Create Plan of Action & Milestones¶

A Plan of Action & Milestones (POA&M) is a required security artifact that tracks known security weaknesses, remediation plans, and progress toward resolution. For systems authorized under FedRAMP, the POA&M provides transparency to Authorizing Officials (AOs), security assessors, and stakeholders by documenting:

Identified vulnerabilities
The associated control weaknesses
Planned remediation actions
Responsible parties
Target remediation dates
Risk status and severity

The POA&M is a living document that must be updated regularly as vulnerabilities are discovered, remediated, or reassessed.

When a POA&M is required¶

You must create or update a POA&M when:

A security control fails or is partially implemented
A vulnerability scan identifies a finding
A penetration test identifies exploitable weaknesses
A Security Assessment Report (SAR) identifies control deficiencies
A continuous monitoring activity detects new issues
A risk acceptance decision requires tracking mitigation activities

Key components of a POA&M document¶

A FedRAMP-compliant POA&M entry typically includes the following fields:

Field	Description
POA&M ID	Unique identifier for the weakness
Control ID	Associated NIST SP 800-53 control (e.g., AC-2, SI-2)
Weakness Description	Summary of the security issue
Source of Finding	Scan, assessment, or test identifying the weakness
Severity	Risk rating (High / Moderate / Low)
Remediation Plan	Steps planned to correct the issue
Milestones	Intermediate remediation steps
Responsible Party	Team responsible for remediation
Scheduled Completion Date	Planned remediation deadline
Status	Open, In Progress, or Closed
Comments	Additional context or justification

How to complete POA&M requirements with the Security Advisory Services and Agency

The Security Advisory Services and Agency will work with you to create and maintain your application's POA&M document. Responsibilities are divided as follows:

Security Advisory Services and Agency:
- Identify the security weaknesses in your application
- Map each finding to the applicable security control
- Determine severity and required completion date
Your organization:
- Define a remediation plan for each finding
- Assign ownership and accountability for remediation

The POA&M creation process¶

While the Security Advisory Services and Agency team leads the technical mapping of your POA&M, the following steps outline the standard process. Reviewing these steps will help you understand how vulnerabilities are transformed into actionable remediation plans.

Identify the security weakness

Start by documenting the finding clearly and concisely. Include:

The affected system component
How the issue was identified
The potential security impact

Example: Container image scan identified a critical vulnerability in the OpenSSL dependency used by the application container.

Map the finding to a security control

Each POA&M entry must be associated with the relevant NIST SP 800-53 control.

Example mappings:

Finding Type	Likely Control
Vulnerable dependency	SI-2 Flaw Remediation
Excessive privileges	AC-6 Least Privilege
Weak encryption	SC-13 Cryptographic Protection
Missing logging	AU-2 Event Logging

Determine the severity

FedRAMP severity ratings generally align with CVSS scoring or assessor risk ratings.

Severity	Description
High	Immediate remediation required
Moderate	Must be remediated within defined timelines
Low	Minor issue or informational

Define a remediation plan

Describe the actions required to eliminate the vulnerability. Include:

Technical remediation
Configuration updates
Dependency upgrades
Process improvements

Example remediation actions:

Update vulnerable dependency
Apply security patches
Modify IAM policies
Harden configuration settings

Assign responsibility

Each POA&M item must have a clearly identified owner, such as the DevOps or Application teams.

Establish completion dates

FedRAMP programs often require remediation timelines based on severity. Review the Acceptance Baseline Criteria for the exact timeline.

