CA-5(1): Automation Support for Accuracy and Currency

CA-5 is the NIST SP 800-53 control that requires you to maintain a POA&M to track security and privacy weaknesses through remediation. CA-5(1) adds a specific operational expectation: you don’t just maintain the POA&M manually; you support it with automation so it stays accurate, current, and available under real operating conditions. That is a build-and-run requirement, not a documentation exercise.

For a Compliance Officer, CCO, or GRC lead, the fastest path to operationalizing CA-5(1) is to define the POA&M “system of record,” connect it to the sources that create and close findings (scanners, audits, incidents, exceptions, and change management), and enforce minimum data quality rules. Your goal is simple: if an assessor samples a weakness, you can show where it came from, who owns it, what the due date is, what compensating controls exist, and why the current status is trustworthy.

This page focuses on requirement-level implementation guidance you can execute quickly, with step-by-step actions, evidence to retain, and the audit questions that tend to stall teams.

Regulatory text

Requirement (verbatim): “Ensure the accuracy, currency, and availability of the plan of action and milestones for the system using {{ insert: param, ca-05.01_odp }}.” ¹

Operator interpretation: You must run the POA&M in a way that makes it (1) correct, (2) up-to-date, and (3) accessible to the people and processes that need it, and you must do that using automation ¹. The “{{ insert: param, ca-05.01_odp }}” placeholder indicates NIST expects an organization-defined parameter describing what automation support you will use; in practice, you define the tools/integrations/workflows that satisfy the intent ¹.

Plain-English interpretation (what CA-5(1) is really asking)

A POA&M fails CA-5(1) when it is treated as a periodic spreadsheet updated for audits. “Accuracy and currency” means the POA&M reflects the real state of weaknesses and remediation work, with minimal lag and minimal manual re-keying. “Availability” means the POA&M is accessible to stakeholders (security, IT, engineering, system owner, authorizing official) with controlled access and recoverability.

Automation support can be lightweight or advanced. NIST is not prescribing a single product. It is prescribing outcomes supported by repeatable, tool-assisted processes ².

Who it applies to (entity and operational context)

Entity types typically in scope:

• Federal information systems implementing NIST SP 800-53 controls ².
• Contractor systems handling federal data where NIST SP 800-53 is flowed down contractually or required by an authorization boundary ².

Operational contexts where CA-5(1) becomes exam-critical:

• Systems with ongoing vulnerability scanning and frequent configuration change.
• Environments with multiple finding sources (SAST/DAST, penetration tests, audit findings, privacy issues, incident postmortems).
• Authorization packages where assessors sample POA&M items and trace them to evidence and closure decisions ².

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

Use this as a build sheet for your CA-5(1) implementation.

1) Define your POA&M system of record (and forbid “shadow POA&Ms”)

• Select the authoritative repository: a GRC platform, a ticketing system with strong controls, or a database-backed workflow tool.
• Document that this repository is the single source of truth for weaknesses and remediation milestones.
• Restrict creation/closure permissions to defined roles (Control Owner, System Owner, Security, Compliance) and log actions.

Deliverable: POA&M Operating Procedure with the named system of record and role permissions.

2) Standardize POA&M data fields and validation rules

Define mandatory fields for every POA&M item, then enforce them with form validation or workflow gates:

• Unique ID
• Weakness source (scanner, audit, assessment, incident, manual)
• Control mapping (relevant control IDs)
• Risk statement and impact description
• Owner and responsible team
• Planned remediation and milestones
• Due date and status
• Closure criteria and closure evidence link(s)
• Exception/acceptance linkage (if applicable)

Automation expectation: the tool should prevent “incomplete” records from being marked active/closed without required fields.

3) Automate intake from high-volume sources

Prioritize automation where manual entry causes staleness:

• Vulnerability management: auto-create or sync POA&M items from validated scanner findings (after triage rules).
• Audit/assessment findings: import findings from assessor deliverables into the POA&M system, with assigned owners and due dates.
• Ticketing/change systems: link remediation work items bi-directionally so status updates don’t require double entry.

If you can’t fully integrate, implement a controlled “assisted automation” approach: templated imports plus validation checks plus a required reconciliation step.

4) Automate “currency” through scheduled reconciliation

Build a recurring reconciliation job/checklist:

• Identify open POA&M items with no updates since the last reporting cycle.
• Identify items marked “complete” without closure evidence.
• Identify findings that no longer appear in the source system but remain open (or vice versa).

Evidence goal: show that you continuously detect drift between the POA&M and reality.

5) Automate reporting and stakeholder visibility (availability)

Availability is more than “the file exists.”

• Provide role-based dashboards (Open items by owner, overdue items, aging, high-impact items).
• Ensure read access for assessors and authorizing officials as needed, with least privilege.
• Ensure backups and retention so the POA&M remains accessible during outages or staff turnover.

6) Add quality controls for “accuracy”

Accuracy failures usually come from weak governance, not bad tools. Add these controls:

• Required peer review for status changes to “Closed.”
• Mandatory linkage to evidence artifacts (scan results, change tickets, test results, approvals).
• Controlled vocabulary for status (avoid free-text states).
• Duplicate detection (same weakness created multiple times).

7) Assign ownership and cadence

• Name a POA&M Process Owner (often GRC or Security Assurance).
• Require system owners to attest to the correctness of their open items during governance reviews.
• Define escalation paths for overdue or blocked remediation.

