For organizations in the Defense Industrial Base (DIB), achieving Cybersecurity Maturity Model Certification (CMMC) readiness is not just a compliance milestone—it’s a commitment to national security and trust.

Yet, full compliance rarely happens overnight. Many companies discover gaps in their cybersecurity controls during readiness assessments. Fortunately, the Department of Defense (DoD) allows for structured remediation through POA&Ms, or Plans of Action and Milestones—a powerful tool that helps organizations plan, track, and complete their journey toward full compliance.

What Is a POA&M?

A Plan of Action and Milestones (POA&M) is a formal document that outlines how an organization plans to correct identified cybersecurity weaknesses or deficiencies. It describes the specific problem, the actions needed to fix it, who is responsible, the resources required, and the target completion date.

A strong POA&M also includes milestones that mark progress toward completion. In simple terms, it serves as your roadmap to compliance, ensuring that identified risks are not ignored but managed transparently and effectively.

POA&Ms originated in federal cybersecurity frameworks like NIST SP 800-53 and NIST SP 800-171, and they remain a core part of achieving and maintaining CMMC compliance today.

The Role of POA&Ms in CMMC 2.0

With CMMC 2.0, the Department of Defense officially recognizes the use of POA&Ms as part of the certification process. However, organizations must understand that POA&Ms are not an excuse for incomplete compliance—they are a structured way to manage limited deficiencies responsibly.

Here are key facts about POA&Ms under CMMC 2.0:

• You cannot achieve certification with major gaps unresolved. Critical requirements such as multi-factor authentication, encryption of Controlled Unclassified Information (CUI), and incident response capabilities must be fully implemented before certification.
  
  

• POA&Ms are allowed for lower-risk or non-critical deficiencies. These must be specific, measurable, and time-bound, with clear milestones showing when each gap will be closed.
  
  

• Remediation must be timely. The DoD typically expects all POA&M items to be addressed within 180 days of the initial assessment.
  
  

• Assessors review POA&Ms closely. They evaluate whether each plan is realistic and supported by documented progress. A weak or vague POA&M can undermine confidence in your readiness.
  
  

Why POA&Ms Matter in CMMC Readiness

Rather than viewing a POA&M as a “list of failures,” organizations should see it as a strategic instrument for improvement.

Here’s why POA&Ms are valuable:

• Transparency and Accountability: They provide an auditable record showing that identified issues are being managed responsibly.
  
  

• Resource Prioritization: POA&Ms help organizations focus time, budget, and manpower on the most critical cybersecurity gaps first.
  
  

• Evidence of Commitment: Assessors and clients can see that you’re taking measurable, trackable actions toward compliance.
  
  

• Continuous Improvement: POA&Ms keep your organization aligned with evolving cybersecurity standards and threats.
  
  

When managed properly, POA&Ms don’t just lead to certification—they help build a culture of cybersecurity maturity and continuous readiness.

Common Pitfalls in Managing POA&Ms

Many organizations struggle with POA&M management, often due to a lack of structure or oversight. Below are common mistakes to avoid:

• Vague Action Plans: Generic statements like “improve access control” are not sufficient. Each action must be specific and measurable.
  
  

• Unrealistic Deadlines: Setting aggressive deadlines that can’t be met reduces credibility. Timelines should reflect actual capacity.
  
  

• Unassigned Responsibility: Every POA&M item must have a clearly defined owner to ensure accountability.
  
  

• Lack of Updates: A POA&M is a living document that should be regularly reviewed and updated as progress is made.
  
  

• Treating It as a Checklist: A POA&M should reflect your broader risk management approach—not just serve as a compliance formality.
  
  

Best Practices for Effective POA&M Implementation

To make POA&Ms a meaningful part of your CMMC strategy, organizations should:

1. Integrate POA&M tracking with compliance management systems. Use software tools or dashboards that provide visibility into milestones, due dates, and responsible parties.
   
   

2. Link remediation actions to business impact. Each corrective measure should reduce real-world risk, not just satisfy compliance requirements.
   
   

3. Ensure executive oversight. Senior leadership should review POA&M progress regularly to allocate resources and remove roadblocks.
   
   

4. Set measurable metrics. Track metrics such as open POA&M items, average remediation time, and compliance score improvements.
   
   

5. Document evidence carefully. When closing a POA&M item, provide proof—like updated policies, screenshots, or system configurations—that the issue has been fully addressed.
   
   

How Techellence Helps Organizations Manage POA&Ms

At Techellence, we understand that CMMC readiness is about more than passing an audit—it’s about building resilient, secure systems that protect sensitive defense data.

Our experts help organizations develop and execute POA&Ms that are practical, measurable, and aligned with both compliance goals and operational realities.

Here’s how Techellence supports you:

• Comprehensive Gap Assessment: We identify where your organization stands against CMMC and NIST standards.
  
  

• Tailored POA&M Development: We build detailed, prioritized action plans with realistic milestones and clear accountability.
  
  

• Automation and Monitoring: We leverage technology to track remediation progress, send alerts, and simplify reporting.
  
  

• Continuous Compliance Support: Beyond certification, we help maintain readiness through regular reviews and updates.
  
  

• Executive Reporting: Our dashboards and reports give leadership full visibility into compliance progress and risk reduction.
  
  

With Techellence as your partner, POA&Ms become more than just a document—they become a disciplined, data-driven process that accelerates certification and strengthens your organization’s overall cybersecurity posture.

Final Thoughts

CMMC readiness is not a one-time goal—it’s an ongoing commitment to protecting national defense data and maintaining trust across the supply chain.

POA&Ms play a vital role in that commitment. They turn gaps into opportunities, promote accountability, and ensure progress is measurable and visible at every stage.

Partner with Techellence to optimize your IT operations, enhance security, and drive sustainable business growth—all while achieving and maintaining full CMMC readiness.