Instructions: This template satisfies the CA-7 requirement for a system-level Continuous Monitoring Strategy. Fields marked with yellow highlight must be completed by the organization. Axiom-automated sections are pre-populated with current platform capabilities.
1. Purpose and Scope
This Continuous Monitoring Strategy defines the ongoing assessment, monitoring, and reporting requirements for [System Name] operated by [Organization Name]. It establishes monitoring frequencies, metrics, response actions, and reporting cadences to maintain the security authorization granted by the Authorizing Official.
This strategy is developed in accordance with NIST SP 800-137, NIST SP 800-53 CA-7, and the organization's Risk Management Framework implementation.
1.1 System Identification
| System Name | [System Name] |
| System Owner | [Name, Title] |
| Authorizing Official | [Name, Title] |
| ISSO | [Name, Title] |
| Authorization Date | [Date] |
| Authorization Type | [ATO / IATT / IATO] |
| FIPS 199 Categorization | [LOW / MODERATE / HIGH] |
2. Monitoring Approach
The system employs a hybrid monitoring approach combining automated continuous assessment with periodic manual review:
- Automated Technical Monitoring: Axiom Sovereign Engine performs agentless evidence collection across 123 technical controls every 4 hours. Each scan produces cryptographic SWT3 witness anchors that are immutable and independently verifiable.
- Manual Assessment: Non-technical controls (physical security, personnel, training) are assessed on defined schedules by designated personnel and documented via attestation.
- Vulnerability Management: Trivy scans execute daily at 04:00 UTC. Findings auto-sync to POA&M with severity-based milestones (CAT I: 30 days, CAT II: 60 days, CAT III: 90 days).
3. Monitoring Frequencies by Control Family
NIST 800-53 CA-7(b) requires defined monitoring frequencies per control. Different control types require different monitoring cadences. The following table establishes the frequency and justification for each family.
| Control Family | Frequency | Method | Justification |
|---|
| AC (Access Control) | Every 4 hours |
AUTOMATED |
Access violations are high-impact. Continuous scanning detects unauthorized accounts, stale credentials, and privilege changes. |
| AU (Audit) | Every 4 hours |
AUTOMATED |
Audit log integrity is foundational. Automated checks verify log generation, storage capacity, and retention compliance. |
| CA (Assessment) | Every 4 hours |
AUTOMATED |
Continuous assessment is the core CA-7 requirement. Axiom implements this directly via automated scan cadence. |
| CM (Configuration) | Every 4 hours |
AUTOMATED |
Configuration drift detection requires high-frequency monitoring. Changes to baselines are flagged immediately. |
| CP (Contingency) | Quarterly |
MANUAL |
Backup and recovery testing requires physical execution. Attestation-based, reviewed quarterly by ISSO. |
| IA (Identification) | Every 4 hours |
AUTOMATED |
Authentication mechanisms (MFA, password policy) verified continuously via automated probes. |
| IR (Incident Response) | Annually + event-driven |
MANUAL |
IR plan review is annual. Tabletop exercises require human coordination. Event-driven assessment after any incident. |
| MA (Maintenance) | Every 4 hours |
AUTOMATED |
System update status and patch levels verified continuously. |
| MP (Media Protection) | Quarterly |
MANUAL |
Physical media handling requires manual verification. Attestation-based. |
| PE (Physical/Environmental) | Quarterly |
MANUAL |
Physical access controls, facility security, and environmental protections require on-site inspection. |
| PL (Planning) | Annually |
MANUAL |
Security plan review is an annual activity tied to re-authorization cycle. |
| PS (Personnel Security) | Quarterly |
MANUAL |
Background check status and access termination require HR system verification. Attestation-based. |
| RA (Risk Assessment) | Every 4 hours (vuln scan) + Annually (full RA) |
AUTOMATED + MANUAL |
Vulnerability scanning automated daily. Full risk assessment is an annual activity with human analysis. |
| SA (System Acquisition) | Every 4 hours + Quarterly |
AUTOMATED + MANUAL |
Supply chain scanning automated (Trivy 5-layer). Vendor contract review is quarterly. |
| SC (System Communications) | Every 4 hours |
AUTOMATED |
TLS configuration, boundary protection, and network segmentation verified continuously. |
| SI (System Integrity) | Every 4 hours |
AUTOMATED |
Flaw remediation, malicious code protection, and integrity monitoring verified continuously. |
| AT (Awareness Training) | Annually |
MANUAL |
Training completion requires LMS verification. Annual cycle aligned with onboarding and refresher schedule. |
| AI (AI Governance) | Per-inference (real-time) |
AUTOMATED |
