Written By Paige Langmead
In the journey toward CMMC Level 2 compliance, a Plan of Action and Milestones (POA&M for CMMC compliance) is more than just a requirement—it’s a roadmap that demonstrates risk awareness, governance maturity, and commitment to closing security gaps. Many organizations treat the POA&M as a formality, but building one thoughtfully ensures your remediation efforts are structured, measurable, and ready for assessment.
1. Don’t Wait to Build It
One common mistake is delaying POA&M creation until late in the readiness process. Instead, your POA&M for CMMC compliance should begin as soon as gaps are discovered, ideally during your internal NIST 800-171 self-assessment or mock readiness review. Waiting compresses timelines and increases the risk of missing critical remediation steps.
Treat your POA&M as a parallel workstream alongside your System Security Plan (SSP). For each “Not Met” item in your CMMC assessment objectives, create a corresponding POA&M entry with actionable, measurable remediation steps.
2. Be Specific and Measurable
A vague POA&M signals red flags to assessors. Avoid statements like “implement better access controls.” Instead, use SMART goals: Specific, Measurable, Achievable, Relevant, and Time-bound.
Example:
- Weak: “Implement MFA.”
- Strong: “Deploy and enforce multi-factor authentication for all administrative accounts in Active Directory using Duo Security by July 15, 2025.”
Specific entries help track progress effectively and increase assessor confidence in your remediation strategy.
3. Prioritize by Risk and Dependencies
Not all gaps carry the same risk. Prioritize issues based on their impact on Controlled Unclassified Information (CUI) and likelihood of exploitation. High-risk gaps—such as missing MFA or unlogged admin activity—should come before lower-impact items like policy versioning.
Consider dependencies as well. For example, updating your Incident Response Plan may be required before related testing controls can be completed. Mapping these dependencies ensures a logical remediation sequence and prevents bottlenecks.
4. Assign Ownership and Accountability
Every POA&M item should have a named owner, not just a department. Assign tasks to specific individuals with due dates and ensure they understand their responsibilities. Regular reviews in risk management or compliance meetings help maintain accountability and keep your POA&M active.
5. Track and Document Progress Transparently
C3PAOs want to see that remediation is actively progressing. Each POA&M item should include a status field (Not Started, In Progress, Completed) and supporting artifacts such as screenshots, policy drafts, or deployment reports. Transparent documentation strengthens confidence, even if the item is not fully completed.
Final Thoughts
An effective POA&M for CMMC compliance is more than a checklist. It reflects your organization’s cybersecurity posture, governance maturity, and commitment to risk management. By building a thoughtful, actionable, and transparent POA&M, you demonstrate to assessors, leadership, and partners that your organization understands its risks and actively mitigates them.
For more guidance, explore NIST 800-171 resources or learn how KTL can support CMMC readiness with expert POA&M development and cybersecurity consulting.