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Step 2: Select

Select turns the security category into a tailored, allocated control set, written down in the security and privacy plans (SSP) the AO approves. The SSP becomes the contract the assessor tests against, so this is where most ATO effort goes. Source: SP 800-37 Rev. 2, section 3.3.

TaskWhat it means in practicePrimary roleOutput
S-1 Control selectionStart from the SP 800-53B baseline for your impact level, plus any required overlaysSystem owner, CCPInitial control set
S-2 Control tailoringAdjust the baseline: mark common controls, apply scoping, pick compensating controls, set parameter values, add controls for specific risksSystem owner, CCPTailored baseline with rationale
S-3 Control allocationDecide where each control lives: system-specific, hybrid or common (inherited)Security architect, system owner, CCPAllocation matrix
S-4 Planned implementation documentationDescribe how each control will be met, by whom, and at what statusSystem owner, CCPSecurity and privacy plans
S-5 Continuous monitoring strategy, systemSay how each control will be monitored and how oftenSystem owner, CCPSystem ConMon strategy
S-6 Plan review and approvalAO reviews the plans for completeness and risk fitAOApproved SSP and ConMon strategy

SP 800-53B gives Low, Moderate and High security baselines and a separate privacy baseline, applied when the system processes PII. The catalog itself is SP 800-53 Rev. 5, now at release 5.2.0. Every control page in this guide shows which baselines include it.

Overlays add or remove controls for a context. Common ones are CNSSI 1253 overlays for national security systems (privacy, classified information, space and others), FedRAMP baselines for cloud, and organization overlays from task P-4.

FamilyCoversFamilyCovers
ACAccess controlPEPhysical and environmental protection
ATAwareness and trainingPLPlanning
AUAudit and accountabilityPMProgram management (organization level)
CAAssessment, authorization and monitoringPSPersonnel security
CMConfiguration managementPTPII processing and transparency
CPContingency planningRARisk assessment
IAIdentification and authenticationSASystem and services acquisition
IRIncident responseSCSystem and communications protection
MAMaintenanceSISystem and information integrity
MPMedia protectionSRSupply chain risk management

Inherit first, then build. Pull the common control catalog from Prepare (task P-5). For each baseline control, decide whether it is fully inherited (for example, PE controls from a data center or cloud provider), hybrid (the provider does part, you do part) or system-specific. Record the provider and its authorization for every inherited piece.

Tailor in writing. Every removed or modified control needs a rationale the AO can accept, such as “not applicable: no wireless in the boundary” for AC-18. Compensating controls must give equivalent protection and cite why the original cannot be met.

Fill every parameter. Organization-defined parameters (ODPs) are the blanks inside controls, such as how often accounts are reviewed under AC-2. Most are set by agency policy; cite it. Blank ODPs are an immediate assessment finding.

Write implementation statements an assessor can test. A good statement says who does what, with which tool, how often, and where the evidence is. Weak: “The organization reviews audit logs.” Strong: “The ISSO reviews Splunk alerts daily and privileged-user activity weekly; review notes are kept in ticket queue SEC-AUDIT.”

Plan the attachments now. A complete SSP usually attaches or references the documents below; many are also controls in their own right.

AttachmentRelated controlsTypical owner
Security and privacy policies and proceduresThe -1 control in every familyCISO office, system owner
Hardware and software inventoryCM-8System owner
Configuration management planCM-9System owner
Contingency plan and business impact analysisCP-2, CP-4System owner
Incident response planIR-8ISSO, CISO office
Privacy impact assessment and SORNRA-8, PT-5Privacy officer
Rules of behaviorPL-4System owner
Interconnection agreementsCA-3System owner
Supply chain risk management planSR-2System owner, acquisition
Continuous monitoring strategyCA-7System owner, ISSO

Design the ConMon strategy for automation. For each control, choose a frequency and method (automated scan, log check, manual review). Put volatile controls such as vulnerability scanning (RA-5) and configuration checks (CM-6) on automated weekly or monthly cycles; stable ones such as physical access policy can run annually. Use SP 800-137A to judge the strategy.

Consider OSCAL. Machine-readable plans in OSCAL make assessment and monitoring faster and are becoming required in FedRAMP.

  • Implementation statements that restate the control text instead of describing the system.
  • Controls marked “inherited” with no provider authorization to point to.
  • Controls marked “implemented” in Select that do not exist yet.
  • Tailoring by deletion with no rationale.
  • Policies and procedures (the -1 controls) missing or never reviewed.

SP 800-53 Rev. 5, SP 800-53B, SP 800-18 Rev. 2 (system plan guide), SP 800-137A, CNSSI 1253, OSCAL, SP 800-37 Rev. 2 section 3.3.

Independent guidance, not an official NIST publication. Control text is from NIST SP 800-53 Rev. 5 and SP 800-53A (public domain). Original content is licensed CC BY 4.0; program templates and the downloadable kit are dedicated to the public domain under CC0 1.0.