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Plan of Action and Milestones (POA&M) Management Procedure

Use this free template to write your agency's Plan of Action and Milestones (POA&M) Management Procedure. It maps to National Institute of Standards and Technology (NIST) Special Publication (SP) 800-53 Revision 5, and it sits with the Assessment, Authorization, and Monitoring (CA) family. This copy follows the High baseline with the High Value Asset (HVA) overlay from the Cybersecurity and Infrastructure Security Agency (CISA). It names 14 controls. It calls the agency that adopts it "the Organization", and it names each person by role and each tool by its function. It cites 5 federal sources.

Approved by: Chief Information Security Officer (CISO)

From the document: The Information System Security Officer (ISSO) uses a POA&M item to track one weakness. The item states what is wrong, the risk it poses, the corrective action, the resources needed, the owner, and the milestones to closure. Authorizing Officials use POA&M data for risk decisions.

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Controls covered

  • CA-02
  • CA-05
  • CA-06
  • CA-07
  • CA-08
  • CM-03
  • IR-04
  • PM-03
  • PM-04
  • PM-06
  • PM-09
  • RA-03
  • RA-05
  • SI-02

Every Assessment, Authorization, and Monitoring (CA) template

The text of the Plan of Action and Milestones (POA&M) Management Procedure

Approval #

Role Name Signature
Chief Information Security Officer (CISO)

Revision History #

Date Version Description Reviewer
2026-10-31 1.0 Initial issuance [Reviewer name]

Review cycle: Every year.

Mandate. National Institute of Standards and Technology (NIST) Special Publication (SP) 800-53 control CA-5 requires a plan of action and milestones for identified weaknesses. The Federal Information Security Modernization Act (FISMA), at 44 U.S.C. §3554(b)(6), requires a process to plan, carry out, evaluate, and document remedial action. The Office of Management and Budget (OMB) memorandum M-02-01 sets the POA&M format, including the fixed scheduled completion date and the record of milestone changes. This is the Organization’s POA&M procedure for every system and for the program-level POA&M.

1. Purpose and Scope #

The Information System Security Officer (ISSO) uses a POA&M item to track one weakness. The item states what is wrong, the risk it poses, the corrective action, the resources needed, the owner, and the milestones to closure. Authorizing Officials use POA&M data for risk decisions. The CISO uses it for FISMA reporting, and the Office of Inspector General uses it in its evaluations.

Each step below names the person who acts, the action, the tool, the record the step leaves, and the NIST SP 800-53 controls it supports. The ISSO keeps every POA&M item in the governance, risk, and compliance (GRC) system. Remediation work runs through change and service tickets in the ticketing system.

2. Opening a POA&M Item #

The ISSO must create a POA&M item when administrators cannot remediate a weakness at once and the weakness came from one of these sources:

  1. Security control assessments, including findings in the security assessment report.
  2. Vulnerability findings that will miss their due dates under the Vulnerability Management Procedure (PROC-VM-001), including vulnerabilities in the Known Exploited Vulnerabilities (KEV) catalog.
  3. Audits and evaluations by the Office of Inspector General, the Government Accountability Office, and financial statement auditors.
  4. Incident after-action reports.
  5. Continuous monitoring results and family-policy measures that are off target.
  6. Penetration tests and red team exercises.

The ISSO creates the item within 30 days of identification. For a vulnerability finding, the ISSO creates it no later than the finding’s due date.

Entry criteria: Someone identifies a weakness from one of the sources above.

Exit criteria: The weakness has an open item in the GRC system, or administrators fixed it at once.

Step and actor Action Tool Evidence Controls
1. Security Control Assessor Send the ISSO each weakness in the security assessment report, with the control and the severity. The GRC system Security assessment report CA-02, CA-05
2. Vulnerability management team Each week, list the scanner findings that will miss their due dates under the Vulnerability Management Procedure. Include each KEV finding. The vulnerability scanner Weekly past-due list RA-05, SI-02
3. CISO Send the ISSO each finding from the Office of Inspector General, the Government Accountability Office, or a financial statement auditor. The GRC system Audit finding CA-05, PM-04
4. Security Operations Center (SOC) Manager Send the ISSO each corrective action from an incident after-action report, with the incident ticket number. The ticketing system After-action report and incident ticket IR-04, CA-05
5. ISSO Collect continuous monitoring results and family-policy measures that are off target, and penetration test and red team results. The GRC system Monitoring results and test reports CA-07, CA-08
6. ISSO Decide whether administrators can fix the weakness at once. If they cannot, open one item for each weakness. The GRC system New item CA-05
7. ISSO Open the item within 30 days of identification. For a vulnerability finding, open it no later than the finding’s due date. The GRC system Item with its open date CA-05, RA-05

