EXECUTIVE BRIEF
For contractors seeking their Cybersecurity Maturity Model Certification (CMMC) Certificate of Status, a Plan of Action & Milestones (POA&M) is a critical document. It’s a structured tool for documenting security issues, managing risk, and tracking corrective actions across information systems in government and regulated environments.
This post explains how POA&Ms support risk management and governance, how they map to security controls and assessment findings, and how to manage them effectively over time.
You’ll learn:
- How POA&Ms fit into National Institute of Standards and Technology (NIST), CMMC, and related compliance frameworks
- How to document vulnerabilities, mitigation strategies, and ownership
- How to manage milestones, completion dates, and ongoing remediation
Whether you’re preparing for an assessment or strengthening day-to-day security operations, this guide outlines how to build POA&Ms that are clear, defensible, and audit-ready.
Dig deeper and continue reading below!
A Plan of Action & Milestones (POA&M) is a critical document for any organization seeking to address identified weaknesses or deficiencies. Whether it's improving cybersecurity, enhancing operational efficiency, or complying with regulatory requirements, a well-structured POA&M provides a roadmap for successful remediation. This guide will walk you through creating an effective POA&M, from identifying and prioritizing issues to setting realistic and achievable milestones that drive progress and ensure successful outcomes.
What Is a POA&M (Plan of Action & Milestones)?
A Plan of Action and Milestones (POA&M) is a critical document for any organization seeking to address identified weaknesses or deficiencies. A POA&M document enumerates the identified gaps in your system and outlines the remediation actions and timelines your organization will follow to address them. Whether it's improving cybersecurity, enhancing operational efficiency, or complying with regulatory requirements, a well-structured POA&M provides a roadmap for successful remediation. Think of it as your itinerary for achieving compliance.
What Should a POA&M Include?
A POA&M should comprehensively document all unmet controls, or deficiencies affecting your organization’s cybersecurity compliance posturing. Your POA&M should:
- Name the regulation your organization is benchmarking your compliance posture against
- Document deficiencies in your cybersecurity tools and software, processes and procedures, and resources and training
- Assign criticality scores to each unmet control
- Outline the remediation plan and timeline for each unmet control
- Identify the cost associated with each remediation task
- Assign a point of contact responsible for each task
- Provide a summary report of the POA&M
ISI Insight: If you’re working with a CMMC Managed IT Provider, like ISI, completing a gap assessment and developing a POA&M will be a core deliverable at the beginning of your services.
POA&Ms in the context of risk management and governance
In U.S. federal and defense contracting contexts, POA&Ms play a critical role in how organizations demonstrate accountability for unresolved security issues while continuing to operate. They’re an expected part of an organization’s broader risk management framework, helping leadership understand where risk exists within their information systems and how that risk is being addressed. Oversight bodies such as the Office of Management and Budget (OMB) rely on POA&Ms to ensure agencies and contractors aren’t ignoring known gaps in information security, but instead are actively managing them.
POA&Ms are also closely aligned with guidance from NIST Special Publications (SP), which emphasize documenting security weaknesses, assessing impact, and applying mitigation strategies over time rather than assuming all issues can be resolved immediately. In many cases, POA&Ms support risk-based decision-making by allowing an Authorizing Official to formally accept a defined level of risk while corrective actions are underway.
In this way, a POA&M functions as both a compliance artifact and a governance tool: connecting technical findings to executive-level risk decisions, and ensuring that remediation efforts are visible, prioritized, and tracked within a structured management process.
The Importance of POA&Ms for DoD Contractors
One of the key updates in the final CMMC rule was the allowance of POA&Ms for conditional Level 2 certification. Conditional certification allows defense contractors to place low-level unmet controls on a POA&M and accept award of new defense contracts. However, within 180 days of being issued conditional certification, you must remediate these controls and pass a POA&M close-out assessment to achieve final certification. If not, your conditional certification will end and you will be removed from the contract you’re working on and will have to restart your compliance journey.
ISI Insight: A key thing to note about CMMC POA&M requirements is that controls worth 3-5 points are not allowed on a POA&M. There are a select few 1-point controls that are also not permitted, but making sure those 3- and 5-point controls are satisfied is a great place to start.
The Role of POA&Ms in Cybersecurity
Your POA&M is your path to strengthening your cybersecurity posturing. It’s going to identify gaps and hold your organization accountable for achieving an enhanced compliance posture by a specified date.
In addition to short-term goals, your POA&M is the launching pad for your company’s long-term cybersecurity goals. While your POA&M is benchmarked against a specific regulation, the outcomes of these efforts should result in organizational and operational changes in your company.
Cybersecurity requires buy-in from all facets of your organization and your POA&M highlights an organizational commitment to protecting sensitive information.
What Does a POA&M Look Like?
