A Comprehensive Guide to Understanding Plan of Action and Milestones (POA&Ms)
Plan of Action and Milestones (POA&Ms) are a crucial component of achieving and maintaining regulatory compliance. Compliance regulations are becoming increasingly stringent, and organizations need to be aware of the significance of POA&Ms in effectively managing compliance. With the advent of new technologies, paralleled by a growing threat of cyber risks, compliance frameworks are also evolving, and the need for POA&Ms is more significant than ever.
What Is a POA&M and Why Is It Important?
A POA&M is mandated by the Federal Information Systems Management Act (FISMA) as a formal corrective action plan for tracking and managing specific weaknesses within an organization’s information systems. These weaknesses may include vulnerabilities in software, hardware, or operational processes. The POA&M is a high-structured, version-controlled, and sensitive document, primarily used to manage cyber risk. It is intended to be used in conjunction with a security control framework such as the NIST Risk Management Framework or the Cybersecurity Maturity Model Certification (CMMC). The Federal Risk and Authorization Management Program (FedRAMP), which ensures that cloud service providers (CSPs) meet specific security and compliance standards, also requires CSPs to maintain POA&Ms to track and manage their compliance progress. Writing and submitting a POA&M is necessary for organizations to not only identify and mitigate risks, but also to maintain compliance with regulatory requirements. Failure to maintain a current and comprehensive POA&M could result in the revocation of authorization to operate for an information system.
POA&Ms are important in achieving regulatory compliance because they provide a structured approach to address any deficiencies or noncompliance issues identified during audits or assessments. POA&Ms specify a plan of action that describes the steps necessary to correct deficiencies and mitigate risks, as well as associated milestones that provide time frames for completion. This ensures that corrective actions are taken in a timely manner, reducing the risk of noncompliance and potential regulatory sanctions. Moreover, regulatory agencies often require organizations to submit POA&Ms as part of their compliance reporting, demonstrating their commitment to addressing any identified weaknesses and continuously improving their compliance posture.
Who Is Responsible for Completing POA&Ms?
Effective POA&Ms help businesses identify potential risks and develop appropriate solutions. However, it’s not just the compliance officers who should be involved in completing POA&Ms. There are multiple parties and stakeholders who should be aware of POA&Ms as an organization works toward achieving regulatory compliance, including:
- Business owners and managers who are responsible for ensuring compliance with relevant regulations and standards
- Compliance officers and auditors who are responsible for ensuring that the organization meets all regulatory requirements
- IT professionals who are responsible for implementing and maintaining the technical controls necessary to ensure compliance
- External auditors and regulatory agencies who may review the organization’s compliance efforts and require evidence of POA&Ms
- Investors and shareholders who may be concerned about the organization’s compliance posture and how it affects or may affect the organization’s risk profile
- Customers and vendors who may require proof of compliance as part of their own risk management efforts
- Legal and risk management professionals who may need to review and provide guidance on the organization’s compliance efforts
- Human resources professionals who may need to ensure that employees are trained and aware of POA&Ms as part of compliance training
- Project managers and teams who are responsible for implementing specific compliance-related projects, and who need to track progress against POA&Ms
- Senior leadership who ultimately has the responsibility for ensuring that the organization is in compliance with regulations and standards
How Is a POA&M Different From DFARS SSP?
Both a POA&M and Defense Federal Acquisition Regulation Supplement (DFARS) System Security Plan (SSP) are important elements of an organization’s cybersecurity posture. There are however distinct differences between the two.
A POA&M is a remediation plan that outlines the steps necessary to address and remediate the identified risks and vulnerabilities in an information system. It is required by federal agencies as part of their risk management process.
On the other hand, DFARS SSP is a broader and more comprehensive plan that outlines the policies and procedures for protecting sensitive information and systems in accordance with DFARS requirements. It is a document that outlines an organization’s approach to information security and is required for all companies doing business with the Department of Defense. DFARS SSP outlines the policies, procedures, and controls in place to protect sensitive information and systems from unauthorized access, use, modification, and destruction.