Evidence: the assessment reports, the weekly past-due lists, the audit findings, the after-action reports, and the new items in the GRC system with their open dates.

3. Recording the Required Fields #

In each item, the ISSO records:

  • A unique identifier.
  • A description of the weakness, without exploitable detail.
  • The source and the date identified.
  • The affected systems and controls.
  • A risk statement and the severity.
  • The root cause of the weakness.
  • The corrective action.
  • The resources required, an estimated cost, and the funding status. The ISSO ties the cost to the system’s investment in the budget, by its unique investment identifier, so the cost can enter capital planning.
  • The responsible point of contact.
  • The scheduled completion date. Once the Authorizing Official approves the item, this date never changes.
  • The milestones and their dates, and each change to a milestone with its reason.
  • The status.
  • The evidence of closure.

Entry criteria: The ISSO opened the item.

Exit criteria: Every required field has a value.

Step and actor Action Tool Evidence Controls
1. ISSO Enter every required field listed above. Describe the weakness without exploitable detail. The GRC system Completed item CA-05
2. ISSO Find the root cause with the System Owner. Record it, the risk statement, and the severity. The GRC system Root cause and risk statement CA-05, RA-03
3. System Owner Estimate the cost and the funding status. Tie the cost to the system’s investment by its unique investment identifier. The GRC system Cost and investment link CA-05, PM-03
4. ISSO Check that no required field is blank before sending the item for scheduling. The GRC system Field check CA-05

Evidence: the completed items in the GRC system.

4. Planning and Scheduling the Fix #

Vulnerability findings. The Vulnerability Management Procedure (PROC-VM-001) sets each vulnerability finding’s due date. The due date is the earliest of these deadlines:

  • The Table 1 timeline in Cybersecurity and Infrastructure Security Agency (CISA) Binding Operational Directive (BOD) 26-04.
  • The RA-5 timeframe for the finding’s severity.
  • Any CISA directive deadline.

The ISSO opens the POA&M item no later than that due date. In the item, the ISSO records the interim mitigation, the earliest achievable completion date, and the Authorizing Official’s interim risk decision. Opening a POA&M item does not extend a directive deadline.

All other weaknesses. This covers assessment findings, audit findings, penetration test results, and similar weaknesses. The ISSO schedules each one from the date identified.

Severity Scheduled completion (from identification)
Critical 30 days
High 30 days (High Value Asset assessment findings: 30 days from the final report, per Office of Management and Budget (OMB) memorandum M-19-03)
Moderate 90 days
Low 180 days

When an item cannot meet these timelines, the ISSO documents the reason and gets an interim risk decision from the Authorizing Official. The ISSO does not change the scheduled completion date, as OMB M-02-01 requires. The ISSO records the slip as a milestone change, with the new expected date and the reason.

Entry criteria: Every required field has a value.

Exit criteria: The Authorizing Official approved the item, and each remediation task has a ticket.

Step and actor Action Tool Evidence Controls
1. ISSO Set the scheduled completion date from the due date or the timelines table. Add milestones with dates. The GRC system Scheduled completion date and milestones CA-05
2. System Owner Put an interim mitigation in place for any item that stays open past its due date. Describe it in the item. The GRC system Interim mitigation CA-05, RA-05
3. Authorizing Official Approve the item and its scheduled completion date. Make an interim risk decision for any item that cannot meet its timeline. The GRC system Approval and interim risk decision CA-05, CA-06
4. ISSO Open a change or service ticket for each remediation task. Record each ticket number in the item. The ticketing system Remediation tickets CA-05, CM-03

Evidence: the approved items with their scheduled completion dates and milestones, the interim mitigations and risk decisions, and the linked tickets in the ticketing system.

