A POA&M (pronounced "po-am") lays out your security gaps and how you plan to close them. Get it right, and you’re on track. Get it wrong, and your CMMC assessment might not go your way.

Each POA&M item maps a specific unmet security control to clear remediation steps, an owner, and a timeline. Your plan of action and milestones are recorded in a living document that shows progress, not just initial intent. Stale updates won’t impress assessors.

A POA&M example might include any of the following elements:

• Missing a security control requirement or a specific requirement you haven’t met

• Description of the weakness or gap

• Detailed remediation plan and steps

• Resources you need for remediation (budget, people, technology, and other resources)

• Point of contact or person you assign responsible for remediation

• Target and actual completion dates for each step or milestone

• Current status and any issues that will affect the completion date

CMMC limits the POA&M’s role more than other cybersecurity compliance programs and frameworks. The Department of Defense created CMMC to verify that defense contractors have the capabilities they need to protect sensitive data, such as Federal Contract Information (FCI) and CUI. The sensitive nature of these data categories and the threat environment facing the Defense Industrial Base means assessors will have little tolerance for deferring important security capabilities via a POA&M.

You can use your POA&M to document the implementation of some lower-level (and lower risk) Level 2 controls, but only with several important caveats and limitations. There is zero tolerance for POA&Ms as a catch-all list of exceptions. Your POA&M cannot include high-risk gaps or security capabilities important for the fundamental protection of sensitive data if deferring these controls would compromise CUI security.

Don’t defer these items: access controls, encryption for data at rest or in transit, and security awareness training. These form the foundation of your CUI protection, and your organization has to have these controls in place in order to receive CMMC certification.

Similarly, CMMC assessors generally don’t allow organizations to defer incident response, monitoring, visibility, or audit logging controls through a POA&M. If your organization processes CUI but is unable to detect and respond to security incidents, no POA&M will satisfy your assessor that your organization properly manages sensitive data security.

Remember, your POA&M is only for lower-risk gaps where you've made partial progress but need more time to reach maturity. It’s not an exception to the implementation of fundamental security capabilities.

Assessors will look for the following:

Assign owners and point of contact

To show you have a plan to address a gap, there must be an owner with a defined responsibility and accountability to ensure completion.

Identify realistic, measurable milestones

For every POA&M item, set a schedule with realistic and trackable milestones. Break out subtasks with target dates, for example: "Evaluate vendors (January 15), award procurement contract (February 1), install on test environment (February 28), production deployment (March 31)."

Demonstrate active remediation

Assessors want to see some active work toward remediation rather than all future activity. They'll look for evidence of procurement processes, project plans, completed initial steps, or resources allocated. Anything showing progress versus a blank slate will help.

Limit the number of items

Organizations that pass CMMC assessments typically maintain a very small number of open POA&M items (often low single digits). A concise, risk-focused list indicates mature preparation and that only lower-risk gaps remain. An extensive list of high-risk POA&M items will likely signal that your organization is not ready to earn CMMC certification. Each open item should represent a clear exception rather than a workaround to avoid completing a required security control.

Review POA&M items monthly or quarterly and prioritize them like any other security vulnerability.

Document everything

Documentation is critical. Maintain records of remediation activities, resource expenditures, and obstacles encountered. This documentation will serve as proof of good-faith effort for assessors and provide valuable information if you need to adjust the projected completion dates for your remediation plans.

Organizations often let POA&M scope creep by tracking issues they should’ve remediated. The best solution is to do a rigorous self-preparation process and an honest gap analysis before you involve an assessor.

Organizations may also struggle with resource constraints, resulting in lengthy remediation periods for POA&M items. A best practice is to break large remediation activities into smaller chunks, delivering a series of incremental security improvements while working within your budget.

Managing POA&M items related to endpoint protection, logging, and monitoring can be especially challenging for organizations pursuing CMMC compliance. Huntress Managed EDR and Managed SIEM solutions provide continuous visibility and the supporting evidence that your assessor will be looking for.

This addresses monitoring controls that assessors typically won’t let you defer through a POA&M. Organizations need continuous monitoring and incident response capabilities in full operation, rather than listing them as open POA&M items.

Managing CUI with sensitive data mode

Malware investigations often require retrieving files that may contain CUI. So, how do you maintain security monitoring while protecting CUI from unauthorized access, including by your security vendors?

Huntress built Sensitive Data Mode, a setup so clever it investigates threats while protecting your CUI from unnecessary access. Here's what Sensitive Data Mode delivers:

• Blocks SOC access to CUI files: SOC analysts still do their job, but they won’t access CUI. This measure reduces risk and protects compliance.

• Maintains investigation capabilities: Huntress analysts can focus on the files that matter, like malicious code, scripts, and other clues, without touching sensitive data. This means Huntress can continue to deliver critical incident detection and response without compromising compliance.

• May help with assessment scoping: Sensitive Data Mode is designed so Huntress may be treated as a Security Protection Asset (SPA) rather than a CUI asset, depending on your implementation, data flows, and assessor scoping decisions. This can help reduce assessment scope when CUI is not accessed, processed, or stored by the service.

Huntress Managed EDR and Managed SIEM help you close POA&M gaps faster, with full visibility and assessor-ready reporting for assessors. Less guesswork, more proof. Get a demo of the Huntress platform to see how we help you pass your assessment faster.