While POA&Ms and SSPs are crucial in achieving regulatory compliance, they oftentimes aren’t enough. To achieve CMMC 2.0 compliance, for example, organizations must be assessed by a certified CMMC Certified Third Party Assessor Organization (C3PAO). CMMC 2.0 Level 1 requires self-attestation and here, a POA&M alone will suffice. For CMMC 2.0 Level 2 and CMMC 2.0 Level 3, a C3PAO must be involved, besides using a POA&M and SSP.
Components of Plan of Action and Milestones
A POA&M typically includes a set of action items with specific deadlines, responsible individuals, and milestones to track progress toward achieving a specific outcome. The key components of a POA&M are the objectives, goals, tasks, milestones, metrics, and resources.
A POA&M’s objectives are the outcomes an organization aims to achieve within a specific time frame. The objectives should be specific, measurable, achievable, relevant, and time-bound. These requirements are essential in ensuring that objectives are realistic and achievable within the allocated period. POA&M goals, on the other hand, define the broad targets that an organization aims to achieve. Goals provide direction for the objectives and guide the decision-making process toward the overall outcome.
POA&M tasks are specific activities that are necessary for achieving the goals and objectives. The tasks should be identified according to their priority, and the timelines for each should be established. These help to create a detailed implementation plan that ensures that the organization achieves the desired outcomes.
POA&M milestones are essential components of POA&Ms, as they provide the means for measuring progress toward achieving the overall objective. Milestones are significant events or achievements that indicate a change in direction toward the objective.
Within the POA&M milestones, there are POA&M items. These are a list of tasks and milestones that need to be completed in order to achieve a specific goal or objective. These action items can include activities like completing a training program, implementing new software, or resolving security vulnerabilities. POA&M items are used in project management to ensure that all necessary tasks are identified, assigned, and tracked to ensure progress toward the project goal. A list of POA&M items include:
| POA&M Identifier | A unique identifier assigned to each POA&M item for tracking purposes |
| Name of the Control | The specific control or action that needs to be implemented to address the weakness or deficiency |
| Name of the Weakness/Deficiency | A concise description of the weakness or deficiency that needs to be addressed |
| Weakness/Deficiency Description | A more detailed explanation of the weakness or deficiency, including its impact on the organization |
| How the Weakness Was Identified | A brief description of the process or method used to identify the weakness or deficiency |
| Asset Identifier | The identifier of the asset or system that the weakness or deficiency pertains to |
| Date of Identification | The date that the weakness or deficiency was first identified |
| Resources Required to Address the Issue | An estimate of the resources (time, money, personnel, etc.) needed to address the weakness or deficiency |
| Planned Milestones | Specific milestones or targets for addressing the weakness or deficiency |
| Planned Resolution Date | The date by which the weakness or deficiency is planned to be fully addressed |
| Milestone Changes | Any changes to the planned milestones or targets |
| Vendor Dependencies | Any dependencies on vendors or third-party providers that may impact the resolution of the weakness or deficiency |
| Risk Rating | A quantitative assessment of the level of risk posed by the weakness or deficiency |
| Adjusted Risk Rating | Any adjustments made to the risk rating based on new information or changed circumstances |
| Operational Requirement Assessment | An assessment of whether addressing the weakness or deficiency is necessary to meet the organization’s operational requirements |
| Supporting Documents | Any documents or evidence that support the identification or resolution of the weakness or deficiency |
Best Practices for Developing an Effective POA&M
Developing an effective POA&M requires careful planning and execution. Organizations must identify their strategic objectives and priorities and use them as guiding principles for the plan. The POA&M should be aligned with the organization’s mission and vision. It is also important to set realistic and achievable goals and objectives. The POA&M must be developed in collaboration with all stakeholders, including management, employees, and partners.
Strategies for Monitoring Progress
A POA&M’s success largely depends on monitoring progress consistently. Organizations must track and measure progress at regular intervals and adjust the plan accordingly. A dashboard that provides real-time data and metrics can provide insights into the effectiveness of the plan. Ensure that there is clear communication on the progress made, and efforts needed to achieve the desired results. Data analytics can be used to measure the performance of the POA&M and identify areas requiring improvement.
