What Is a POA&M? Plans of Action and Milestones Explained

The POA&M is one of the most universally required yet frequently mismanaged compliance documents. In our experience, organizations that treat their POA&M as a living operational document succeed in their compliance programs. Those that treat it as a static artifact created for an assessment invariably struggle with audit findings, missed deadlines, and credibility issues with assessors.

A Plan of Action and Milestones (POA&M) — sometimes written as POAM or POA&M — is a formal document that identifies known security weaknesses in an information system, describes the planned actions to address each weakness, assigns responsible parties, and establishes target dates for completion. It is a foundational compliance document required across virtually every federal and defense cybersecurity framework, including CMMC, FedRAMP, the Risk Management Framework (RMF), and FISMA.

Unlike a general to-do list or project tracker, a POA&M is a structured compliance artifact that assessors, authorizing officials, and contracting officers review to evaluate whether an organization is managing its security gaps responsibly. This guide explains what POA&Ms are, how they are used across different frameworks, what a well-structured POA&M contains, and best practices for managing them effectively.

The Purpose of a POA&M

A POA&M serves several distinct purposes within a compliance program:

Acknowledging Known Weaknesses

No organization achieves perfect security, and compliance frameworks recognize this reality. The POA&M provides a structured way to formally acknowledge gaps between your current security posture and the requirements of your applicable framework. This acknowledgment is not a failure — it is a demonstration of security maturity. An organization that knows its weaknesses and has a plan to address them is in a better position than one that claims perfection but has unidentified gaps.

Demonstrating Remediation Commitment

Identifying a weakness without a plan to fix it provides little value. The POA&M transforms identified weaknesses into actionable remediation plans with specific steps, assigned owners, allocated resources, and target dates. This demonstrates to assessors and authorizing officials that the organization is actively managing its security posture, not just documenting it.

Enabling Risk-Based Decisions

POA&Ms include risk assessments for each identified weakness, enabling authorizing officials and system owners to make informed decisions about acceptable risk. A weakness with a credible 30-day remediation plan and low residual risk may be acceptable, while a critical weakness with a vague 12-month timeline may not.

Supporting Continuous Monitoring

POA&Ms are not point-in-time documents. They are updated regularly as milestones are completed, new weaknesses are discovered, and timelines shift. This continuous update cycle makes the POA&M a real-time reflection of the organization's remediation status.

POA&M Structure

While exact formatting varies by framework and organization, every effective POA&M contains the following elements for each identified weakness:

Required Fields

Field	Description	Example
POA&M ID	Unique identifier for tracking	POAM-2026-042
Weakness description	Clear description of the security gap	"Vulnerability scanning is performed quarterly rather than monthly as required"
Source of finding	How the weakness was identified	Self-assessment, third-party audit, vulnerability scan, incident investigation
Control reference	Applicable control or requirement	NIST 800-171 RA.L2-3.11.2
Risk level	Severity of the weakness	High, Moderate, Low
Planned remediation	Specific actions to address the weakness	"Procure and deploy automated vulnerability scanning tool; configure monthly scan schedule"
Responsible party	Individual or role accountable	IT Security Manager
Resource requirements	Budget, tools, or staffing needed	"Tool license cost; 40 hours for implementation"
Milestones	Intermediate steps with target dates	"1) Tool procurement by May 15; 2) Installation by May 30; 3) Initial scan by June 7; 4) Monthly schedule operational by June 15"
Scheduled completion	Target date for full remediation	June 15, 2026
Status	Current status of remediation	Open, In Progress, Completed, Delayed
Completion evidence	Documentation proving the weakness is resolved	Scan report showing monthly execution, tool configuration screenshot

Optional but Recommended Fields

• Cost to remediate — Total estimated cost including tools, labor, and professional services
• Residual risk after remediation — Expected risk level once the weakness is addressed
• Dependencies — Other POA&M items or projects that must complete first
• Change history — Record of updates to the POA&M entry, including timeline changes with justification

POA&M Across Frameworks

While the concept of a POA&M is consistent across frameworks, each framework has specific rules about how POA&Ms are used and what limitations apply.

CMMC

CMMC 2.0 allows POA&Ms at Levels 2 and 3 with specific limitations:

• Not all controls are eligible — Approximately 20-25 critical controls cannot have POA&Ms; they must be fully met for certification
• 180-day closure window — All POA&M items must be closed within 180 days of conditional certification
• Scoring impact — POA&M items affect your overall CMMC assessment score
• Conditional certification — Organizations with open POA&Ms receive conditional certification that converts to full certification upon closure

For a detailed guide on CMMC-specific POA&M requirements, see our CMMC POA&M guide.

FedRAMP

FedRAMP has the most prescriptive POA&M requirements:

• Required format — FedRAMP provides a specific POA&M template that must be used
• Monthly updates — POA&Ms must be updated monthly as part of continuous monitoring
• Deviation requests — If a POA&M item will miss its target date, a formal deviation request must be submitted to the Authorizing Official
• False positive tracking — FedRAMP POA&Ms track false positive findings alongside genuine weaknesses
• Operational requirement tracking — Vulnerabilities from continuous monitoring (vulnerability scans, configuration checks) flow into the POA&M
• Automated feeds — Many FedRAMP-authorized organizations automatically populate POA&M entries from vulnerability scanning tools

For an overview of the FedRAMP authorization process, see our FedRAMP authorization guide.

