In This Article
A Plan of Action and Milestones (POA&M) is a document that identifies known security weaknesses in a system and describes the specific steps, resources, and timeline for remediating them. Think of it as a structured remediation tracker — it tells assessors and authorizing officials “here’s what isn’t fully compliant yet, here’s our plan to fix it, and here’s when it will be done.” POA&Ms are required for FedRAMP, CMMC, FISMA, DoD ATO, and virtually every other federal compliance framework.
A POA&M is not a sign of failure — it’s an expected part of the compliance process. No system is perfect, and authorizing officials understand that. What matters is that weaknesses are documented, prioritized, and tracked with clear remediation timelines. An authorization can be granted even with open POA&M items, as long as the risks are understood and the remediation plan is credible.
What Does a POA&M Include?
Each POA&M item (also called a POA&M entry or finding) typically documents:
- Weakness description — A clear explanation of the security gap or deficiency.
- Associated control — Which security control (e.g., AC-2, SI-4) the weakness relates to.
- Risk level — The severity of the weakness, typically rated as Low, Moderate, or High.
- Remediation plan — The specific actions that will be taken to address the weakness.
- Scheduled completion date — When the remediation will be finished.
- Responsible party — Who owns the remediation effort.
- Status and milestones — Current progress toward resolution.
- Resources required — Budget, personnel, or technology needed.
POA&M Requirements by Framework
FedRAMP POA&Ms
FedRAMP has the most rigorous POA&M requirements. Every vulnerability and security finding must be tracked, including results from monthly vulnerability scans, annual assessments, and penetration tests. FedRAMP specifies remediation timelines based on severity:
- Critical — Must be remediated within 30 days
- High — Must be remediated within 30 days
- Moderate — Must be remediated within 90 days
- Low — Must be remediated within 180 days
FedRAMP POA&Ms are submitted monthly as part of continuous monitoring and are reviewed by the authorizing official. Missing remediation deadlines without justification can jeopardize your authorization.
CMMC POA&Ms
Under CMMC, a POA&M documents any security controls that are not fully implemented at the time of assessment. CMMC allows a limited use of POA&Ms — you must have at least 80% of your Level 2 controls fully implemented to pass, and all POA&M items must be closed within 180 days of the assessment. Certain critical controls cannot be placed on a POA&M at all.
FISMA and DoD ATO POA&Ms
Federal agencies maintain POA&Ms as part of their ongoing Risk Management Framework (RMF) activities. These are tracked in systems like eMASS and are reviewed during annual security reviews and inspector general audits.
POA&M vs. Risk Acceptance
A POA&M means you plan to fix the weakness. A risk acceptance means you’ve decided the weakness is acceptable and won’t be fixed — typically because the cost of remediation outweighs the risk, or because a compensating control reduces the impact. Risk acceptances require formal approval from the authorizing official and must be documented separately.
Best Practices for Managing POA&Ms
- Be specific in your remediation plans — Vague plans like “address the finding” don’t satisfy assessors.
- Set realistic timelines — Missing POA&M deadlines is worse than setting a longer timeline upfront.
- Prioritize by risk — Focus remediation efforts on High and Critical findings first.
- Track progress continuously — Don’t wait until the monthly reporting deadline.
- Close items with evidence — When remediated, document what was done and provide evidence.
- Review with your assessor — Discuss findings with your 3PAO or C3PAO early.
How Many POA&M Items Are Too Many?
There’s no universal limit, but context matters. For FedRAMP, authorizing officials may question a package with dozens of open High-severity items. For CMMC Level 2, you need at least 80% of controls fully implemented — so more than 22 open items out of 110 would prevent certification. The key is the severity, the credibility of your remediation plan, and whether you’re meeting your stated timelines.
How Paramify Helps with POA&Ms
Paramify automates POA&M creation and management alongside your System Security Plan (SSP). When your gap assessment identifies controls that aren’t fully implemented, Paramify automatically generates POA&M entries with the associated controls, risk levels, and remediation fields pre-populated. As you remediate and update your system, the POA&M updates accordingly.
This integrated approach means your SSP and POA&M always stay in sync — a common problem when these documents are maintained separately in spreadsheets.
→ Request a demo to see how Paramify automates POA&M management
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