How to Measure the Success of Plan of Action and Milestones
One of the best ways to measure the success of a POA&M is to analyze the results achieved against the key performance indicators (KPIs) set. Organizations should collect data and evaluate progress frequently. Analyzing data against the set KPIs can provide insights into the effectiveness of the plan and highlight areas that require improvements. Organizations should also listen to feedback from employees, customers, and other stakeholders to evaluate the effectiveness of the POA&M.
KPIs Used in Measuring the Success of POA&Ms
KPIs are critical in measuring the success of the POA&M. Some of the most commonly used KPIs include financial metrics such as ROI, operational metrics such as cycle time and quality, customer satisfaction metrics, and employee satisfaction metrics. KPIs should be specific, measurable, achievable, relevant, and time-bound (SMART).
Common Challenges in Developing Plan of Action and Milestones
Developing a POA&M can be challenging, especially if the organization lacks experience in strategic planning. Some common challenges include lack of clarity on objectives, poor communication with stakeholders, inadequate resources, and resistance to change. Additionally, a POA&M can be challenging to develop in a rapidly changing environment where priorities shift quickly.
Strategies for Overcoming Common Challenges
To overcome these common challenges, organizations must engage in effective communication with stakeholders to ensure buy-in and commitment. It is also essential to allocate adequate resources, including funding, staff, and technology, to ensure that the plan is achievable. Organizations must also be flexible and adapt their plan to changing priorities. Finally, it is essential to manage resistance to change by involving key stakeholders in the planning process, providing training and support, and demonstrating the benefits of the POA&M. By overcoming these common challenges, organizations can develop a successful and effective POA&M.
Kiteworks Helps DoD Contractors Comply With Regulations That Require a Plan of Action and Milestones
The Kiteworks Private Content Network helps defense contractors comply with data security regulations and standards that require a POA&M. With the increasing number of regulations that defense contractors must adhere to, staying compliant can be a daunting task. Kiteworks facilitates compliance by providing a consolidated third-party communications platform that meets the highest levels of security and compliance. With Kiteworks, all third-party communication channels, including email, file sharing, managed file transfer (MFT), secure file transfer protocol (SFTP), web forms, and more, are consolidated so that every sensitive file sent, received, or shared is centrally controlled, protected, monitored, and tracked.
Government contractors and other organizations in highly regulated industries that leverage Kiteworks utilize advanced security features to secure the sensitive content they share with trusted third parties. These include end-to-end encryption, access controls, a hardened virtual appliance, and secure deployment options that enable encryption key ownership. In addition, Kiteworks provides complete visibility into all file activity, including every sensitive file accessed, downloaded, sent, received, uploaded, or shared. This activity, all visible on the Kiteworks CISO Dashboard, is also tracked and logged to facilitate eDiscovery, legal requests, and regulatory compliance. The platform also integrates with enterprise applications, enterprise content management (ECM) systems, and security tools. This makes it easy for defense contractors to access and share sensitive information securely.
Kiteworks is FedRAMP Authorized to Moderate Level Impact and meets all the security requirements listed in NIST 800-171. Furthermore, Kiteworks supports nearly 90% of CMMC 2.0 Level 2 requirements out of the box. These features make Kiteworks an indispensable tool for every defense contractor that wants to achieve compliance with these regulations.
Kiteworks also supports a range of other regulations and standards, including International Traffic in Arms Regulations (ITAR), the General Data Protection Regulation (GDPR), SOC 2, FISMA, FIPS 140-2, and Export Administration Regulations (EAR). This level of compliance meets the strict cybersecurity requirements that the Department of Defense requires.
Kiteworks is the ideal solution for defense contractors that need to comply with strict cybersecurity and data privacy requirements. Schedule a custom demo of Kiteworks today to learn more about regulatory compliance for DoD contractors.
Additional Resources
- Blog Post What Are Data Compliance Standards?
- Blog Post Secure File Transfer for Defense Contractors: Ensuring Confidentiality and Integrity
- Blog Post What Is the NIST Cybersecurity Framework (CSF)?
- Blog Post A Roadmap for CMMC 2.0 Compliance for DoD Contractors
- Webinar Making the Journey to CMMC 2.0 by Protecting FCI and CUI