CMMC Level 2 Practice 3.12.2: Develop and implement plans of action designed to correct deficiencies and reduce or

CMMC Level 2 Practice 3.12.2 requires you to maintain a working Plan of Action & Milestones (POA&M) process that identifies control deficiencies, assigns owners, sets realistic remediation milestones, and tracks items to verified closure to reduce or eliminate risk. Your assessor will expect to see documented plans, evidence of execution, and closure validation tied to specific CMMC/NIST 800-171 requirements. ¹

Key takeaways:

• Your POA&M must be operational: owned, prioritized, tracked, and closed with proof, not just written. ¹
• Tie every POA&M item to a specific requirement, affected scope (CUI systems), and measurable completion criteria. ¹
• Retain evidence of both remediation and validation, plus management visibility (reviews, approvals, exceptions). ²

CMMC Level 2 assessments reward disciplined remediation. Practice 3.12.2 is where that discipline becomes visible: you don’t just find gaps, you plan the work, resource it, and prove it’s done. This practice is mapped to NIST SP 800-171 Rev. 2 requirement 3.12.2 and is a cornerstone expectation for organizations handling Controlled Unclassified Information (CUI) for the Department of Defense. ^{1 3}

Operationally, this requirement forces a shift from “we have a list of issues” to “we run a remediation program with accountable owners and evidence.” That matters because CMMC Level 2 is assessed against the environment where CUI is processed, stored, or transmitted, and assessors will test whether your system security plan and your POA&M tell a consistent story about known deficiencies and how you are reducing risk over time. ²

This page gives you requirement-level implementation guidance you can put into production fast: who owns it, what artifacts to create, how to run the workflow, what assessors ask for, and how to avoid the failure modes that cause delays or adverse findings.

Regulatory text

Excerpt (as provided): “CMMC Level 2 practice mapped to NIST SP 800-171 Rev. 2 requirement 3.12.2 (Develop and implement plans of action designed to correct deficiencies and reduce or).” ¹

Operator meaning: You must have documented plans (typically POA&Ms) for deficiencies in your CMMC Level 2 / NIST SP 800-171 control implementation, and you must execute those plans to correct deficiencies and reduce or eliminate the associated risks. The plans must be specific enough to manage work (scope, ownership, milestones, and validation), and current enough to reflect reality in the CUI environment. ^{1 2}

Plain-English interpretation (what the assessor is looking for)

Assessors are trying to answer four questions:

1. Do you know what is wrong? Your gaps are identified and described clearly (not vague “improve security” tasks). ¹
2. Is someone accountable? Each deficiency has an owner with the authority to drive remediation. ²
3. Is there a credible plan? Milestones and dependencies exist, and the plan matches the actual environment and architecture in your SSP. ¹
4. Did you actually fix it? Closure includes validation evidence (testing, configuration proof, screenshots, logs, or procedure output) and a clear closure decision. ²

Who it applies to (entity and operational context)

Applies to: Defense industrial base organizations and other federal contractors that handle CUI and are pursuing or maintaining CMMC Level 2. ³

Where it applies: The assessed environment and boundary that processes, stores, or transmits CUI, including cloud services, endpoints, identity systems, on-prem infrastructure, and managed service arrangements in-scope for CMMC Level 2. ²

Common internal owners: CCO/GRC lead (program owner), IT/security operations (remediation executors), system owners (risk acceptance), and internal audit/assurance (closure validation). Map this to your SSP ownership model so “system responsibility” and “remediation accountability” are consistent. ¹

What you actually need to do (step-by-step)

Step 1: Stand up a “requirement control card” for 3.12.2

Create a one-page runbook that defines:

• Objective: manage deficiencies to closure to reduce or eliminate risk.
• Scope: which systems/enclaves are covered (your CUI boundary).
• Trigger events: assessment findings, internal audits, security incidents, configuration drift, third-party changes affecting in-scope services.
• Cadence: when POA&M review occurs (tie to governance meetings).
• Roles: POA&M manager, control owners, approvers for risk acceptance.
• Exceptions: how you handle deferred items and risk acceptance. ²

This is the fastest way to prevent the most common audit failure: “no one can explain how POA&Ms work here.”

