POAM Best Practices: From Documentation to Implementation

Ever stared at the acronym “POAM” in a compliance document and felt your brain short-circuit for a second? You’re not alone. In the alphabet soup of cybersecurity compliance, the Plan of Action and Milestones often stands out as particularly confusing. But it’s also absolutely critical to your organization’s security strategy. 

While some see POAMs as just another compliance checkbox, security assessors know they represent something far more valuable: a structured approach to identifying, tracking, and resolving security gaps. Whether you’re navigating FedRAMP, tackling CMMC compliance, or implementing NIST standards, understanding POAMs is essential. 

In this comprehensive guide, we’ll cut through the jargon to reveal what POAMs really are, how they function across different compliance frameworks, and how to implement them effectively. No more guesswork, no more confusion — just clear, actionable insights to transform your compliance approach. 

What is a POAM (Plan of Action and Milestones)?

Also known as a POA&M, a Plan of Action and Milestones is a document used to tackle the process of tracking and resolving your organization’s security vulnerabilities or deficiencies. At its core, it’s a living document that catalogs security incidents, security gaps, and root cause analysis taken from assessments, audits, and vulnerability scans. 

A POAM can serve as both a management tool and a formal agreement between an organization and its authorizing officials, clarifying how identified security weaknesses will be addressed. For each identified issue, the POAM will typically outline: 

• A detailed description of the vulnerability or deficiency
• The specific security controls affected
• Risk ratings and prioritization levels
• Clear remediation actions to address the issue
• Resources required for implementation
• Responsible parties for each action item
• Scheduled completion dates and milestones
• Current implementation status

Organizations in both the government and the private sector use POAMs to systematically track and manage the remediation process for security weaknesses. But for government agencies and contractors handling sensitive information, maintaining POAMs isn’t merely a best practice; it’s also a regulatory requirement under frameworks like FISMA, FedRAMP, and CMMC.

That’s because POAMs are useful far beyond simple documentation. When properly implemented, they can become an essential part of your risk management strategy. They operationalize your security team to prioritize remediation efforts, identify policy improvements, allocate resources efficiently to address critical vulnerabilities, and track progress toward compliance with security requirements. They’re also integral for demonstrating due diligence and providing transparency to leadership and authorizing officials.

POAMs vs SSPs: What’s the difference?

While POAMs and System Security Plans (SSPs) both play crucial roles in GRC and information security programs, they serve two distinct functions: 

A System Security Plan (SSP) offers an overview of a system’s security requirements and documents how the organization will implement those required security controls. It may also describe the system boundaries, security architecture, operational environment, and more. 

In contrast, a Plan of Action and Milestones (POAM) focuses specifically on gaps, weaknesses, or deficiencies in security control implementation. It serves as a remediation roadmap that identifies what controls are missing or inadequate and details how and when these issues will be addressed. 

The relationship between the two is complementary: 

• The SSP defines what security controls should be in place
• Assessment activities (like audits or penetration testing) identify where actual implementation falls short
• The POAM then documents those gaps and establishes a plan to fix them

In compliance frameworks like FedRAMP or CMMC, both documents are typically required. The SSP demonstrates your intended security posture, while the POAM acknowledges your current limitations and establishes that you have a credible plan to achieve full compliance within a reasonable timeframe. 

POAMs for specific compliance frameworks

POAMs play a critical role in helping organizations demonstrate their commitment to addressing security gaps and aligning their security practices with specific compliance frameworks. They also facilitate accountability and progress tracking toward closing those security gaps. Here’s how POAMs are implemented across key regulatory frameworks. 

FedRAMP

POAMs are a mandatory component of the FedRAMP authorization process, which standardizes security assessments for cloud products and services used by US federal agencies. Cloud Service Providers (CSPs), 3PAOs, and certain federal government contractors must use POAMs to demonstrate that they have action plans for addressing known security weaknesses. 

In the FedRAMP context, POAMs include critical pieces of information like: 

• The security categorization of the cloud information system 
• Specific weaknesses or deficiencies in the organization’s security controls 
• The importance of those weaknesses or deficiencies and their scope within the organization 
• Proposed risk mitigation approaches, which may include the prioritization of risk management actions and the allocation of risk resources

FedRAMP requires strict adherence to its POAM template, an Excel Workbook that includes fields for vulnerability descriptions, risk ratings, remediation plans, milestones, and status updates. CSPs seeking FedRAMP authorization must follow the given guidelines closely, as failure to address high-risk items within specified timeframes can jeopardize their authorization status.  

