How to Create an Effective POA&M

A Plan of Action & Milestones (POA&M) is a critical component of the CMMC framework, demonstrating your commitment to continuous security improvement. Consider these best practices to create a robust POA&M that not only satisfies CMMC compliance requirements but also drives genuine security improvement within your organization.

1. Conduct Thorough Gap Assessments

Don’t just identify vulnerabilities; understand their impact. Use a multi-faceted approach combining automated scans, manual testing, documentation reviews, and personnel interviews to uncover technical weaknesses, procedural gaps, and documentation inconsistencies.

2. Prioritize Vulnerabilities Based on Risk

Not all vulnerabilities are created equal. Develop a risk scoring methodology that considers the potential impact on CUI confidentiality, integrity, and availability, likelihood of exploitation, and existing compensating controls.

3. Establish Realistic Timelines and Milestones

Set achievable deadlines based on the complexity of the remediation, resource availability, and potential dependencies. Include buffer time for unexpected challenges and communicate timelines clearly to all stakeholders.

4. Assign Clear Ownership and Accountability

Define specific individuals responsible for each POA&M item, ensuring they have the authority and resources to complete the task. Establish escalation paths for issues and integrate POA&M ownership into performance evaluations.

5. Document Interim Risk Mitigation Measures

For vulnerabilities with extended remediation timelines, implement compensating controls to reduce risk exposure during the process. Document these measures thoroughly, including implementation details and effectiveness assessments.

6. Allocate Appropriate Resources

Commit sufficient budget, personnel time, and technical expertise to each POA&M item. Consider ongoing maintenance costs and factor in training requirements for users.

7. Track Progress with Meaningful Metrics

Go beyond simple completion counts. Track progress by risk level, time to closure, resource utilization, and actual risk reduction achieved. Use metrics to identify systemic issues and areas for improvement.

8. Regularly Review and Update the POA&M

Make your POA&M a living document. Conduct regular reviews to assess progress, adjust timelines, reprioritize items, and incorporate new vulnerabilities.

9. Integrate with Your Change Management Process

Align POA&M implementation with your organization’s change management framework to ensure smooth transitions and minimize operational disruptions.

10. Prepare Supporting Evidence and Documentation

For each completed item, compile comprehensive evidence demonstrating implementation and effectiveness. Include configuration snapshots, test results, approvals, and updated documentation.

Learn More About Preparing an Effective POA&M for CMMC Compliance

To learn more about the essential components of a POA&M, including how to create an effective document ahead of a C3PAO audit, be sure to check out How to Create an Effective Plan of Action and Milestones (POA&M): A Strategic Approach to CMMC Compliance.

And to learn more about Kiteworks for CMMC compliance, be sure to check out Achieve CMMC Compliance With Complete Protection of CUI and FCI.