SWT3 witness anchors are minted per inference. 43 AI procedures cover model integrity, fairness, explainability, and security. |
4. Metrics and Thresholds
4.1 Automated Metrics (Axiom-Generated)
| Metric | Source | Threshold | Response Action |
|---|
| Sovereign Score | Posture API |
Below 90%: WARN. Below 80%: FAIL. |
ISSO notified. Gap analysis initiated. AO briefed within 48 hours if FAIL. |
| Overdue POA&M Items | POA&M API |
Any CAT I overdue: Immediate escalation. |
ISSO escalates to AO. Remediation sprint initiated. |
| CRITICAL/HIGH CVEs | Trivy scan |
CRITICAL: 7-day remediation. HIGH: 30-day. |
Auto-POA&M creation. ISSO review within 24 hours for CRITICAL. |
| Scan Freshness | Health API |
Last scan older than 24 hours: WARN. |
Investigate scan pipeline. Manual scan if automated cadence failed. |
| AI Model Drift | AI Witness API |
AI-MDL.3 factor_c negative (degradation detected). |
Model review. Potential rollback. ISSO documents in POA&M. |
4.2 Manual Metrics
| Metric | Frequency | Responsible | Threshold |
|---|
| Security training completion rate | Annually |
[Training Manager] |
100% within 30 days of onboarding or annual refresher date. |
| Background check currency | Quarterly |
[HR / Security Manager] |
All personnel with system access have current investigation. |
| Physical access review | Quarterly |
[Facility Security Officer] |
Access lists reviewed and attested. Terminated personnel removed within 24 hours. |
| Contingency plan test | Annually |
[ISSO / ISSM] |
Test executed. After-action report completed. Lessons learned documented. |
5. Response Actions
Per CA-7(f), the following response actions address results of control assessment and monitoring:
- Automated Response: FAIL verdicts auto-open POA&M items with severity-based milestones. PASS verdicts auto-close with cryptographic closure anchors. No manual intervention required.
- ISSO Triage: ISSO reviews new FAIL items within 24 hours (CAT I) or 72 hours (CAT II/III). Assigns responsible party, estimated cost, and remediation plan.
- AO Escalation: Any CAT I finding overdue beyond milestone, or Sovereign Score below 80%, triggers AO briefing within 48 hours.
- Risk Acceptance: Items that cannot be remediated require formal AO risk acceptance with written justification (available for IATT/IATO authorization types only).
- Re-Authorization Trigger: Significant changes to the system (new AI models, infrastructure migration, new interconnections) trigger re-assessment per CA-6.
6. Reporting
| Report | Audience | Frequency | Source |
|---|
| Executive Summary | AO, System Owner | Monthly | GET /api/v1/executive-summary |
| Gap-to-Green Roadmap | ISSO, ISSM | After each assessment | GET /api/v1/gap-to-green |
| POA&M Status | AO, ISSO, C3PAO | Monthly | GET /api/v1/poam/export |
| Vulnerability Report | ISSO, System Admin | After each scan | GET /api/v1/cve/export |
| OSCAL Assessment Results | C3PAO, eMASS | Quarterly | GET /api/v1/ar/export |
| AI Witness Posture | ISSO, AI Governance Board | Monthly | GET /api/v1/ai-witness/export |
7. Roles and Responsibilities
| Role | ConMon Responsibility | Assigned To |
|---|
| Authorizing Official | Reviews monthly posture reports. Accepts residual risk. Triggers re-authorization when warranted. | [Name] |
| ISSO | Triages new findings within SLA. Assigns responsible parties. Manages POA&M lifecycle. Conducts manual assessments. | [Name] |
| ISSM | Reviews ConMon strategy annually. Coordinates with C3PAO. Oversees attestation controls. | [Name] |
| System Administrator | Remediates technical findings per POA&M milestones. Verifies fixes via re-scan. | [Name] |
| Security Engineer | Maintains scan infrastructure. Investigates scan failures. Updates remediation library. | [Name] |
8. Strategy Review and Update
This Continuous Monitoring Strategy shall be reviewed and updated:
- Annually, as part of the re-authorization cycle
- After any significant system change (new interconnections, infrastructure migration, new AI models)
- After any security incident requiring IR plan activation
- When directed by the AO based on risk posture changes
| Version | Date | Author | Changes |
|---|
| 1.0 | [Date] | [ISSO Name] | Initial ConMon strategy |
9. Approval
| Role | Name | Signature | Date |
|---|
| Authorizing Official | [Name] | [Signature] | [Date] |
| ISSO | [Name] | [Signature] | [Date] |
| System Owner | [Name] | [Signature] | [Date] |
This guide is provided for informational purposes only and does not constitute legal, regulatory, or compliance advice. Regulatory mappings and crosswalk interpretations reflect the publisher's analysis and may not address all obligations applicable to your organization. Consult qualified legal counsel before making compliance decisions based on this content.