A Plan of Actions and Milestones (POAM) is a document used in the context of cybersecurity compliance frameworks, including the Cybersecurity Maturity Model Certification (CMMC). CMMC is a framework developed by the Department of Defense (DoD) to assess and enhance the cybersecurity posture of contractors and subcontractors working with the DoD.

A POAM outlines the specific actions and milestones that an organization plans to take to address identified weaknesses or deficiencies in its cybersecurity controls (Gaps). Here’s how a POAM typically works within the context of CMMC:

  1. Identification of Deficiencies: The organization undergoes a cybersecurity assessment against the CMMC framework, which identifies areas where its cybersecurity practices do not meet the required maturity level.
  2. Documentation of Findings: The findings of the assessment are documented, detailing the specific areas of non-compliance or weaknesses in cybersecurity controls.  These are also identified as Gaps.
  3. Development of Mitigation Strategies: Based on the identified deficiencies, the organization develops a plan to address each one. This plan includes specific actions that will be taken to mitigate the deficiencies and bring the organization’s cybersecurity practices into compliance with the requirements of the applicable CMMC level.
  4. Assignment of Responsibilities and Timelines: The POAM assigns responsibilities for implementing the mitigation strategies to specific individuals or teams within the organization. It also establishes timelines or milestones for completing each action.
  5. Monitoring and Reporting Progress: The organization regularly monitors progress on implementing the mitigation strategies outlined in the POAM. Progress updates may be reported to relevant stakeholders, including DoD contracting officers or auditors.
  6. Documentation of Completion: Once all actions outlined in the POAM have been completed, the organization documents the actions taken and any resulting changes to its cybersecurity posture. This documentation may be reviewed during subsequent assessments or audits.

Overall, a POAM serves as a roadmap for organizations to address cybersecurity deficiencies identified through assessments or audits and demonstrates their commitment to improving their cybersecurity posture in alignment with CMMC requirements. It’s an essential tool for achieving and maintaining compliance with CMMC standards.