What is a Plans of Action and Milestones (POA&M) for CMMC?

A Plan of Action and Milestones (POA&M) is a structured document that identifies security weaknesses, details tasks to fix them, assigns resources, sets milestones (intermediate goals), and establishes completion dates for a systematic roadmap to achieve desired outcomes, often used in cybersecurity for compliance (like CMMC/NIST) but applicable to any project for tracking progress and ensuring timely goal achievement. 

It breaks down large objectives into manageable steps with clear ownership and timelines, serving as a living, progress-tracking tool.

Poor vs. Effective POA&M

Poor POA&M

  • Security issue
  • No owner
  • No deadline set
  • No evidence provided
  • Never updated

Effective POA&M

  • MFA enabled for administrator accounts
  • Assigned to Security Manager
  • Completion by Sept. 15 deadline
  • Screenshots and audit logs attached
  • Reviewed weekly
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    Follow the Steps to Create an Effective CMMC POA&M

    1. Identify the Specific Control Gap
    Begin by documenting the exact CMMC practice, control, or requirement that is not fully implemented. Include:
    • The control identifier
    • The requirement description
    • The affected systems, processes, or users
    • Evidence showing the current gap
    The more precise the description, the easier it will be to remediate and validate later.
    Avoid vague language such as “security issue” or “policy gap.” Instead, explain exactly what is missing. For example:
    • Weak: “MFA not complete”
    • Strong: “Multi-factor authentication has not been implemented for remote administrative access to cloud-based systems.”
    Specific language improves accountability and reduces confusion.
    Each POA&M item should include clear steps for remediation.Examples of corrective actions may include:
    • Deploying new endpoint protection software
    • Updating access control policies
    • Implementing encryption for portable devices
    • Conducting employee security awareness training
    • Configuring log monitoring and alerting
    Corrective actions should be measurable and practical.
    Every POA&M item should have an assigned owner responsible for remediation. Depending on the issue, ownership may fall to:
    • IT teams
    • Security teams
    • Compliance officers
    • Human resources
    • Third-party vendors
    Clear ownership reduces the risk that remediation tasks are overlooked.
    Break larger remediation projects into smaller milestones with estimated completion dates.For example:
    • Select MFA solution
    • Purchase licenses
    • Configure users
    • Test implementation
    • Train employees
    • Verify completion
    This makes progress easier to track and helps leadership understand where projects stand.
    POA&Ms should not be created and forgotten.Organizations should review them regularly, update milestone completion dates, document progress, and note any delays or blockers. Many organizations review POA&Ms monthly or quarterly as part of their cybersecurity governance process.
    As remediation steps are completed, maintain documentation that proves the issue has been resolved.Examples include:
    • Updated policies and procedures
    • Screenshots of implemented controls
    • Training records
    • Configuration files
    • Audit logs
    • Vulnerability scan reports
    This evidence can support future CMMC assessments and reduce the time needed to validate remediation.

    See more tips on creating an effective CMMC POAM

    Key CMMC POA&M Glossary Terms​

    Understanding common POA&M terminology can make remediation planning easier

    View the POA&M Glossary from NIST

    Deficiency

    A missing or incomplete security control, process, or requirement.

    Milestone

    A measurable checkpoint or task that shows progress toward completing remediation.

    Residual Risk

    The remaining risk that exists after partial remediation or control implementation.

    Corrective Action

    The specific step taken to resolve a documented weakness.

    Remediation Owner

    The person, team, or department responsible for resolving the issue.

    Due Date

    The target date for completing a remediation task or milestone.

    Evidence

    Documentation or proof showing that a corrective action has been completed.

    Gap Assessment

    An evaluation process used to identify where an organization does not fully meet CMMC requirements.

    SSP

    A System Security Plan (SSP) is the document that describes how security controls are implemented throughout the organization. POA&Ms often reference deficiencies identified in the SSP.

    How a POA&M Helps You Reach CMMC Compliance:

    CMMC Assessment
    Security Gains Identified
    POA&M Created
    Corrective Actions
    Milestones Completed
    Compliance Achieved

    More Thoughts about POA&M and CMMC Certification

    A well-managed POA&M is an essential part of preparing for CMMC certification. It helps organizations document security gaps, prioritize remediation, assign accountability, and demonstrate progress.

    Rather than treating a POA&M as a one-time checklist, organizations should view it as an active management tool that supports ongoing compliance and stronger cybersecurity.

    FAQs about POA&M

    A POA&M, or Plan of Action and Milestones, is a formal document used to track cybersecurity weaknesses, deficiencies, or unmet requirements that need remediation. Within CMMC, a POA&M is typically used when an organization has identified security gaps that do not prevent certification immediately but still require corrective action within an approved timeframe. A POA&M generally includes: * The specific security requirement that is not fully met * A description of the weakness or deficiency * The planned corrective action * The person or team responsible for remediation * Estimated completion dates * Milestones and progress updates * Residual risk if the issue remains unresolved For example, if a company has not fully implemented multi-factor authentication for all privileged accounts, it may document that deficiency in a POA&M along with the steps needed to complete implementation.
    • Identified Weakness/Task: What needs to be done (e.g., patch software, implement firewall rule).
    • Resources Needed: Budget, personnel, tools needed.
    • Responsible Party: Who owns the task.
    • Milestones: Key checkpoints or mini-goals within the task.
    • Scheduled Completion Date: Deadline for each milestone and the final task.
    • Status/Notes: Tracking progress, risks, or deviations.

    Use the following steps to learn how it works:

      1. Define Goal: Start with a large objective (e.g., launch new product, improve security).
    • Break Down: Identify all necessary tasks to reach the goal.
    • Assign & Schedule: Assign tasks, define milestones (e.g., design complete, testing started), and set dates.
    • Track Progress: Regularly review the POA&M to ensure milestones are hit and address delays.
    • Achieve & Close: Complete all tasks, document closure, and mark the plan finished.

    In cybersecurity and CMMC, a POA&M helps by proving:

    • Purpose: A formal artifact for documenting & resolving system security gaps (vulnerabilities, non-compliant controls).
    • Usage: Required for federal compliance (FISMA, CMMC, FedRAMP) to show commitment to fixing issues, not a permanent pass.
    • Lifecycle: A "living document" updated as weaknesses are found and resolved, proving continuous improvement.

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