SC-21 System and Communications Protection

Secure Name / Address Resolution Service (Recursive or Caching Resolver)

High Risk Moderate Medium Cost

SC-21 requires recursive or caching resolvers to perform data origin authentication and integrity verification when resolving names (typically DNSSEC validation) and to handle validation failures in a defined way. Clinical endpoints that trust open or non-validating resolvers can be steered to malicious EHR lookalikes, rogue update servers, or attacker-controlled APIs.

Control Objective

Ensure organizational recursive/caching resolvers used by ePHI systems authenticate and integrity-check resolution data and fail closed per policy when validation fails.

Implementation Guidance

  1. Standardize recursive resolvers for clinical VLANs, servers, and VDI (no ad-hoc public DNS on EHR subnets).
  2. Enable DNSSEC validation on resolvers; define failure behavior (serve SERVFAIL vs insecure fallback—document risk acceptance if fallback allowed).
  3. Disable recursion on authoritative-only nodes; keep roles distinct (SC-22).
  4. Block outbound client DNS to the Internet from clinical networks except via approved resolvers.
  5. Log resolution anomalies and validation failures to SIEM.
  6. Protect resolver admin planes; patch resolver software promptly.
  7. Cover container/cloud workloads that resolve names for ePHI microservices.
  8. Test phishing/malicious domain scenarios and validation failure handling.

Real-World Use Cases

How this control shows up in healthcare and HIPAA-covered environments.

Nursing PC forced through validating resolvers

Floor workstations use only hospital validating resolvers; attempts to set 8.8.8.8 via local config are blocked by GPO/MDM, reducing DNS spoof paths to the EHR.

Validation failure on forged EHR alias

A forged signed-looking response fails validation; SC-21 resolvers return failure instead of quietly resolving to an attacker IP hosting a credential harvester.

Imaging modality name lookup

PACS modalities use approved recursive services so study send destinations resolve consistently and securely during overnight batches.

Best Practices

  • Force clinical traffic through enterprise validating resolvers.
  • Document validation failure policy.
  • Separate recursive vs authoritative roles.
  • Monitor SERVFAIL spikes.
  • Patch resolvers like any ePHI-supporting infra.
  • Align with SC-20 signing on authoritative side.

Common Gaps & Violations

  • Clinical devices using public DNS.
  • Validation disabled "for compatibility."
  • Authoritative servers also open recursive to the world.
  • No logging of DNS anomalies.
  • IoT/biomed on open resolvers with no control.

Required Documentation

  • Recursive resolver security standard (SC-21)
  • Resolver architecture diagram (clinical paths)
  • DNSSEC validation and failure-handling policy
  • Egress DNS firewall rules evidence
  • Monitoring/alert definitions

How to Test & Validate

  1. From a clinical test host, confirm only approved resolvers are reachable.
  2. Query a known-bad/unsigned test case per policy; observe expected failure/fallback.
  3. Verify recursion is disabled on authoritative-only servers.
  4. Review SIEM for resolver validation events.
  5. Spot-check biomed VLAN DNS settings.

Audit Considerations

Ask where nursing stations resolve names. If the answer is \"whatever the ISP or public DNS returns,\" SC-21 is not operating for ePHI workstations.

HIPAA Mapping

How this NIST control supports HIPAA Security Rule expectations.

  • 164.312(e) Transmission Security — correct endpoint resolution supports confidential transmission.
  • 164.312(c) Integrity — resolver integrity protects against redirected sessions.
  • 164.308(a)(1) Risk Management — DNS spoofing is a recognized residual risk.
  • 164.312(a) Access Control — users must reach authorized systems, not impostors.

Compliance Tips

  • Ban public DNS on ePHI VLANs in the network standard.
  • Include resolver validation in annual technical control tests.
  • Coordinate SC-21 with Zero Trust DNS/web gateway designs.

Frequently Asked Questions

How does SC-21 differ from SC-20?

SC-20 secures authoritative sources; SC-21 secures recursive/caching resolvers that clients use.

Can we use a secure cloud DNS resolver?

Yes if it provides required authentication/integrity properties, is covered by BA/contract as needed, and clinical egress is forced through it.

What if a legacy modality breaks on DNSSEC validation?

Document exception, compensating controls, and remediation timeline—do not disable validation enterprise-wide.

References & Resources

  • NIST SP 800-53 Rev. 5 — SC-21
  • Related controls: SC-20, SC-22, SC-7, SI-4
  • NIST SP 800-81

Need Help Implementing SC-21?

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