Step 2: Normalize POA&M intake so every item is actionable

Define required fields for each POA&M entry:

• Unique ID
• Related requirement/control (e.g., “3.12.2” plus the deficient practice)
• Deficiency description (what is missing, where, and why it matters)
• Affected asset/system and CUI relevance
• Root cause category (process, tooling, configuration, training, third party dependency)
• Remediation tasks (discrete, testable)
• Owner (person, not team)
• Dependencies (e.g., change window, procurement, third party)
• Target milestone dates and final completion date
• Validation method (what proof closes the item)
• Status (open/in progress/blocked/ready for validation/closed)
• Risk decision field (fix, mitigate, accept, transfer) with approver. ¹

Step 3: Prioritize with a defensible risk lens

Use a simple prioritization rule:

• Highest priority: deficiencies that directly expose CUI confidentiality or allow unauthorized access within the boundary.
• Next: deficiencies that undermine detection/response or make auditability impossible (logging gaps, incomplete inventories, missing account controls).
• Then: documentation/process maturity gaps that do not directly create exposure but block assessment readiness (SSP mismatches, missing procedures). ²

Document the rule in your POA&M SOP so prioritization is repeatable.

Step 4: Execute remediation through change control

Most POA&M items require operational changes. Tie remediation to:

• change tickets,
• implementation plans,
• test results,
• rollback plans,
• approvals.

A POA&M that is not linked to actual work artifacts reads as “intent,” not “implementation.” ¹

Step 5: Validate closure (don’t self-attest without proof)

Define closure gates:

• Implementation complete: change deployed, procedure updated, users trained if needed.
• Evidence captured: screenshots, configs, logs, ticket closure notes, or test output stored in an evidence repository.
• Independent check: someone other than the implementer verifies the control now operates as intended (can be GRC, internal audit, or a peer review). ²

Step 6: Management review and risk acceptance governance

Some items will be blocked by budget, contract constraints, or third-party dependencies. If you defer:

• record the reason,
• define interim mitigations,
• get documented approval from an authorized risk owner,
• revisit on a defined governance cadence. ¹

Assessors will probe whether “accepted risk” is real governance or a parking lot.

Required evidence and artifacts to retain

Store artifacts in a system that supports access control and retention aligned to your compliance program.

Minimum evidence bundle:

• POA&M policy or SOP describing workflow, roles, and closure criteria. ¹
• Current POA&M register (export or read-only view) with required fields populated. ¹
• Traceability to SSP: cross-reference showing which requirements are fully met, partially met, or planned. ¹
• For each closed item: remediation artifacts (tickets, configs, screenshots), validation evidence, and closure approval. ²
• Governance records: meeting minutes, risk acceptance approvals, and escalation decisions for blocked items. ²

Practical tip: if you can’t produce it quickly during an assessment, treat it as missing.

Common exam/audit questions and hangups

What assessors commonly ask:

• “Show me your POA&M and how it maps to your SSP.” ¹
• “Pick one open item. Who owns it, what’s the plan, and what’s the current blocker?” ²
• “Pick one closed item. Prove it’s fixed and operating.” ²
• “How do you decide priority and due dates?” ¹
• “Where do you document risk acceptance, and who can approve it?” ¹

Hangups that slow assessments:

• POA&M entries that are too vague to test.
• Closure with no validation evidence.
• SSP claims “Implemented” while POA&M shows the item is still open.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails	Fix
POA&M is a spreadsheet with no workflow	Items stall; owners aren’t accountable	Put the POA&M in a tracked system (GRC tool, ticketing, or controlled register) with required fields and status gates.
“Fix” tasks are not testable	Assessor can’t verify closure	Write tasks as verifiable outcomes (config state, control output, access review record).
No linkage to change tickets	No evidence the work happened	Require ticket IDs and store artifacts in an evidence repository.
Risk acceptance is informal	Looks like avoidance, not governance	Require written approval and interim mitigations; review regularly. 1
POA&M doesn’t match SSP	Signals weak configuration management	Establish an SSP/POA&M sync step in your monthly governance. 1

