13 Jul 2026CMMC Phase II suspended: no C3PAO assessments can be designated. DFARS 7012 and Rev 2 still apply.What changed, and what did not

NIST SP 800-171 Rev 2 · 3.13 System & Communications Protection

3.13.3 Separate user and management functions

Separate user functionality from system management functionality.
SPRS weight
1
1 point deducted from 110 when not implemented.
CMMC level
L2
Level 2 only; not among the 17 Level 1 practices.
Assessment objectives
3
From NIST SP 800-171A, each one a “determine if” an assessor answers.

What an assessor checks

NIST SP 800-171A breaks 3.13.3 into 3 objectives. Every one has to be met for the requirement to be met; a partial answer scores as not implemented.

  1. [a]Determine if user functionality is identified.
  2. [b]Determine if system management functionality is identified.
  3. [c]Determine if user functionality is separated from system management functionality.
Examine
[SELECT FROM: System and communications protection policy; procedures addressing application partitioning; system design documentation; system configuration settings and associated documentation; security plan; system audit logs and records; other relevant documents or records].
Interview
[SELECT FROM: System or network administrators; personnel with information security responsibilities; system developer].
Test
[SELECT FROM: Separation of user functionality from system management functionality].

If it is open: POA&M eligibility

May be carried on a Level 2 POA&M · 1 point deducted

A 1-point requirement outside the six named exclusions - eligible to carry, and NOT MET until a closeout assessment confirms it.

A POA&M is only permitted at a score of 88 or above, and closes in one 180-day window. Check a full gap list or compute your score.

Where 3.13.3 maps

NIST SP 800-53 Rev 5

  • SC-2 Application Partitioning
  • SC-39 Process Isolation

NIST CSF 2.0

No direct mapping.

SOC 2

No direct mapping.

Query it from your own tools

This page and the MacTech CMMC MCP server render the same dataset. Ask your assistant and it will answer from the methodology, not from memory.

lookup_control 3.13.3
get_assessment_objectives 3.13.3
generate_poam_entries ["3.13.3"]

Install the MCP server, free, no account.

From MacZine

Working notes on System & Communications Protection

The full run →