03.12.02: Plan of Action and Milestones

A POA&M is one of the fastest ways for an assessor to determine whether your NIST SP 800-171 program is real. Policies describe intent, procedures describe how, and control implementations show what exists today. The POA&M shows what is missing and whether you have disciplined follow-through.

For most federal contractors and other organizations handling CUI in nonfederal systems, the operational challenge is not creating a POA&M file. The challenge is keeping it accurate across engineering, IT, security operations, and third parties; tying each open item to a concrete remediation plan; and proving that milestones were completed with objective evidence. If you cannot show that linkage, you will spend every assessment cycle re-litigating the same gaps.

This page translates 03.12.02: plan of action and milestones requirement into a requirement-level, step-by-step implementation approach you can hand to control owners. It focuses on what to record, how to govern updates, what artifacts to retain, and what typically causes audits to stall.

Regulatory text

Requirement: “NIST SP 800-171 Rev. 3 requirement 03.12.02 (Plan of Action and Milestones).” (NIST SP 800-171 Rev. 3)

Operator interpretation: You must document and manage a plan to remediate deficiencies in your implementation of NIST SP 800-171 for the system(s) in scope. Your POA&M needs enough structure to prove: (1) you know what is not compliant, (2) you have a defined path to fix it, (3) someone owns the work, and (4) you track it to completion with evidence. (NIST SP 800-171 Rev. 3)

What the operator must do: Maintain a current POA&M for the defined CUI environment, keep it synchronized with assessment results and risk decisions, and be able to produce it quickly for internal governance and external assessment. (NIST SP 800-171 Rev. 3)

Plain-English interpretation of the requirement

A POA&M is your “open findings register” plus your “remediation program plan,” merged into one operational record. For every control you have not fully implemented, you record:

• What is missing (the deficiency)
• Why it matters (risk/impact statement in your language)
• What you will do (discrete remediation tasks and milestones)
• Who will do it (single-threaded owner plus accountable approver)
• When it will be done (target dates)
• How you will prove it (evidence you will produce)
• Whether you accepted risk instead of fixing it (and who approved that decision)

If your POA&M contains vague items like “improve logging” or “enhance access control,” you are not meeting the intent. An assessor cannot validate progress without measurable milestones and objective evidence.

Who it applies to (entity and operational context)

Applies to:

• Organizations implementing NIST SP 800-171 Rev. 3 to protect CUI in nonfederal systems (commonly federal contractors and subcontractors). (NIST SP 800-171 Rev. 3)

Operational context where it matters most:

• Your CUI boundary is spread across identity, endpoints, cloud workloads, ticketing, and third-party services.
• You have inherited gaps from acquisitions, legacy environments, or partial migrations.
• You rely on third parties (MSPs, SaaS, data processors) that are inside your CUI workflow.

A POA&M is not optional “paperwork.” It is the control mechanism that prevents known gaps from becoming permanent.

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

Step 1: Define the POA&M scope and owner

1. Bind the POA&M to a defined system boundary (your CUI environment). Keep separate POA&Ms if you run multiple distinct CUI systems; do not mix unrelated environments. (NIST SP 800-171 Rev. 3)
2. Assign a POA&M Program Owner (often the ISSO/ISSM equivalent) responsible for quality and currency.
3. Set up a RACI for updates:
   • Control owner updates tasks and milestones
   • Security/GRC validates evidence and status transitions
   • CCO/authorizing leadership approves risk acceptance items

Step 2: Build a normalized POA&M record format (minimum viable fields)

Use a template that supports audit traceability. Include, at minimum:

• POA&M Item ID (unique, never reused)
• NIST SP 800-171 control reference (03.12.02 relates to maintaining the POA&M; your items will reference other controls)
• Deficiency statement (specific, testable)
• Source (assessment, audit, incident, continuous monitoring, third-party finding)
• Root cause category (process, technology, people, third party)
• Risk rating method (use your internal scale; document it)
• Remediation approach (what change will be made)
• Milestones (measurable outputs)
• Target dates ¹
• Owner (one name) and supporting teams
• Dependencies (contracts, procurement, architecture decisions)
• Evidence to close (files, screenshots, configs, tickets)
• Status (Open, In Progress, Blocked, Ready for Validation, Closed)
• Risk acceptance link (if applicable) with approver and expiration/review trigger

Practical rule: if you cannot state what evidence will exist at closure, the milestone is not ready.

Step 3: Populate from real findings, not brainstormed wishes

1. Start from your most recent assessment results and known gaps across the CUI boundary. (NIST SP 800-171 Rev. 3)
2. Convert each gap into remediation tasks that an engineering team can execute.
   • Example deficiency: “Centralized audit logging is not enabled for CUI cloud workloads.”
   • Better tasks: “Enable provider audit logs for Project X,” “Forward to SIEM,” “Create retention policy,” “Create detection rules,” “Run validation test case.”
3. Add third-party-driven gaps as first-class POA&M items, with contract actions as milestones (security addendum, logging access, configuration changes).

Step 4: Establish governance and change control

1. Put the POA&M on a recurring review cadence with security and control owners. The key is consistency, not frequency.
2. Define status transition criteria:
   • “In Progress” requires an approved implementation plan or ticket(s) in motion
   • “Ready for Validation” requires evidence attached
   • “Closed” requires independent validation (GRC/security review) and evidence retention
3. Require date changes to include:
   • reason for slip
   • impact on risk
   • new dependency or decision needed

Step 5: Close items with objective evidence

Closure should be evidence-driven:

• Implementation evidence (configuration, policy settings, system output)
• Operational evidence (alerts, tickets, access reviews, logs, test results)
• Validation evidence (internal control test steps and results)

Keep the “closure package” for each item so you can re-prove compliance without recreating the story.