A POA&M can be created on a variety of different platforms. A lot of contractors build out their POA&M in an Excel spreadsheet while others use an application that helps build out and manage their remediation plans. See an example of an Excel POA&M task below.
Creating a POA&M
No matter which platform you use, your POA&M should have the following elements included:
- Weakness Identification
- Responsible Party
- Action Planning
- Necessary Resources
- Setting Milestones for Deliverables
Read more about each below.
Weakness Identification
Every POA&M begins with the identification and documentation of unmet controls. Your organization should be benchmarking your cybersecurity practices against an established regulation that pertains to your business and contracts. Once you have established which regulation(s) your company is required to adhere to, you can begin a gap assessment to identify any unmet controls and deficiencies.
Be sure to add a detailed description of the weakness within your POA&M to ensure all team members are in alignment on the problem so time can be spent on determining the proper corrective action.
Who’s Responsible for the POA&M
Oversight roles are often shared across security leadership. A Chief Information Security Officer (CISO) may provide strategic direction, prioritize remediation efforts based on organizational risk, and ensure alignment with broader risk management objectives. An Information System Security Officer (ISSO) is commonly responsible for day-to-day oversight of POA&Ms tied to specific information systems, including validating remediation steps and supporting assessment activities.
One way or the other, your POA&M is likely going to cover multiple departments and include a variety of remediation tasks, from tool selection and implementation to internal policy development. At the operational level, each POA&M item should have an assigned Point of Contact (POC) responsible for driving remediation forward. The POC is typically accountable for coordinating corrective actions, tracking progress, and ensuring updates are reflected accurately in the POA&M.
Action Planning
Once you’ve identified the gaps in your compliance posture and the appropriate team members to support remediation efforts, it’s time to start action planning.
A helpful model to ensure your remediation efforts are effective is to employ the SMART goal model. SMART stands for: Specific, Measurable, Achievable, Relevant, and Time-bound. With this mindset, you will be poised to develop remediation tasks that are:
- Clear in directive
- Measurable through performance metrics to track progress
- Practical and affordable solutions
- In alignment with your organization’s compliance and business goals
- Set with clear and achievable deadlines
One other important aspect of action planning is assigning a criticality level to each unmet control. This will help your organization prioritize which controls are most important to enhancing your compliance posture and may require more support or resources to complete (i.e., assigning a higher criticality level to developing a System Security Plan compared to revising a process around visitor logs).
Resource Allocation
Enhancing your security and compliance posturing takes both time and financial resources. When developing your POA&M, make sure to spend adequate time price-pointing different solutions and identifying how any difference in functionality could impact your team or compliance goals.
Setting Milestones
Timelines are a defining feature of an effective POA&M. Each POA&M item should include clear milestones and scheduled completion dates that reflect realistic remediation efforts rather than aspirational deadlines. These dates are critical for demonstrating progress and maintaining credibility with auditors, assessors, and stakeholders.
Milestones help break corrective actions into manageable steps, particularly when remediation spans multiple teams or systems. As work progresses, POA&Ms should be updated to reflect changes in status, revised timelines, or adjustments to scope. When remediation is complete, the date of completion should be documented along with evidence supporting closure of the item.
Well-managed timelines demonstrate an active, disciplined approach to remediation and provide visibility, accountability, and continuity across the full remediation life cycle.
Here are three tips for creating milestones within your POA&M:
- The more specific and detailed your milestones are, the better
- Ensure your milestones are measurable so you can effectively track and communicate your progress
- Be realistic in both timelines for completing tasks, as well as your budget for remediation efforts
Mapping POA&M Items to Security Controls and Assessments
POA&Ms don’t exist in isolation. Each POA&M item should be directly traceable to a documented finding identified through a formal assessment or review. In most environments, those findings originate from activities such as a security controls assessment, an audit report, penetration testing, or routine vulnerability scanning.
At a minimum, every POA&M item should map back to a specific security control requirement and the information system where the issue was discovered. This system-level linkage is essential for understanding scope and impact, particularly in complex information technology environments where a single weakness may affect multiple processes or users.
For example, a failed control identified during a penetration test may reveal a security vulnerability related to access control or configuration management. That vulnerability becomes the basis for a POA&M entry, which documents the associated risk, the affected system, and the steps required to remediate or mitigate the issue.
Clear traceability between POA&Ms, assessments, and controls supports stronger IT security and information security practices overall. It also makes it easier for auditors and assessors to validate that findings have been acknowledged, prioritized, and incorporated into an ongoing remediation effort rather than addressed in an ad hoc or undocumented manner.
Vulnerabilities, Weaknesses, and Countermeasures
POA&Ms are often triggered by the discovery of a vulnerability. But not every vulnerability represents the same level of risk or requires the same response.