CMMC

The Cybersecurity Maturity Model Certification (CMMC) framework establishes cybersecurity standards for DoD contractors within the Defense Industrial Base (DIB). CMMC 2.0 has specific limitations on how POAMs can be used for each certification level, but those POAMs must generally: 

• Document existing vulnerabilities and points of non-compliance for specific security controls  
• Detail remediation responsibilities within the organization and ensure leadership commitment to resource allocation 
• Establish clear, realistic, and verifiable timelines for completing remediation activities  

NIST SP 800-171

POAMs are also required for NIST Special Publication 800-171, which governs the protection of Controlled Unclassified Information (CUI) for defense contractors and subcontractors. Within this NIST framework, POAMs serve as: 

• A mechanism to track progress toward implementing all 110 security requirements  
• A way to document due diligence for Defense Federal Acquisition Regulation Supplement (DFARS) compliance 
• A risk management tool to help organizations prioritize their remediation efforts 

POAM Best Practices: From Documentation to Implementation

Regardless of whether you’re using POAMs for FedRAMP, CMMC, or other frameworks, you’ll need a structured approach for truly effective POAM management. Luckily, there are best practices you can follow to optimize the process. 

Document with precision and detail. Create comprehensive POAMs that include specific vulnerability descriptions, clear remediation steps, and explicit connections to compliance requirements. Vague entries like “improve access controls” should be replaced with specific actions such as “implement multi-factor authentication for all administrator accounts accessing CUI repositories.” This precision will eliminate ambiguity and set clear expectations for remediation teams. 

Prioritize your actions based on risk. Not all vulnerabilities pose an equal threat to your organization, so POAMs are a great opportunity to rank your action items based on their potential impact. Critical vulnerabilities — e.g. the kind that could lead to unauthorized access to sensitive information — should take precedence over low-impact compliance gaps. 

Set realistic timelines. We know: easier said than done. But it’s important to consult with the technical teams who will implement the remediation plan when you’re establishing deadlines. To keep your credibility and your momentum intact, try to break complex tasks into smaller milestones, account for procurement cycles, and build in contingency time for unexpected roadblocks. 

Document resource requirements. Clearly specify the personnel, budget, technical expertise, and time needed for each remediation activity. Assign named individuals rather than departments to specific action items, and obtain explicit commitments from leadership to provide the necessary resources.  

Implement consistent status monitoring. Establish a regular cadence for POAM reviews to assess your progress. When possible, use visual dashboards that clearly display approaching deadlines and potential bottlenecks. 

For remediation activities, update and verify. Before closing any POAM item, you’ll want to verify that the remediation was completed successfully and that it effectively addresses the identified risk. You’ll also want to update the related security documentation after remediation is complete, either in your SSP or elsewhere. This will help you stay aligned between your stated security posture and actual implementation — a must for audits. 

Unite your security, risk, and compliance efforts. Connect your POAM process to your continuous monitoring program to improve your security architecture and development practices. This will help your team address the root issues rather than just symptoms. 

Organizations that implement these best practices will transform their POAM process from a compliance checkbox into a powerful mechanism for continuously improving their security posture. When executed well, POAMs can become a valuable tool for maintaining an ironclad GRC function and demonstrating due diligence to everyone involved. 

Transform Your Compliance Journey with RegScale

RegScale’s Continuous Controls Monitoring platform integrates seamlessly with your existing security tools — vulnerability scanners, SIEM solutions, DevSecOps tools, and ticketing systems — to create a continuous compliance ecosystem. Our Export Builder feature allows you to generate your POAMs in whatever format your framework requires, and our automatic real-time updates ensure that your POAMs reflect your current security posture, not outdated snapshots. 

Unlike traditional GRC tools that require extensive customization, RegScale also offers out-of-the-box templates for FedRAMP, CMMC, NIST 800-171, and other frameworks, allowing you to implement effective POAM management in days rather than months. 

Visit our website to schedule a demo and see how our platform can reduce your compliance burden.