What is POAM? How do I Create One?

You've just landed a government contract or are eyeing one, and suddenly you're faced with requirements mentioning NIST 800-171, DFARS compliance, and something called a "POAM." Your IT team is showing you spreadsheets with hundreds of security controls, and management is asking about timelines and costs. Sound familiar?

If you're feeling overwhelmed by compliance requirements and unsure where to start, you're not alone. Many organizations struggle with understanding what a Plan of Action and Milestones (POAM) is and how to create one that satisfies federal requirements.

What is a Plan of Action and Milestones (POAM)?

A Plan of Action and Milestones (POAM) is a document that identifies tasks that need to be accomplished to address security weaknesses in your information systems. It details the resources required to accomplish these tasks and establishes milestones for their implementation.

In the context of NIST 800-171 and Defense Federal Acquisition Regulation Supplement (DFARS) compliance, a POAM serves as:

• A formal record of identified security deficiencies
• A management tool for tracking remediation activities
• Evidence of your commitment to addressing cybersecurity gaps
• A compliance requirement for organizations handling Controlled Unclassified Information (CUI)

As one Reddit user explained: "if you had the SSP and the POAM filled out and you were working towards full deployment you were technically in compliance with DFARS 7012." This highlights the importance of POAMs as compliance documentation.

Why POAMs Matter for Federal Contractors

For organizations working with the Department of Defense (DoD) or other federal agencies, POAMs aren't just good practice—they're often contractually required. The DFARS clause 252.204-7012 mandates that contractors handling CUI must implement NIST SP 800-171 security requirements, and POAMs are a critical component of demonstrating this compliance.

POAMs matter because:

1. They demonstrate due diligence: Even if you haven't implemented all security controls, a POAM shows you've identified gaps and have a plan to address them.
2. They help prioritize security investments: By documenting and tracking security weaknesses, you can allocate resources more effectively.
3. They're required for SPRS score submission: When submitting your NIST SP 800-171 assessment score to the Supplier Performance Risk System (SPRS), you must reference your POAMs.

The Relationship Between POAMs, SSPs, and Compliance

A POAM works in conjunction with your System Security Plan (SSP). While the SSP documents your security controls and how they're implemented, the POAM addresses any gaps where requirements aren't fully met.

Many organizations struggle with understanding exactly how POAMs fit into overall compliance. As one Reddit user asked: "I am trying to see if they would accept the SSP and POAM as being in compliance like the DOD did/does so I can have some backup to reference."

The DoD has clarified this relationship in various guidance documents. According to the Cyber DFARS FAQ, contractors can be considered compliant with DFARS 252.204-7012 if they have:

1. Completed an SSP that describes how the specified security requirements are implemented
2. Created POAMs that identify and describe how any unimplemented security requirements will be met
3. A clear timeline for implementing the remaining requirements

This approach recognizes that achieving 100% compliance is often a journey, not an immediate destination.

Key Components of an Effective POAM

A properly structured POAM contains several essential components:

1. Weakness Identification

Each security weakness or deficiency should be clearly documented with:

• A unique identifier (ID number)
• The specific security control that's not fully implemented
• A detailed description of the weakness
• The source that identified the weakness (self-assessment, audit, etc.)

2. Remediation Plan

For each identified weakness, you need:

• A description of the planned remediation actions
• The specific milestones to achieve resolution
• The resources required (budget, personnel, tools)
• The office or individual responsible for implementation

3. Timeline and Deadlines

Your POAM must include:

• Scheduled completion dates for each milestone
• Original completion dates (if revised)
• Status indicators (not started, in progress, completed, etc.)

4. Risk Assessment

Each weakness should be assessed for:

• Severity level (high, moderate, low)
• Potential impact on operations or data security
• Risk acceptance documentation (if applicable)

How to Create a POAM: Step-by-Step Guide

Creating a comprehensive POAM may seem daunting, especially if you're new to federal compliance requirements. The following step-by-step process will help you develop an effective POAM that meets NIST 800-171 and DFARS requirements.

Step 1: Conduct a Gap Assessment

Before you can create a POAM, you need to identify your security gaps.

1. Review NIST SP 800-171 requirements: Familiarize yourself with all 110 security requirements across the 14 control families.
2. Perform a self-assessment: For each requirement, determine if your organization is:

• Fully compliant
• Partially compliant
• Non-compliant

1. Document findings: Record detailed observations about each control gap, including current state and what's needed for compliance.

Many organizations struggle at this stage due to limited expertise. As one Reddit user noted: "I am not an IT expert and was wondering about solutions to become compliant in a quick turnaround time?" If you lack in-house expertise, consider bringing in a cybersecurity consultant to assist with this assessment.

Step 2: Prioritize Security Weaknesses

Not all security gaps present the same level of risk. Prioritize based on:

1. Severity and impact: Focus on high-risk vulnerabilities that could lead to data breaches or system compromise.
2. Implementation difficulty: Consider which controls can be addressed quickly versus those requiring significant resources.
3. Regulatory requirements: Prioritize controls explicitly mentioned in your contract clauses.

A common challenge is balancing immediate needs with long-term infrastructure improvements. As one user explained: "How do I get management to get past 'It still works why do we need to change it' when we have 10 year old servers? This is stopping upgrades to ERP system."

When making your case to management, focus on the business risks of non-compliance, including potential contract loss and cybersecurity incidents.

Step 3: Develop Detailed Remediation Plans

For each identified weakness:

1. Define specific actions: Outline exactly what needs to be done to implement the control.
2. Assign responsibilities: Designate who will be accountable for implementing each action.
3. Establish realistic timelines: Set target completion dates that are achievable but demonstrate progress.
4. Identify required resources: Document what you'll need in terms of budget, personnel, and technology.

Remember that NIST 800-171 compliance is not an overnight process. As one experienced professional noted: "Starting from zero, NIST 800-171 compliance is a 12-18 month endeavor (with no major funding or human resource constraints)."

Step 4: Document in the POAM Template

While there's no single required format for POAMs, they typically include the following columns:

• Control ID: The NIST 800-171 control reference (e.g., 3.1.1)
• Control Description: The text of the security requirement
• Weakness: Description of the specific deficiency
• Risk Level: High, Moderate, or Low
• Remediation Plan: Specific actions to address the weakness
• Resources Required: Budget, personnel, tools needed
• Responsible Party: Person or team accountable
• Scheduled Completion Date: Target date for implementation
• Status: Not Started, In Progress, Completed, etc.
• Comments: Additional notes or context

Step 5: Implement Tracking and Reporting Mechanisms

A POAM is a living document that requires regular updates and management attention:

1. Establish review cadence: Schedule regular meetings (monthly or quarterly) to review POAM progress.
2. Update status and milestones: As work progresses, update the status of each item and adjust timelines if necessary.
3. Document evidence of completion: Maintain records of completed remediation activities as evidence for audits or assessments.
4. Report to stakeholders: Provide regular updates to management and contractual authorities as required.

Many organizations seek tools to streamline this process. One Reddit user mentioned: "I am trying to look for a good software to help me automate POAMs." While there are specialized compliance tools available, your approach should match your organization's size and complexity.

Tools and Solutions for POAM Management

The right tools can significantly reduce the administrative burden of creating and maintaining POAMs:

Spreadsheet Solutions

For smaller organizations or those just starting their compliance journey, spreadsheet solutions may be sufficient:

• Microsoft Excel: Create custom templates that can be shared and updated by your team.
• Google Sheets: Enables real-time collaboration on POAM documentation.
• SmartSheets: As one Reddit user suggested, "If you want it to be web-enabled or something, you can try SmartSheets. But it's just a spreadsheet. No need for much that's fancy."

Dedicated POAM Tools

For more complex environments or organizations seeking greater automation:

• FutureFeed: Recommended by cybersecurity professionals for automating POAMs and compliance tracking.
• RegScale: Offers compliance automation including POAM management.
• ZenGRC: Provides comprehensive governance, risk, and compliance management.

Project Management Integration

Some organizations integrate POAM tracking with existing project management tools:

• JIRA: Can be configured to track remediation tasks and deadlines.
• Microsoft Planner/Teams: Useful for assigning and tracking POAM-related tasks.

When selecting a tool, consider your specific needs and constraints. As one Reddit commenter cautioned about certain solutions: "Their autogenerated SSP is terrible." It's important to evaluate any tool's outputs to ensure they meet your quality requirements.

Common POAM Challenges and Solutions

Challenge 1: Unclear Contract Requirements

Many organizations struggle to determine exactly what's required for compliance. As one user expressed: "Honestly it does surprise me that they added this since there is no CUI to perform this contract."

Solution: Carefully review contract language and don't hesitate to seek clarification from your contracting officer. The DFARS clause applies specifically to the handling of CUI, so understanding your data classification is critical.

Challenge 2: Resource Constraints

Compliance efforts can strain limited resources, especially for small businesses. One Reddit user shared: "We just finished our SSP. It was a 12 month engagement between four experienced IT admins."

Solution:

• Prioritize control implementation based on risk
• Consider cloud solutions that offer built-in compliance features
• Explore shared services models for certain security functions
• Investigate Small Business Innovation Research (SBIR) grants or other funding assistance for cybersecurity improvements

Challenge 3: Management Buy-In

Getting leadership support for necessary upgrades can be difficult. As one user lamented: "How do I get management to get past 'It still works why do we need to change it' when we have 10 year old servers?"

Solution:

• Frame compliance as a business opportunity rather than just a cost
• Quantify the potential financial impact of contract loss
• Highlight competitive advantages of strong security posture
• Present a phased approach with clear ROI milestones

Challenge 4: Tracking and Reporting Progress

Maintaining an up-to-date POAM can become administratively burdensome without the right processes.