Required evidence and artifacts to retain

Maintain a POA&M evidence binder (folder structure or GRC system record) with:

• Current POA&M export (dated) and prior versions for change history
• Assessment reports or control test results that generated items
• Tickets/epics linking milestones to work completed (with timestamps)
• Approval records for risk acceptance (with scope, rationale, and review trigger)
• Closure evidence per item (screenshots, config exports, runbooks, log samples)
• Meeting notes or decision records for major scope/date changes

Tip: make each POA&M item evidence self-contained. Audits slow down when evidence is scattered across chat threads and personal drives.

Common exam/audit questions and hangups

Expect questions like:

• “Show me your POA&M and explain how it stays current.” (NIST SP 800-171 Rev. 3)
• “Pick three items. Walk me from finding, to remediation work, to closure evidence.”
• “How do you prevent items from aging indefinitely?”
• “Which items are risk accepted, and who approved them?”
• “Are third-party dependencies tracked, and do you have a contract-backed plan?”

Hangups that derail assessments:

• No linkage between POA&M milestones and real work artifacts (tickets, commits, change records)
• Closure claimed without validation evidence
• Items tied to the wrong system boundary (mixing corporate IT with the CUI enclave)

Frequent implementation mistakes and how to avoid them

Mistake	Why it fails in practice	Fix
Treating POA&M as a one-time spreadsheet	It becomes stale; assessors discount it	Assign ownership, cadence, and status criteria; keep change history
Vague remediation language (“improve,” “enhance,” “review”)	No testable outcome, no closure evidence	Write milestones as measurable outputs plus named evidence
No risk acceptance discipline	“Deferred” becomes permanent	Require approver, rationale, scope, and a review trigger per accepted item
Mixing environments and owners	Accountability collapses	Keep POA&M aligned to a defined CUI boundary; one owner per item
Closing items based on intent	Audit asks for proof; you scramble	Define closure evidence up front and validate independently

Enforcement context and risk implications

No public enforcement cases were provided in the source catalog for this specific requirement, so this page does not cite enforcement actions.

Operationally, a weak POA&M increases the chance you will:

• Fail to demonstrate control maturity during customer or government assessments tied to CUI handling. (NIST SP 800-171 Rev. 3)
• Miss remediation deadlines because dependencies (procurement, third-party commitments, architecture decisions) are not tracked to milestones.
• Repeat the same findings across cycles because closure criteria were not evidence-based.

A practical 30/60/90-day execution plan

First 30 days: Stand up a defensible POA&M

• Choose the system boundary for the CUI environment and name the POA&M owner. (NIST SP 800-171 Rev. 3)
• Publish the POA&M template with mandatory fields and status definitions.
• Import findings from the latest assessments and known gaps.
• For the highest-risk items, add owners, milestones, and closure evidence definitions.

Days 31–60: Make it operational

• Establish the recurring POA&M review meeting with control owners and engineering.
• Link every open item to a work artifact (ticket/epic/change record) and capture dependencies.
• Implement “Ready for Validation” and “Closed” gates with independent evidence checks.
• Start a risk acceptance workflow for items that cannot be remediated promptly (document approver and review trigger).

Days 61–90: Prove closure and harden governance

• Close a meaningful set of items end-to-end with full evidence packages and validation notes.
• Run an internal “audit drill”: sample items, test traceability, confirm evidence quality.
• Tune your milestone language based on what was hard to validate.
• If you manage POA&Ms in spreadsheets, consider moving to a system of record (including Daydream) that enforces required fields, evidence attachments, and status gates while preserving full history.

Daydream fits best once you have repeatable inputs (findings, tickets, owners) and want reliable traceability, reminders, and audit-ready exports without hand-curating spreadsheets each cycle.

Frequently Asked Questions

What counts as a POA&M item under the 03.12.02: plan of action and milestones requirement?

Any known deficiency where your NIST SP 800-171 implementation does not meet the control intent for the in-scope CUI system belongs in the POA&M. Each item needs an owner, milestones, target dates, and defined closure evidence. (NIST SP 800-171 Rev. 3)

Can we keep the POA&M in a spreadsheet?

Yes, if you can control versions, enforce required fields, attach closure evidence, and produce a clean audit trail. Many teams switch to a workflow tool once evidence and approvals become too hard to manage consistently.

How do we handle items that depend on a third party (cloud provider, MSP, SaaS)?

Keep the deficiency in your POA&M with your internal owner, and add third-party actions as milestones (contract change, configuration request, access to logs). Track proof from the third party as closure evidence, not a verbal assurance.

What is the difference between a POA&M and a risk register?

A risk register can be broader and may include accepted risks without remediation. A POA&M is execution-focused: it tracks specific deficiencies and the tasks and milestones to fix them (or formally accept the risk with documented approval). (NIST SP 800-171 Rev. 3)

What do auditors usually reject as “insufficient” POA&M evidence?

They reject closures without objective proof, milestones that are not measurable, and items that claim completion but have no validation record. They also push back when the POA&M scope does not match the defined CUI system boundary.

How often should we update the POA&M?

Update it whenever a milestone changes, a dependency appears, or evidence is produced for validation. Set a recurring governance cadence so items do not age without scrutiny.

Footnotes

1. NIST SP 800-171 Rev. 3