5. Remediating the Weakness #

Entry criteria: The item has an approved schedule and linked tickets.

Exit criteria: Every remediation ticket is closed, or the ISSO recorded a milestone change.

Step and actor Action Tool Evidence Controls
1. System Owner Assign each remediation ticket to an administrator, with the milestone date as its due date. The ticketing system Assigned tickets CA-05
2. Administrator Make the fix through the change or service ticket. Make a configuration change only after the Change Control Board approves it. The ticketing system Closed tickets and approved changes CM-03, SI-02
3. System Owner Track each ticket against its milestone. Tell the ISSO at once when a milestone will slip. The ticketing system Ticket status CA-05
4. ISSO Record each milestone change with the new expected date and the reason. Leave the scheduled completion date as it is. The GRC system Milestone change history CA-05

Evidence: the closed change and service tickets in the ticketing system, the change approvals, and the milestone change history in the GRC system.

6. Updating, Reviewing, and Reporting #

The ISSO updates the system’s POA&M items at least every month. Each quarter, the CISO’s compliance staff review all POA&Ms for quality, currency, and evidence. They produce the program-level summary that the CISO uses for the Chief Information Officer (CIO) FISMA metrics and the executive risk review. The share of past-due items is a standing program measure. The ISSO escalates missed milestones to the CISO. The CISO reports items more than 90 days past due to the Authorizing Official and adds them to the enterprise risk register.

Entry criteria: An item is open.

Exit criteria: The item is current, and the quarterly summary includes it.

Step and actor Action Tool Evidence Controls
1. ISSO Update the status, milestones, and evidence of every open item at least every month. The GRC system Updated items CA-05
2. ISSO Escalate each missed milestone to the CISO. The GRC system Escalation note CA-05
3. CISO’s compliance staff Each quarter, review all items for quality, currency, and evidence. Return each poor item to its ISSO. The GRC system Quarterly review results CA-05, PM-04
4. CISO’s compliance staff Each quarter, produce the program-level summary, with the share of past-due items. The GRC system Program-level summary PM-04, PM-06
5. CISO Report the CIO FISMA metrics from the summary, and present it at the executive risk review. The GRC system FISMA metrics and review minutes PM-04, PM-09
6. CISO Report each item more than 90 days past due to the Authorizing Official. Add it to the enterprise risk register. The GRC system Past-due report and register entry PM-04, PM-09

Evidence: the update history of each item in the GRC system, the escalation notes, the quarterly review results and summaries, the FISMA metrics, and the enterprise risk register entries.

7. Closing an Item #

The ISSO closes an item only with evidence that the corrective action is in place and effective. The ISSO attaches the evidence to the item, such as configuration exports, rescan results that show remediation, assessor validation, or equivalent records. For an item from an audit by the Office of Inspector General, the Government Accountability Office, or a financial statement auditor, the ISSO closes the item only after the auditor agrees the weakness is fixed. The ISSO attaches the auditor’s agreement to the item. When the Authorizing Official accepts a risk in place of remediation, the Authorizing Official signs a written decision with an expiration date. The Authorizing Official reviews the decision again at each reauthorization.

Entry criteria: Every remediation ticket is closed, or the Authorizing Official decided to accept the risk.

Exit criteria: The item is closed with its evidence, or the signed risk decision is attached.

Step and actor Action Tool Evidence Controls
1. ISSO Collect evidence that the fix is in place and works: a clean vulnerability scan, a configuration export, or the assessor’s validation. The vulnerability scanner Closure evidence CA-05, RA-05
2. ISSO Attach the evidence to the item and request closure. The GRC system Closure request CA-05
3. Security Control Assessor Check the evidence for each item from an assessment, and record the result. The GRC system Validation record CA-02, CA-05
4. ISSO For an audit finding, close the item only after the auditor agrees the weakness is fixed. Attach the auditor’s agreement. The GRC system Auditor’s agreement CA-05, PM-04
5. ISSO Close the item and its remediation tickets. The GRC system Closed item CA-05

Evidence: the POA&M items in the GRC system with their milestones and closure evidence, the quarterly review results, and the Authorizing Official’s risk decisions.

8. References #

These are the sources this document cites, with a link to each official text.