Plan of Action & Milestones (POAM)
Last reviewed · By Chad Griffith
A Plan of Action & Milestones (POAM) is a formal document tracking security weaknesses or controls that are not yet fully implemented, with planned remediation actions, responsible parties, target completion dates, and required resources. POAMs are required artifacts under NIST SP 800-171, DFARS 252.204-7012, and CMMC. Under CMMC 2.0, contractors with most controls implemented but with some controls in POAM status can achieve Conditional CMMC Status valid for 180 days — POAM items must be completed within that window or the certification is lost.
Frequently Asked Questions
What information must a POAM entry include?
Per NIST guidance: control identifier, weakness description, planned milestones with specific actions, milestone target dates, responsible party, resources required (budget, headcount, technology), scheduled completion date, status (open, in progress, completed, deferred), and completion evidence when complete.
Can any control be POAMed under CMMC 2.0?
No. The DoD designated specific 'POAM-eligible' controls under CMMC 2.0. Higher-priority controls (typically those weighted at 5 points in NIST 800-171 scoring) generally cannot be POAMed and must be fully implemented before certification. The full eligibility list is published in CMMC Assessment Guide documents.
What is the 180-day rule?
Contractors achieving Conditional CMMC Status with POAMs must complete all POAM items within 180 days. Completed items convert to Final CMMC Status; incomplete items result in loss of certification. There are no extensions — missing the deadline requires restarting certification.
Are POAMs and risk acceptance the same thing?
No. A POAM is a documented plan to remediate a weakness within a defined timeframe. Risk acceptance is a formal decision by the system owner that a risk will not be remediated. CMMC requires implementation of all 110 controls — risk acceptance is generally not an alternative to POAM. Documented compensating controls may substitute for direct implementation in limited cases.
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