Quick answer: A POA&M, or plan of action and milestones, is a document that lists known security weaknesses in a system, the actions planned to fix each one, who is responsible, the resources needed and the dates for completion. It is required in US federal programs such as FISMA, FedRAMP and CMMC, and is a good practice for tracking remediation in any organization.
Assessments and audits always find gaps. A POA&M turns those findings into a tracked plan, so nothing is forgotten and progress can be shown to auditors and leadership. This guide explains what a POA&M contains and how to manage one well.
What a POA&M contains
| Field | Purpose | Example |
|---|---|---|
| Weakness description | States the problem clearly | MFA not enforced for remote access |
| Source | Where the finding came from | Annual assessment, scan, audit |
| Related control | Links to the framework requirement | NIST SP 800-53 IA-2 |
| Risk rating | Prioritizes the fix | High |
| Planned actions and milestones | Breaks the fix into steps | Pilot, roll out, verify |
| Owner and resources | Assigns accountability | IT manager, licence budget |
| Scheduled completion | Sets the deadline | End of next quarter |
| Status | Tracks progress | Ongoing, completed, delayed |
Each row should be specific enough that someone outside the team could understand the problem and check whether it has been fixed. Vague entries such as “improve security” defeat the purpose.
Where POA&Ms are required
- FISMA and NIST RMF: federal systems track weaknesses in a POA&M as part of authorization, using the term defined in the NIST glossary.
- FedRAMP: cloud providers submit and update POA&Ms as part of continuous monitoring.
- CMMC: contractors may use POA&Ms for certain unmet requirements within strict limits and timeframes.
Our reviews of CMMC readiness software cover tools that manage POA&Ms, and NIST 800-53 vs SOC 2 explains the controls they reference.
POA&M best practices
- Create entries directly from assessment findings and gap analysis results.
- Prioritize by risk, not by ease of completion.
- Set realistic dates and record the reason if they slip.
- Review the POA&M monthly with owners.
- Close items only with evidence that the fix works.
The POA&M is the operational side of governance, risk and compliance. Where a full fix is not possible yet, fixing a risk or control gap may involve interim measures, which should also be recorded.
Frequently asked questions
What does POA&M stand for?
POA&M stands for plan of action and milestones.
Who is responsible for a POA&M?
The system owner is usually accountable, with individual items assigned to the people who will carry out the fixes.
How often should a POA&M be updated?
Programs such as FedRAMP expect monthly updates. Reviewing it at least monthly is good practice for any organization.
Is a POA&M the same as a risk register?
No. A risk register lists risks and their ratings. A POA&M tracks the specific actions to fix identified weaknesses.
Conclusion
A good POA&M is specific, prioritized and kept current. It shows auditors that weaknesses are under control and shows leaders where resources are needed. Treat it as a working plan, not a compliance form.