Example POA&M Entry¶

POA&M Entry

POA&M ID	Weakness Name	Weakness Description	Control ID	Source of Finding	Affected Assets	Security Impact	Risk Severity	Remediation Plan	Milestones with Completion Dates	Planned Completion Date	Resources Required	Responsible Party	Status	Comments
POAM-2026-001	Vulnerable OpenSSL dependency in application container	A container image scan identified a critical OpenSSL vulnerability (CVE-2025-12345) in the application container image used in the production environment.	SI-2	Container Image Scan	Production application container image	Exploitation of the vulnerable library could allow compromise of application confidentiality, integrity, or availability.	High	Upgrade OpenSSL to the patched version, rebuild the container image, validate the fix through rescanning, and deploy the updated image through the approved release process.	1. Validate vulnerability applicability - 2026-03-20 2. Upgrade dependency - 2026-03-25 3. Rebuild image and rescan - 2026-03-28 4. Deploy to staging and production - 2026-04-10 5. Verify closure - 2026-04-15	2026-04-15	Engineering time, CI/CD pipeline support, security validation	Application Engineering Team	In Progress	Patch included in the next approved release cycle. Security team will review scan evidence before closure.
POAM-2026-002	Inactive accounts not disabled within required timeframe	User accounts that have been inactive for more than 35 days remain enabled in the identity management system.	AC-2	Security Control Assessment	Identity provider and application-integrated user accounts	Stale accounts increase the risk of unauthorized access through dormant or unmanaged credentials.	Moderate	Implement automated inactivity monitoring, disable inactive accounts after the approved threshold, and document periodic account review procedures.	1. Review inactive account inventory - 2026-04-05 2. Implement automated disablement rule - 2026-04-15 3. Disable existing stale accounts - 2026-04-20 4. Update SOP and evidence collection process - 2026-05-01	2026-05-01	IAM administrator support, identity platform configuration updates	Identity & Access Management Team	Open	Manual reviews are currently performed inconsistently. Automation is required for sustained compliance.
POAM-2026-003	Incomplete logging of administrative actions	Administrative actions performed through the management interface are not consistently captured in centralized audit logs.	AU-2	Penetration Test	Application admin portal and centralized logging pipeline	Missing audit trails reduce the ability to detect, investigate, and respond to unauthorized or inappropriate administrative activity.	Moderate	Update application logging to record administrative events, forward logs to the centralized monitoring platform, and validate retention and searchability.	1. Identify missing admin events - 2026-04-10 2. Update logging instrumentation - 2026-04-25 3. Integrate with centralized logging service - 2026-05-05 4. Validate event capture and retention - 2026-05-20	2026-05-20	Developer support, logging pipeline updates, validation testing	Platform Engineering	Open	Existing logs capture authentication events but not all privilege-changing or configuration actions.
POAM-2026-004	Deprecated TLS cipher suites enabled for internal services	Configuration compliance scans identified deprecated TLS cipher suites enabled on internal service-to-service communication endpoints.	SC-13	Configuration Compliance Scan	Internal API gateways and service endpoints	Weak cryptographic settings could allow downgrade attacks or weaken protection of data in transit.	High	Update TLS configuration baselines, disable deprecated cipher suites, redeploy affected services, and validate using configuration and network testing.	1. Inventory affected services - 2026-03-18 2. Update TLS baseline configuration - 2026-03-24 3. Redeploy services - 2026-04-02 4. Validate secure cipher enforcement - 2026-04-10	2026-04-10	DevOps support, configuration management updates, validation testing	DevOps Team	In Progress	Staging remediation is complete. Production rollout is pending completion of change control review.
POAM-2026-005	Privileged containers allowed by default in cluster policy	Kubernetes cluster configuration permits privileged containers to run without requiring documented exception approval.	CM-6	Configuration Review	Kubernetes admission policy and workload configuration	Privileged containers may enable container breakout or unauthorized host-level access.	High	Implement admission controls to block privileged containers by default, establish an exception workflow, and retest workloads for compatibility.	1. Draft admission control policy - 2026-03-30 2. Test policy in non-production cluster - 2026-04-08 3. Deploy policy to production - 2026-04-18 4. Publish exception procedure - 2026-04-25	2026-04-25	Platform security engineering, cluster admin support, workload testing	Platform Security Team	Open	A temporary review process exists, but enforcement is not yet technical or automated.
POAM-2026-006	Password policy does not meet required complexity settings	The identity provider configuration does not fully enforce password complexity and minimum length requirements expected for the environment.	IA-5	Security Assessment Report	Enterprise identity provider	Weak password requirements increase the likelihood of credential compromise and unauthorized access.	Moderate	Update password policy settings in the identity provider, validate enforcement, and document the updated authenticator management configuration.	1. Review current password settings - 2026-04-12 2. Update identity provider policy - 2026-04-25 3. Test policy enforcement - 2026-05-02 4. Update supporting documentation - 2026-05-10	2026-05-10	IAM administrator support, user communications, validation testing	Identity Management Team	Open	MFA is enabled, but password policy configuration still requires adjustment to meet baseline expectations.
POAM-2026-007	Vulnerability scanning not consistently performed across environments	Monthly vulnerability scans are not being executed consistently across staging and production environments, and tracking evidence is incomplete.	RA-5	Continuous Monitoring Review	Production and staging environments	Inconsistent scanning may delay identification of exploitable vulnerabilities and weaken continuous monitoring effectiveness.	Moderate	Automate recurring vulnerability scans for all in-scope environments, centralize scan results, and track completion evidence in the security workflow.	1. Confirm environment inventory - 2026-04-15 2. Configure automated scan schedules - 2026-04-30 3. Integrate results with tracking system - 2026-05-15 4. Validate monthly reporting process - 2026-05-30	2026-05-30	Security operations support, scanner licensing, reporting workflow updates	Security Operations	Open	Current scanning is partially manual and depends on individual team follow-through.

Best practices¶

To ensure your POA&M remains effective:

Keep entries concise and actionable. Focus on clear, specific remediation steps rather than vague descriptions.
Prioritize by risk. Address High severity findings first.
Track progress consistently. Update status regularly to reflect current remediation state.
Align with scan results. Ensure POA&M items stay in sync with the latest vulnerability scan outputs.

Additional resources

For more information on POA&M requirements, review: