Episode 46 — Manage Deviation Requests and Exceptions

Deviation Requests and exceptions are the formal mechanisms FedRAMP uses to handle situations where a weakness cannot be remediated on the normal timeline, where an alternate control achieves equivalent protection, or where a scanner-reported issue is a verified false positive. This episode explains the difference between common categories—due-date extensions tied to POA&M items, risk adjustments based on compensating safeguards, vendor dependencies that constrain patch windows, and false positives with corroborating evidence—and shows how each maps to required fields and approvals. We describe the core argument structure: state the weakness precisely, quantify exposure and blast radius, present compensating controls with operating evidence, estimate residual risk, and propose a milestone plan with review dates. The objective is not to “paper over” risk but to make a transparent, auditable case that keeps authorization integrity while acknowledging real-world constraints and engineering timelines.

Execution quality turns a request from delay paperwork into a disciplined risk decision. We outline evidence packages that support each type: authenticated rescans showing non-exploitation and segmentation, configuration exports proving control layering, monitoring dashboards that flag attempted abuse, vendor bulletins and ticket histories, and sign-offs from the system owner and authorizing official. We cover pitfalls that trigger rejections—reusing boilerplate rationales, omitting asset identifiers, failing to quantify detection/response strength, or asking for open-ended extensions—and offer review practices that keep requests concise, consistent, and traceable. Finally, we explain how to track approvals in the POA&M, publish follow-through metrics, and close deviations promptly when conditions change. Managed well, deviations become rare, time-boxed exceptions inside a program that still demonstrates steady risk reduction. Produced by BareMetalCyber.com, where you’ll find more cyber audio courses, books, and information to strengthen your educational path. Also, if you want to stay up to date with the latest news, visit DailyCyber.News for a newsletter you can use, and a daily podcast you can commute with.