Understanding the distinction between security vulnerabilities and security weaknesses is key to creating meaningful, defensible POA&M entries.
- A security vulnerability typically refers to a specific flaw or condition, such as a misconfiguration, missing patch, or control failure,that could be exploited.
- A security weakness is broader and may reflect a systemic issue, such as gaps in policy enforcement, inconsistent implementation of controls, or insufficient oversight at the system-level.
Both can appear in POA&Ms, but they should be described and prioritized differently. Each POA&M item should clearly document the associated risk level, taking into account likelihood and potential impact to the organization’s information systems. From there, the POA&M defines the planned mitigation approach, including any technical, procedural, or administrative countermeasures that will be implemented to reduce or manage that risk.
Note that mitigation doesn’t always mean immediate elimination of the issue. In some cases, compensating controls or interim countermeasures may be appropriate while a longer-term corrective action is planned. A well-written POA&M makes these decisions explicit, providing transparency into how risk is being managed rather than ignored.
How Long a POA&M Should Be
Your POA&M should be as long as it needs to be to achieve compliance. If you have a pretty strong compliance posturing, you will likely have a shorter POA&M document. On the other hand, if you’re new to the defense industrial base (DIB) and just getting familiar with DoD-specific regulations, it will likely be a longer document.
The length of your document is less important than the comprehensiveness and detail within it. The goal is to develop a POA&M that all involved team members can look at and understand the objective at hand.
POA&Ms Across Frameworks: CMMC, NIST, Federal Risk and Authorization Management Program (FedRAMP), and Beyond
While the format of a POA&M may vary slightly by program, the underlying methodology is consistent across major security and compliance frameworks. Whether an organization is operating under NIST SP 800-171, pursuing authorization through FedRAMP, or aligning with FIPS requirements, POA&Ms serve the same fundamental purpose: to document known security issues and track their resolution over time.
For organizations working across multiple frameworks, this consistency is an advantage. A well-managed POA&M process can be reused and adapted as requirements evolve, reducing duplication of effort while improving overall information security posture. What matters most is that POA&Ms remain accurate, current, and tied to real system-level conditions rather than treated as static documentation.
CMMC Compliance Considerations
If you’re just getting started preparing for CMMC, a detailed and comprehensive POA&M is critical to ensuring you achieve compliance with your targeted CMMC maturity level requirements.
As mentioned earlier, certain outstanding unmet controls are allowed to be on a POA&M for conditional certification. This is where assigning timelines and criticality levels become important within your CMMC compliance journey. Make sure to prioritize your remediation efforts for three- and five-point unmet controls applicable to your organization. Otherwise, you risk failing your assessment and missing out on new defense contracts.
ISI Insight: CMMC only allows POA&MS for Level 2 and Level 3 contractors. Conditional certification and the use of POA&Ms is not permitted for contractors seeking Level 1 certification.
Tools For Managing a POA&M
While many defense contractors rely on Excel to develop their POA&M, there are platforms available to help develop and manage your POA&M. ISI partners with FutureFeed to assist our clients during their compliance journey.
FutureFeed serves as a project management platform and is designed for NIST 800-171 controls, which is required for CMMC Level 2.
» Learn more about FutureFeed here!
In addition to FutureFeed, here are some other governance, risk, and compliance (GRC) platforms that can support your compliance journey:
- CSAM (JCAM)
- Xacta
- Archer
Implementing and Monitoring a POA&M
Once you have written and developed your POA&M, it’s time to start on your remediation efforts. That said, don’t forget about your POA&M after it is written. Find tips for updating and tracking your progress within your POA&M to help keep your compliance journey on track.
Tracking the Progress of a POA&M
A key aspect of your POA&M will be tracking your progress at the holistic and specific remediation task level. Proper and accurate tracking relies on having specific and measurable milestones detailed in your POA&M. Another key aspect of tracking your progress is prioritizing your unmet controls. With conditional certification allowed, there is a difference between progress to completing your goals versus progress towards achieving certification.
How to Ensure Your POA&M Is Effective
The most important aspect to the effectiveness of your POA&M is your familiarity and expertise with defense-related regulations and assessment processes. If your organization does not have much experience with DoD regulations, you risk developing a POA&M that is not properly aligned with NIST 800-171.
Another key to an effective POA&M is effective communication. A detailed POA&M will your team identify:
- The most pressing or critical remediation tasks and who they’re assigned to
- When remediation must be completed to keep your compliance journey on track
- Specific, measurable actions needed to satisfy the control, allow your team to track their progress, and enhance your security posturing
Additionally, your POA&M will serve as a real-time view into your compliance journey to internal and external stakeholders. Effectively communicating your efforts and progress will help alleviate concern or foster additional buy-in from key decision makers.