Risk Management Framework (RMF)

Under the RMF, POA&Ms play a central role in the Authorization to Operate (ATO) process:

• Part of the authorization package — The POA&M is submitted alongside the System Security Plan and Security Assessment Report
• Authorizing Official review — The AO reviews POA&M items to make risk acceptance decisions during the ATO process
• Ongoing authorization — POA&Ms support continuous authorization by tracking remediation of findings from ongoing assessments
• Connection to risk assessment — POA&M items should link to entries in the system risk assessment

For more information about the ATO process, see our guide to Authorizations to Operate.

NIST 800-171 / DFARS

For defense contractors subject to NIST 800-171:

• Self-assessed — POA&Ms are created as part of the contractor's self-assessment
• SPRS linkage — The existence of a POA&M is recorded in the SPRS submission
• No mandated closure timeline — Unlike CMMC, NIST 800-171 alone does not impose a specific closure deadline, though contractors must demonstrate active remediation
• Contracting officer review — Contracting officers may request to review the POA&M alongside the SPRS score

Best Practices for Effective POA&Ms

Write Specific Remediation Plans

The most common POA&M weakness is vague remediation language. Compare:

Vague (unhelpful):

"Implement vulnerability scanning."

Specific (actionable):

"1) Evaluate and select vulnerability scanning tool (Tenable, Qualys, or Rapid7) by April 30. 2) Procure selected tool and deploy scanner appliance in DMZ by May 15. 3) Configure authenticated scanning profiles for all CUI systems by May 22. 4) Execute initial scan and remediate critical findings by June 5. 5) Configure automated monthly scan schedule and distribute reports to system owners by June 15."

The specific version tells assessors exactly what will happen, when, and in what order. It also provides intermediate milestones that demonstrate progress before the final completion date.

Assign Individual Ownership

POA&M items assigned to teams or departments instead of named individuals tend to stagnate. Best practice:

• Assign a single named individual as the responsible party
• Ensure that individual has the authority and resources to execute the remediation
• If the remediation spans multiple teams, assign the coordinating individual as the owner with supporting roles documented

Set Realistic Timelines

Overly aggressive timelines that consistently slip damage credibility more than conservative timelines that are met. When setting target dates:

• Account for procurement lead times, especially for government and defense organizations
• Factor in change management and testing requirements
• Build in buffer for unexpected complications
• If a timeline must change, document the reason and update the completion date rather than silently missing the deadline

Maintain Monthly Review Cadence

Regardless of framework-specific requirements, review your POA&M monthly:

• Update status — Move items from Open to In Progress to Completed as appropriate
• Verify milestones — Confirm that intermediate milestones are being met on schedule
• Escalate delays — Identify items at risk of missing their completion date and escalate early
• Add new items — Incorporate findings from vulnerability scans, assessments, or incidents
• Close completed items — Document completion evidence and formally close remediated items

Link to Evidence

Every completed POA&M item should have associated evidence demonstrating that the weakness is resolved:

• Configuration screenshots showing the remediated state
• Scan results confirming the vulnerability is no longer present
• Policy documents showing the new or updated procedure
• Test results demonstrating the control is operating effectively

Without closure evidence, a POA&M item is not truly closed — it is just marked as closed without verification.

Common POA&M Mistakes

Using the POA&M as a wish list. A POA&M should contain items with genuine remediation plans, not aspirational improvements. If there is no budget, no assigned owner, and no realistic timeline, the item does not belong in the POA&M — it belongs in a strategic roadmap or risk acceptance decision.

Letting items age without updates. POA&M items that show the same status month after month signal to assessors that remediation is not being actively managed. Even if progress is slow, document incremental updates to demonstrate continued effort.

Setting the same target date for everything. Assessors notice when every POA&M item has the same target date (often "end of quarter" or "end of year"). Stagger dates based on actual remediation timelines and dependencies.

Not tracking closure evidence. Marking a POA&M item as complete without documenting how the weakness was resolved invites assessment findings. Maintain a clear evidence trail for every closed item.

Creating POA&Ms only before assessments. The POA&M should be a living document updated throughout the year. Organizations that create or significantly update their POA&M only in advance of an assessment reveal a reactive rather than proactive security posture.

Excluding vulnerability scan findings. Particularly for FedRAMP, vulnerability scan findings should feed into the POA&M. Organizations that track POA&M items separately from vulnerability management create inconsistencies that assessors will identify.

POA&M Management Tools

While POA&Ms can be maintained in spreadsheets, dedicated tools provide better tracking, automation, and reporting:

• GRC platforms (Drata, Vanta, Hyperproof) — Integrate POA&M management with broader compliance workflows
• Specialized CMMC/FedRAMP tools — Platforms designed specifically for defense and federal compliance that include POA&M templates and workflows
• Project management tools — Jira, Asana, or Monday.com can be adapted for POA&M tracking with custom fields, though they lack compliance-specific features
• Spreadsheets — Adequate for small organizations with few POA&M items but become unmanageable at scale

The right tool depends on your organization's size, the number of POA&M items you typically manage, and whether you need the POA&M integrated with other compliance workflows. For organizations managing more than 20-30 POA&M items, a dedicated platform significantly improves tracking and reporting.