes.
Monitoring frequency and methods vary based on risk and control criticality—not all activities occur in real time. However, in high-assurance environments like DoD’s Continuous Authorization to Operate (cATO), real-time or near real-time monitoring is a requirement to support rapid risk-based decisions.
Common RMF continuous monitoring activities include configuration management, security impact analysis, and ongoing assessments or audits. These activities inform Authorizing Officials (AOs) of the system's current risk posture and support reauthorization or, in advanced cases, enable ongoing authorization through cATO.
What Is Continuous Monitoring in RMF?
Under RMF Step 7 (Monitor), organizations implement a Continuous Monitoring Strategy to detect and respond to changes that affect a system’s security and privacy posture. Key activities include:
- 🔧 Configuration Management and Control
Track hardware, software, and system settings to ensure all changes are authorized, documented, and do not introduce unmanaged risks. - 🔍 Security Impact Analysis
Assess how changes—such as software updates, infrastructure modifications, or new integrations—may alter the security baseline and require control updates. - ✅ Security Control Assessment
Conduct periodic vulnerability scans, audits, penetration tests, and control effectiveness checks to confirm continued compliance and risk mitigation.
These efforts help ensure controls remain appropriate over time and allow Authorizing Officials to make informed, ongoing risk decisions. For DoD systems pursuing cATO, this level of mature, automated monitoring is a foundational requirement.
What Is Meant by Continuous Monitoring?
Continuous monitoring refers to the ongoing process of tracking and evaluating the security and privacy status of an information system. It promotes effective, near real-time risk management with automation and modern practices to monitor controls and changes to the system or the environment so an Authorizing Official (AO) can determine whether to authorize the continued operation of a system or the use of inherited common controls. Continuous monitoring contributes to ongoing authorization with information to support ongoing risk determinations after the initial system or common control authorization.
What Is Continuous Monitoring in RMF?
An RMF continuous monitoring plan involves real-time detecting, reporting, and responding to changes that may affect a system’s security posture, using information from security controls. It may include activities like:
- Configuration management and control to track all hardware and software configurations, ensuring changes prevent unauthorized modifications.
- Security impact analysis to understand how modifications, like software updates or hardware upgrades, affect the system’s overall security.
- Assessment of security controls with regular scans and audits to detect vulnerabilities and deviations from security policies.
Organizations must evaluate controls for correct implementation, operation, and efficacy with regard to security or privacy requirements.
What Is the RMF Continuous Monitoring Strategy?
An RMF continuous monitoring strategy defines the monitoring frequency for implemented controls, the approach to ongoing control assessment, and how or what tools will be in place to conduct ongoing assessments. The strategy may also define the security and privacy reporting requirements and recipients. Key components of this strategy include establishing a security baseline, conducting regular security control assessments, utilizing automated tools for continuous monitoring, and implementing incident response procedures.
This short RMF continuous monitoring checklist demonstrates what this strategy typically involves:
- Establish a Baseline: Defining the initial security posture of the system and environment of operation.
- Ongoing Assessments: Regularly evaluating the effectiveness of controls (either implemented or inherited).
- Ongoing Risk Response: Identifying mitigation actions or risk acceptance decisions based on ongoing monitoring, risk assessments, incomplete plans of action/milestones.
- Reporting and Documentation: Updating plans, assessment reports, and plans and action/milestones based on the results of continuous monitoring. Regularly reporitng the security and privacy posture of the system to the AO and organizational leadership.
What Is an Example of Continuous Monitoring?
Let’s consider a continuous monitoring example in a U.S. Air Force setting for a system that monitors the integrity of flight operations. The system employs machine learning and AI to continuously analyze network traffic, user behaviors, and system activities.
The system scans for anomalies such as unusual login attempts, unauthorized data access, or irregular communication patterns between devices. If the system detects a potential threat, such as an attempt to access classified flight operation plans from an unauthorized device, it immediately alerts the cybersecurity team. The team can then take swift action to investigate and neutralize the threat, ensuring the security of sensitive information.Using an RMF continuous monitoring plan template, the Air Force outlines the specific steps for deploying and maintaining this threat detection system. This template includes setting up automated monitoring tools, conducting regular vulnerability assessments, implementing compliance checks, and detailing incident response protocols. By following this plan, the Air Force ensures its flight operations network remains secure and resilient against cyber threats, demonstrating the effectiveness of continuous monitoring in maintaining national security.
Achieve Continuous Monitoring with Rise8
Ongoing authorization, or cATO, is a disciplined approach to constantly understanding a system’s risk profile based on building trust through transparency and enabling technologies that create a secure, compliant, agile environment. With the right partner, you can regain control of your digital transformation initiatives and deliver high-quality software with reduced risk, faster than you ever have before.
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