The Ultimate Guide to POAMs (Plan of Action and Milestones)
This guide breaks down what a POAM is, why you need one, how the POAM process works, what the end goal is, and what a real-world example looks like
Ready to Talk to an Expert?
If you're navigating cybersecurity compliance in the defense industry, especially for frameworks like CMMC (Cybersecurity Maturity Model Certification) and NIST 800-171, then understanding POAMs is critical. This guide breaks down what a POAM is, why you need one, how the POAM process works, what the end goal is, and what a real-world example looks like.
What is a POAM?
A POAM (Plan of Action and Milestones) is a formal document that identifies and tracks gaps in cybersecurity compliance efforts. It lists security requirements that are partially implemented or not implemented and provides a detailed plan to remediate those issues.
In the CMMC and NIST world, the POAM is a key component of your cybersecurity strategy. POAMs are traditionally accompanied by:
- A System Security Plan (SSP)
- A Security Assessment Report (SAR)
Together, these documents form the foundation for how your organization manages risk and achieves compliance.
However, in the CMMC world, security assessment reports aren’t requirements.
Why is a POAM Needed?
A POAM is not just a checklist; it's a living roadmap for achieving and maintaining cybersecurity compliance. Here's why it's needed:
- Regulatory requirement: CMMC and NIST 800-171 require organizations to document and resolve deficiencies.
- Audit readiness: During a CMMC assessment, a POAM shows assessors that you know what’s missing and how you plan to fix it.
- Realistic compliance: Not every organization starts at 100%. A POAM allows you to move forward while addressing gaps.
- Mitigation and risk management: It helps reduce security risks by tracking the resolution of vulnerabilities over time.
In the CMMC 2.0 model, conditional certification is possible even if your implementation isn't 100% complete, as long as only certain types of items are on your POAM.
What is the POAM Process?
The POAM process involves several key steps:
- Security Assessment: An assessment reveals deficiencies in your implementation of security controls.
- POAM Creation: Document each gap with the following:
- Description of the deficiency
- Responsible party
- Mitigation strategy
- Estimated completion date
- Milestones to track progress
- Prioritization: Focus on five-point and three-point controls first because missing these disqualifies you from conditional certification under CMMC.
- Remediation: Implement fixes and update the POAM.
- Closeout: After addressing all items, a closeout assessment is conducted to verify remediation before full CMMC certification.
Important Note: Only specific one-point controls are allowed on the POAM under CMMC. You must achieve a minimum score (88/110) to qualify for conditional certification.
End Goal with POAMs
The end goal of a POAM is to reach and maintain full compliance with security requirements. Under CMMC Level 2, a POAM allows you to:
- Achieve conditional certification
- Continue operating under contract
- Buy time (up to 180 days) to fix low-priority deficiencies
Ultimately, you’ll need to close all open POAM items, especially before undergoing the closeout assessment. Failure to do so could result in losing your conditional certification status and impact contract eligibility.
POAM Example
Let’s say your organization is missing the requirement to automatically log user activity (a one-point requirement). Here’s what your POAM entry might look like:
- Requirement ID: AU-2 (Audit Events) – use 3.1.1 and its assessment objectives
- Status: Not Implemented
- Deficiency: System currently does not automatically log user access or file access events.
- Responsible Party: IT Security Manager
- Mitigation Plan: Implement centralized logging through Microsoft Sentinel within GCC High environment.
- Milestones:
- Research and acquire logging tools (Due: Aug 1)
- Configure audit policies in Windows (Due: Aug 15)
- Deploy solution across production systems (Due: Aug 30)
- Planned Completion Date: August 30, 2025
If this is your only missing requirement (and it’s eligible under CMMC rules), you could still receive conditional certification so long as your organization has a clear, actionable plan in place and executes it within 180 days.
Final Thoughts
POAMs are a useful tool in your compliance journey but are not a shortcut. The end goal is 100% implementation of all 110 controls in NIST 800-171. That’s the standard the Department of Defense expects, and it’s what assessors will measure.
While a POAM can help you cross the finish line through conditional certification, it should never become a crutch. Relying too heavily on POAMs or leaving too many items open puts your business at risk, especially if you fail to close them out within the 180-day window or if they involve high-priority controls.
The only absolute path to long-term success is full, verified implementation of all requirements. If you're serious about securing contracts and protecting Controlled Unclassified Information (CUI), aim for 110 out of 110. Anything less should be the rare exception, not the plan.
Need help building your POAM or preparing for CMMC certification? Connect with a reputable MSP, MSSP, or compliance consulting partner with real, verified success stories.