8) Map CA-5(1) to an owner, procedure, and recurring evidence set

Auditors will ask who owns the control and how it is operated. Treat that mapping as part of the control design ¹. If you use Daydream to manage your control library, assign CA-5(1) to an owner, attach the procedure, and schedule evidence requests so updates happen continuously rather than at audit time.

Required evidence and artifacts to retain

Retain evidence that proves automation exists and is operating:

Control design artifacts

• POA&M Policy / Standard and POA&M Operating Procedure.
• Data dictionary for POA&M required fields and status definitions.
• Role-based access model and approval workflow description.

Automation artifacts

• Integration diagrams (scanner → POA&M, ticketing → POA&M).
• Configuration screenshots or exports showing enabled integrations, validation rules, and workflow gates.
• Scheduled job logs or reconciliation run records.

Operational evidence (most sampled)

• A sample set of POA&M records showing:
  • Source linkage (finding ID or report reference)
  • Owner assignment
  • Milestones and dates
  • Status history (audit trail)
  • Closure evidence links
• Meeting minutes or governance logs where POA&M is reviewed and exceptions are addressed.
• Backup/restore evidence for the POA&M system of record (availability support).

Common exam/audit questions and hangups

Auditors tend to probe these areas:

1. “Show me that this POA&M is current.”
   Expect sampling: they will pick a finding from a scanner/audit and ask to see it reflected correctly in the POA&M, with the same scope, severity rationale, and current status.

2. “Where is the automation?”
   A spreadsheet plus a calendar reminder rarely passes. Be ready to show integrations, automated imports, workflow validation, and audit trails tied to the tool.

3. “How do you prevent inaccurate closure?”
   They will look for closure criteria, independent verification, and evidence linkage.

4. “Is this POA&M available during an incident or staff turnover?”
   They may ask about access control, continuity, and recoverability.

Frequent implementation mistakes (and how to avoid them)

Mistake	Why it fails CA-5(1)	Fix
POA&M lives in a spreadsheet emailed around	No dependable audit trail, weak availability controls, manual updates go stale	Move to a controlled system of record with permissions and history
“Automation” is only a template	Templates reduce effort but don’t keep items current	Add integrations or scheduled reconciliation that updates or flags drift
Closing items without objective evidence	Creates inaccurate POA&M and weak accountability	Require evidence links and a closure review step
Multiple sources of truth (GRC tool + tickets + spreadsheets)	Conflicting statuses break “accuracy”	Define one authoritative record; link others as supporting systems
No defined parameter for automation support	The ODP placeholder implies you must specify what you use	Document the named tools, integrations, and checks that satisfy CA-5(1) 1

Enforcement context and risk implications

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

Operational risk still concentrates in familiar failure modes: stale POA&Ms hide overdue remediation, inaccurate closure masks exposure, and poor availability slows decision-making during audits and authorization events. For federal programs and contractor environments, these weaknesses increase the chance of assessment findings and delays in authorization outcomes ².

Practical 30/60/90-day execution plan

First 30 days (foundation)

• Name a CA-5(1) control owner and POA&M process owner.
• Select/confirm POA&M system of record; disable uncontrolled copies.
• Publish POA&M data standards (required fields, status definitions, closure criteria).
• Implement access controls and audit logging for POA&M records.

Days 31–60 (automation that changes outcomes)

• Integrate at least one high-volume source (commonly vulnerability scanning or ticketing) into POA&M intake.
• Implement workflow gates: required fields, required owner, required due date, required evidence for closure.
• Stand up a recurring reconciliation report for stale items, missing evidence, and overdue milestones.

Days 61–90 (assessment readiness)

• Run an internal sampling exercise: trace a set of POA&M items to source evidence and to closure evidence.
• Tune automation rules to reduce duplicates and false positives.
• Package evidence for assessors: diagrams, configs, example records, reconciliation logs, and governance artifacts.
• In Daydream (or your GRC system), map CA-5(1) to the owner, procedure, and recurring evidence artifacts so collection stays consistent across cycles ¹.

Frequently Asked Questions

What counts as “automation support” for CA-5(1)?

Automation support means the POA&M’s accuracy and currency depend on system-enforced workflows or integrations, not on manual re-entry. Examples include scanner-to-POA&M ingestion, ticket sync, mandatory field validation, and automated reconciliation checks ¹.

Can I meet CA-5(1) with Jira or ServiceNow instead of a GRC tool?

Yes, if it functions as a controlled system of record with required fields, audit trails, access control, and reporting that maintains accuracy, currency, and availability. The key is proving operation through artifacts, not the product category ².

How do I prove the POA&M is “current” to an assessor?

Be ready to trace sampled weaknesses from their source (scan, audit report, assessment) into the POA&M and show recent status history. Reconciliation logs and bi-directional ticket links are strong evidence because they show ongoing alignment.

What if a weakness is accepted risk rather than remediated?

Keep it in the POA&M with a status that reflects the risk decision, and link to the formal approval and rationale. Automation should still preserve accuracy (who approved, when, scope) and availability (auditable retrieval).

Do we need automated closure verification?

You need a repeatable way to prevent inaccurate closure. Automated verification is ideal for scanner-driven items; for others, enforce closure evidence and a required review step before status changes.

How should we define the organization-defined parameter for automation in CA-5(1)?

Document the specific tools, integrations, and workflow controls you use to maintain POA&M accuracy, currency, and availability. Keep it specific enough that an assessor can verify it in configuration and operational logs ¹.

Footnotes

1. NIST SP 800-53 Rev. 5 OSCAL JSON

2. NIST SP 800-53 Rev. 5