CMMC Practice CA.L2-3.12.2 – Plan of Action: Develop and implement plans of action designed to correct deficiencies and reduce or eliminate vulnerabilities in organizational systems.
Links to Publicly Available Resources
A complete guide to creating, managing, and closing your system’s POA&M This document provides assessment guidance for conducting Cybersecurity Maturity Model Certification (CMMC) assessments for Level 2. This training is intended to provide guidance for developing effective POA&Ms. The guidance in this Attachment is written to assist DHS and its Components in implementing the POA&M process. This link provides a FedRAMP POA&M template. This example policy from the USDA can be referenced for how they handle identifying, assessing, prioritizing, and monitoring the progress of corrective efforts for security vulnerabilities. In this YouTube video the plan of action and milestones (POA&M) document is introduced and explained.
Discussion [NIST SP 800-171 R2]
The plan of action is a key document in the information security program. Organizations develop plans of action that describe how any unimplemented security requirements will be met and how any planned mitigations will be implemented. Organizations can document the system security plan and plan of action as separate or combined documents and in any chosen format.
Federal agencies may consider the submitted system security plans and plans of action as critical inputs to an overall risk management decision to process, store, or transmit CUI on a system hosted by a nonfederal organization and whether it is advisable to pursue an agreement or contract with the nonfederal organization.
Further Discussion
When you write a plan of action, define the clear goal or objective of the plan. You may include the following in the action plan:
- ownership of who is accountable for ensuring the plan’s performance;
- specific steps or milestones that are clear and actionable;
- assigned responsibility for each step or milestone;
- milestones to measure plan progress; and
- completion dates.
This practice, CA.L2-3.12.2, which ensures developing and implementing plans of action to correct and reduce vulnerabilities in systems, is driven by risk management practice RA.L2-3.11.1, which promotes periodically assessing risk to organizational systems. CA.L2-3.12.2 promotes monitoring security controls on an ongoing basis as defined in practice CA.L2-3.12.3.