A CMMC Plan of Action and Milestones (POA&M) is a formal document that identifies certain unmet CMMC security requirements and defines how and when an organization will remediate them.
Organizations pursuing Cybersecurity Maturity Model Certification (CMMC) may discover security gaps during assessment preparation or the assessment itself. In certain circumstances, eligible deficiencies can be documented in a POA&M rather than requiring immediate remediation before the assessment can proceed.
A CMMC POA&M provides a structured approach to POA&M cyber security management by documenting the security deficiency, required corrective action, responsible owner, remediation timeline, and progress toward completion. However, not every unmet CMMC requirement is eligible for a POA&M, and outstanding items must be resolved within CMMC’s required timeframe.
Understanding when POA&Ms are permitted and what they should include can help organizations prioritize security gaps and avoid unnecessary certification delays. This gives teams a clearer view of which issues require attention before an assessment and helps them allocate resources more effectively as they work toward certification.
Not every unmet security requirement can be placed on a POA&M during a CMMC assessment. Under the Department of Defense (DoD) POA&M requirements, only certain eligible requirements may remain open, while specific high-priority requirements must be fully implemented before an organization can achieve certification. Organizations must also meet the required minimum assessment score to qualify for conditional CMMC certification with outstanding POA&M items.
POA&Ms are designed to address temporary security gaps, not provide long-term exceptions to CMMC requirements. Each eligible deficiency should have a clear remediation plan, assigned owner, and completion deadline, and all outstanding POA&M items must be closed within the timeframe required for CMMC compliance.
Although the exact format may vary, effective POA&M documentation should clearly capture what needs to be fixed, who is responsible, and how remediation is progressing. Using CMMC compliance software can help centralize this information and keep remediation activities organized. A typical POA&M includes these components:
Identifies the specific security requirement or control that has not been fully implemented. It should clearly describe the gap that needs to be remediated.
Outlines the steps required to resolve the identified security deficiency. It provides a clear plan for addressing the gap and meeting applicable security compliance requirements.
Assigns an individual or team responsible for completing the remediation activities. This establishes accountability and helps ensure the issue is addressed on time.
Sets the deadline for completing the required remediation. The date should be realistic and align with applicable CMMC remediation timelines.
Tracks the progress of the remediation activity and any outstanding work. It should be updated regularly as corrective actions are completed.
Documents evidence showing that the required remediation activities have been completed. This helps demonstrate that the identified security deficiency has been properly addressed.
A Plan of Action and Milestones (POA&M) plays an important role in managing security gaps related to NIST SP 800-171, which establishes requirements for protecting Controlled Unclassified Information (CUI) in nonfederal systems and organizations. A NIST POA&M approach helps organizations document deficiencies identified through self-assessments, gap analyses, or other security reviews and outline how and when those gaps will be remediated.
POA&Ms are commonly maintained alongside a System Security Plan (SSP). While the SSP describes the system environment and how applicable security requirements are implemented, the POA&M tracks outstanding deficiencies and corrective actions. Together, they provide visibility into an organization’s current security posture and should be updated as controls change and remediation activities are completed.
| Category | SSP | POA&M |
| Purpose | Documents the security environment | Tracks security gaps |
| Focus | Security requirement implementation | Outstanding deficiencies |
| Content | Controls and implementation details | Gaps and corrective actions |
| Timeline | Reflects current implementation | Sets remediation deadlines |
| Updates | Updated as systems or controls change | Updated as remediation progresses |
Effective POA&M management helps organizations keep remediation activities on track, maintain accurate documentation, and prepare for CMMC assessments. The following best practices can help ensure outstanding security deficiencies are addressed efficiently.
Address POA&M items based on their security risk, business impact, and urgency. Higher-risk deficiencies should generally be prioritized to reduce exposure and avoid potential certification delays.
Assign a specific individual or team to every POA&M item. Clear ownership creates accountability and helps prevent remediation activities from being overlooked or delayed.
Establish achievable deadlines for each remediation activity while staying within applicable CMMC timelines. Review progress regularly to identify delays and keep corrective actions moving forward.
Maintain evidence that demonstrates the progress and completion of remediation activities. Keeping it organized and current makes it easier to verify that deficiencies have been properly addressed.
Update each POA&M item as remediation work progresses or is completed. Accurate status information gives teams a clear view of remaining gaps and supports a continuous compliance approach by ensuring remediation records accurately reflect progress.
Review the POA&M alongside the System Security Plan (SSP) to ensure both documents reflect the organization’s current security posture. When remediation changes how a requirement is implemented, update the relevant documentation accordingly.
Scytale simplifies POA&M management by centralizing remediation activities in one platform. Teams can document security gaps, assign owners and deadlines, track corrective actions, and maintain supporting evidence without relying on scattered spreadsheets or manual processes.
With automated evidence collection and continuous visibility into compliance status, Scytale helps teams maintain accurate POA&M documentation and monitor remediation progress. This makes it easier to identify outstanding gaps, demonstrate remediation efforts, and prepare efficiently for CMMC assessments.