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this requirement, so you should treat risk here as contractual and eligibility-driven: weak POA&M execution can block CMMC Level 2 assessment outcomes, delay contract awards, and create ongoing exposure in the CUI boundary. CMMC program expectations are established through the CMMC rule and DoD program guidance, and assessments test sustained implementation rather than policy-only compliance. ^{3 2}

Practical 30/60/90-day execution plan

First 30 days (stabilize and make it auditable)

• Assign a POA&M process owner and define the workflow (intake, prioritization, validation, closure).
• Build the requirement control card for 3.12.2 and get it approved.
• Standardize POA&M fields and status definitions.
• Reconcile: compare SSP statements to existing findings and populate missing POA&M entries.
• Stand up an evidence repository structure (by requirement, by system, or by POA&M ID). ¹

Days 31–60 (drive remediation throughput)

• Triage open items by CUI exposure and assessment impact.
• Convert top-priority POA&M items into change tickets with implementation tasks.
• Start closure validation with a second set of eyes (GRC/internal audit/peer review).
• Hold a recurring POA&M review with system owners to remove blockers and approve exceptions. ²

Days 61–90 (prove sustained operation)

• Sample closed items and re-verify evidence quality (would an assessor accept it?).
• Add metrics that matter operationally (blocked reasons, aging drivers, validation cycle time) without inventing vanity KPIs.
• Run a “mock pull”: produce the SSP, POA&M, and evidence for a small set of requirements on request.
• Document lessons learned and update the SOP to reflect how work really flows. ²

Tooling note (where Daydream fits)

If you’re managing POA&Ms across multiple systems and third parties, the failure mode is almost always evidence sprawl and inconsistent closure criteria. Daydream can function as the control operating system: create a control card for 3.12.2, enforce a minimum evidence bundle, and track remediation items through validated closure with clear ownership and due dates, so assessment prep becomes a repeatable operational cycle instead of a scramble. ²

Frequently Asked Questions

Does 3.12.2 require a formal POA&M, or can we track remediation in tickets?

The requirement is to develop and implement plans of action to correct deficiencies and reduce or eliminate risk; a POA&M is the common format. You can use tickets if you still meet POA&M expectations: clear linkage to requirements, ownership, milestones, and closure validation evidence. ¹

Can we keep POA&M items open during a CMMC Level 2 assessment?

You can have open items, but you must show an active plan with credible milestones and evidence of progress. Be ready to explain risk impact, interim mitigations, and governance decisions for anything deferred. ²

What does “reduce or eliminate risk” mean in practice?

It means your remediation should measurably lower the likelihood or impact of the deficiency, or remove the deficiency entirely. Your closure evidence should show the control now operates as intended in the CUI boundary. ¹

Who should be allowed to approve risk acceptance for POA&M items?

Assign a documented risk owner with authority over the affected system and mission impact, and require written approval. Keep approvals with the POA&M record so assessors can trace the decision. ¹

How do we prevent the SSP and POA&M from drifting out of sync?

Make SSP/POA&M reconciliation a required step in your governance cadence, and require updates when remediation changes the implemented status of a requirement. Store cross-references so you can prove consistency quickly. ¹

How detailed should POA&M milestones be?

Detailed enough that a reviewer can tell what will be delivered, by whom, and how completion will be validated. If a milestone can’t produce evidence, it’s usually not a useful milestone for assessment readiness. ²

Footnotes

1. NIST SP 800-171 Rev. 2

2. DoD CMMC Program Guidance

3. 32 CFR Part 170