The Role of Continuous Monitoring
Your POA&M is an ever-evolving document. Systems can experience glitches or shutdown, so it is important to employ continuous monitoring practices to ensure that any abnormalities are identified and addressed quickly.
Additionally, as regulations change or as you make changes to your security tool stack and policies, your POA&M has to be updated accordingly.
How Often Should a POA&M Be Updated?
Your POA&M should be updated as progress is made, or as new deficiencies are identified. How often that turns out to be will depend on the progress being made and effectiveness of your continuous monitoring tools in identifying new deficiencies.
Common POA&M Challenges and Solutions
- Lack of Ownership: Developing your POA&M is like any other project and needs clearly defined roles and responsibilities outlined. Without clearly identifying tasks and responsible parties, you risk having key controls fall through the cracks.
- Unrealistic Timeframes: Now that CMMC 2.0 is live, many contractors are feeling an urgency to achieve compliance, and rightfully so. However, it is important to get this right the first time around. Setting realistic timelines on your POA&M is going to save you in the long run.
- Inadequate Resources: Your POA&M is likely going to unveil unmet controls It will be imperative to achieve buy-in from the C-suite at your organization to ensure your organization has the necessary resources.
- Lack of Prioritization: Your POA&M may have a wide variety of unmet controls. You may be inclined to start off with the quick and easy ones first but addressing the more critical controls (i.e. controls worth three or five points) are going to enhance your cybersecurity and compliance posturing faster. Plus, these three- and five-point controls are not permitted on your POA&M for conditional certification.
Completing Your POA&M with ISI
ISI has completed over 180 NIST assessments and accompanying POA&M’s for small- to medium-sized defense contractors. In fact, it is one of the very first tasks we complete for our customers looking to achieve CMMC certification!
» Talk to one of our advisors to learn how we can help your organization’s remediation efforts!
FAQs about POA&Ms
What’s the Difference Between an SSP and a POA&M?
Your SSP is your organization’s comprehensive document detailing the entirety of your security plan. Your SSP will detail your network configurations, tools and software, policies and procedures, … etc. This is your organization’s security playbook.
Your POA&M is detailing your identified gaps and remediation efforts to achieve compliance. So it has narrower focus compared to your SSP, but it complements your SSP by ensuring your cybersecurity practices and policies are in alignment with compliance regulations.
What Is the NIST POA&M Process?
NIST does not outline any formal POA&M policy. Rather defense contractors benchmark their POA&M against the controls listed in a set of regulations (i.e. CMMC Level 2 contractors would benchmark against NIST 800-171).
What’s the Difference Between Tasks and Deliverables?
Tasks are sub-action items that lead to the completion of a deliverable. For example, let’s say your boss asks you to create a spreadsheet providing information on your top 10 clients. The deliverable is the spreadsheet. The tasks would be downloading a report of your sales, identifying who are your top 10 biggest clients, and then compiling the relevant information for your boss.
What’s the Difference Between Outcomes and Milestones?
Outcomes are definitive results from your remediation efforts. Milestones can be outcomes but also account for measurable steps towards achieving the goal. In other words, milestones are the metric you use to track progress while outcomes determine whether the goal has been met.
How can organizations track and maintain SSPs and POA&Ms effectively?
Organizations keep System Security Plans (SSPs) and Plans of Action & Milestones (POA&Ms) up to date by using structured tools and repeatable workflows that make it easy to document controls, assign tasks, track progress, and store evidence in one place. Effective practices include:
- Centralizing documentation so SSPs, POA&Ms, and other documentation all live in one controlled repository
- Automating reminders and milestones so deadlines for remediation or reviews don’t slip
- Version tracking and change logs to show auditors exactly when updates were made
- Regular monthly or quarterly compliance reviews that update control statuses and close completed actions
Because NIST 800-171 and CMMC Level 2 require continuous documentation, contractors need a system that keeps these artifacts accurate as their environment changes. Built specifically for the DIB, our Security Control platform provides pre-mapped NIST 800-171 controls, role-based assignments, automated tasks, and centralized evidence storage to keep your SSPs and POA&Ms accurate, defensible, and always ready for a CMMC review.
Can ISI help us build and maintain our System Security Plan (SSP) and POA&Ms?
Yes. ISI not only builds your System Security Plan (SSP) and POA&Ms, we also keep them accurate and audit-ready year-round. Unlike general MSPs that provide templates or one-time checklists, ISI uses a purpose-built DIB compliance platform to map every NIST 800-171 control, assign owners, track evidence, and automate updates as your environment changes. Our compliance experts maintain the documentation, our engineers close technical gaps, and our platform ensures your SSP and POA&Ms always reflect your true security posture—making CMMC Level 2 certification far easier and more dependable.
» Talk to one of our advisors to learn how we can help your organization’s remediation efforts!