Solution:

• Embed POAM reviews in existing governance processes
• Designate a compliance coordinator responsible for POAM maintenance
• Use automation tools to reduce manual updates
• Establish clear metrics for measuring and reporting progress

Best Practices for POAM Success

1. Be Realistic and Honest

Your POAM should reflect what you can actually achieve, not what you wish you could do. Unrealistic timelines undermine your credibility and set your organization up for failure.

2. Provide Sufficient Detail

Vague remediation plans like "implement better password policies" are inadequate. Instead, specify exactly what actions will be taken: "Develop and implement a password policy that requires minimum 12-character passwords with complexity requirements, changed every 60 days, with account lockout after 3 failed attempts."

3. Align with Your System Security Plan (SSP)

Ensure your POAM directly references your SSP and that both documents use consistent terminology and control references. Your SSP and POAM work together to tell a complete compliance story.

4. Document Compensating Controls

If you can't implement a control exactly as specified, document your alternative approach. Explain how your compensating control provides equivalent protection and reference industry standards where applicable.

5. Communicate Proactively

Don't wait for an audit or assessment to disclose POAM delays. If you encounter obstacles that will extend your timeline, communicate this proactively to stakeholders and contracting officials.

Conclusion

Creating and maintaining a POAM is a fundamental component of NIST 800-171 and DFARS compliance. While it requires dedication and resources, a well-developed POAM demonstrates your organization's commitment to cybersecurity and can help maintain your eligibility for government contracts.

Remember that compliance is a journey, not a destination. As one experienced professional noted: "Starting from zero, NIST 800-171 compliance is a 12-18 month endeavor." By following the steps outlined in this article and leveraging appropriate tools, you can develop a POAM that satisfies regulatory requirements while enhancing your overall security posture.

Frequently Asked Questions

What is a POAM and why is it important for government contractors?

A Plan of Action and Milestones (POAM) is a document outlining how an organization will correct identified security weaknesses in its systems. It's crucial for government contractors, especially those handling Controlled Unclassified Information (CUI), as it demonstrates a commitment to achieving NIST 800-171 compliance and is often a contractual requirement under DFARS. The POAM serves as a roadmap for remediation, a management tool for tracking progress, and evidence of due diligence. It details specific tasks, resources needed, and timelines for addressing security gaps.

How does a POAM relate to a System Security Plan (SSP) for NIST 800-171 compliance?

A System Security Plan (SSP) describes how an organization implements the required NIST 800-171 security controls, while a POAM documents any controls that are not yet fully implemented and the plan to address these gaps. The SSP outlines your current security posture and how you meet (or intend to meet) each control. The POAM complements the SSP by specifically detailing the weaknesses, the actions to correct them, and the timelines for doing so. Together, they provide a comprehensive picture of your compliance status and your plan to achieve full compliance.

What are the essential components of an effective POAM?

An effective POAM must include detailed weakness identification, a comprehensive remediation plan for each weakness, clear timelines with specific milestones, a risk assessment for each identified weakness, and assigned responsibilities for implementation. Specifically, this means unique IDs for weaknesses, descriptions of the control gaps, planned corrective actions, resources needed (budget, personnel), scheduled completion dates, status tracking, and the severity or risk associated with each deficiency.

How do I start creating a POAM for DFARS compliance?

To start creating a POAM for DFARS compliance, you must first conduct a thorough gap assessment against NIST SP 800-171 requirements to identify all security weaknesses. This involves reviewing all 110 security controls, determining your current compliance status for each (fully, partially, or non-compliant), and documenting these findings. Once gaps are identified, you can then prioritize them, develop remediation plans, and document everything in a POAM template.

Can my organization be considered DFARS compliant if we have unimplemented security controls listed in a POAM?

Yes, under certain conditions, an organization can be considered to be working towards DFARS 252.204-7012 compliance if it has a complete System Security Plan (SSP), a POAM detailing how unimplemented NIST SP 800-171 security requirements will be met, and a timeline for their implementation. The DoD recognizes that achieving full compliance can be a process. Having a robust SSP and a detailed, actionable POAM demonstrates your commitment and plan to secure CUI, which is a key aspect of compliance. However, the expectation is that you are actively working to close these gaps as outlined in your POAM.

How often should a POAM be updated?

A POAM is a living document and should be updated regularly, typically on a monthly or quarterly basis, or whenever significant changes occur in your remediation efforts or security posture. Regular reviews and updates are crucial to ensure the POAM accurately reflects your progress in addressing security weaknesses. This includes updating the status of remediation tasks, revising timelines if necessary, and documenting any newly identified weaknesses or completed actions. Consistent updates are essential for effective management and for demonstrating ongoing due diligence.

For additional guidance, consult the Cyber DFARS FAQ, which provides valuable insights on compliance requirements and expectations.

Whether you're just starting your compliance journey or looking to improve your existing processes, understanding POAM requirements and implementing best practices will position your organization for success in the federal marketplace.