Plan of Action and Milestones (POA&M) for CMMC Certification Process
As the cyber-threat landscape evolves and cyberattacks continue to increase, organizations need to take proactive measures to ensure the security of their information systems. The Department of Defense (DoD) has taken a significant step toward this goal by introducing the Cybersecurity Maturity Model Certification (CMMC) framework. CMMC is a set of guidelines and standards with which contractors and subcontractors for the DoD must comply to ensure the protection of sensitive content. One of the critical components of the CMMC compliance process is the Plan of Action and Milestones (POA&M). This article explores POA&M in detail and its role in the CMMC process.
Understanding Plan of Action and Milestones (POA&M)
POA&M is a management tool that helps organizations prioritize and manage cybersecurity risks effectively. It is a document that outlines the steps an organization needs to take to address identified vulnerabilities or weaknesses in its information systems. The POA&M process involves the identification of vulnerabilities, categorization of risks, and the development of mitigation strategies. The document must also include a timeline for the implementation of the strategies and the monitoring of progress.
The Importance of POA&M in CMMC
A POA&M is a structured document that is created after a security assessment is conducted. It outlines security vulnerabilities and associated risks, along with actionable steps and deadlines to fix or remediate those issues. A POA&M can include a wide range of security issues, ranging from the implementation of best practices like regular patching and user training, to the deployment of additional security controls like antivirus and firewall configuration. By having an up-to-date POA&M, an organization can demonstrate evidence of their efforts to improve their overall security posture.
Using POA&M as part of the CMMC certification process is beneficial to both organizations and the DoD, as it helps reduce the potential risks and vulnerabilities associated with noncompliant systems and networks. By having a comprehensive and actionable POA&M in place, organizations are better able to identify, track, and address any security issues immediately. Further, this provides the DoD with assurance that organizations are meeting regulatory requirements for cybersecurity, enabling them to identify organizations that are compliant with the CMMC standard.
Similarities and Differences Between POA&M and a System Security Plan
The Plan of Action and Milestones (POA&M) and System Security Plan (SSP) are two important documents used in cybersecurity. Both documents are created by security/compliance teams to ensure that a secure working environment is provided to organizations.
A POA&M is an active document that tracks vulnerabilities within an organization’s environment. This document outlines the action taken to correct identified weaknesses, along with associated risks, impact, target dates, and resources needed for successful remediation of the identified risks. It is a living document that is updated as vulnerabilities are identified and remediated.
In contrast, an SSP is a static document that is developed before any risk assessment or audit is conducted. The SSP is intended to provide a high-level overview of the organization’s security posture and the security policies used to protect the environment. The SSP outlines the roles and responsibilities of personnel involved in the security process and provides the theoretical basis for security in the organization.
Thus, the main difference between a POA&M and an SSP is that a POA&M focuses on the corrective action taken to address risks while an SSP provides an overview of the security policies in an organization. While both documents are important to protect the organization from cyber threats, the POA&M is more action-oriented, while the SSP is more theory-based.
The Role of POA&M in the CMMC Compliance Process
The POA&M outlines and documents the activities that are necessary to achieve compliance with the CMMC standards. It serves as a roadmap for organizations to track the activities needed to be compliant with each of the three maturity levels. The POA&M should specify the remediation and mitigation activities that must be completed in order to meet the CMMC standards, including corrective actions, as well as preventive measures. It should also identify each milestone to be achieved in order to satisfy a specific CMMC requirement.
Additionally, the POA&M should provide a timeline for the completion of each activity and milestone, and an estimate of the resources required to complete them. The POA&M also helps organizations to track their progress, which is an essential part of the CMMC certification process. By tracking the progress, organizations can identify the steps they have taken to ensure compliance and make any necessary adjustments as needed. This allows organizations to demonstrate their progress and commitment to compliance, and it can be used to guide the CMMC assessor in determining the organization’s maturity level of cybersecurity.
Developing a POA&M for CMMC Certification
Developing a POA&M for CMMC certification involves several steps. These include:
Step 1: Identify Vulnerabilities
The first step in developing a POA&M for CMMC certification is to identify vulnerabilities in an organization’s information systems. This can be done through a cybersecurity risk assessment, which involves identifying assets, threats, and vulnerabilities. The assessment should prioritize risks based on their potential impact on the organization and the data it handles.
Step 2: Categorize Risks
Once vulnerabilities have been identified, they should be categorized based on their severity. This categorization should be based on the potential impact on the organization and the data it handles. Risks can be categorized as high, medium, or low, and mitigation strategies developed accordingly.
Step 3: Develop Mitigation Strategies
Mitigation strategies should be developed for each identified vulnerability. These strategies should be specific, measurable, achievable, relevant, and time-bound (SMART). They should also prioritize high-risk vulnerabilities and align with the organization’s overall cybersecurity strategy.
Step 4: Develop a Timeline
A timeline should be developed for the implementation of the mitigation strategies. The timeline should be realistic and achievable, and should take into consideration any resource constraints the organization may face.
Step 5: Monitor Progress
Once the POA&M has been developed and the mitigation strategies implemented, progress should be monitored regularly. This involves tracking the implementation of the strategies and assessing their effectiveness. Any changes in the threat landscape or organizational environment should be taken into account and adjustments made to the POA&M accordingly.
Benefits of a POA&M for CMMC Certification
Developing a POA&M for CMMC offers several benefits. These include:
1. Enhanced Cybersecurity
The POA&M process helps organizations identify and address vulnerabilities in their information systems, leading to enhanced cybersecurity.
2. Compliance With CMMC Framework
The POA&M document demonstrates an organization’s commitment to cybersecurity and its ability to manage identified risks effectively, thereby increasing the likelihood of compliance with the CMMC framework.
3. Improved Risk Management
The POA&M process involves the identification and categorization of risks, and the development of mitigation strategies. This approach helps organizations prioritize risks and allocate resources effectively, leading to improved risk management.
4. Competitive Advantage
Organizations that have developed a POA&M for CMMC certification have a competitive advantage over those that have not. They are better positioned to win contracts with the DoD and other government agencies that require compliance with the CMMC framework.
5. Best Practices for Developing a POA&M for CMMC Certification
Developing an effective POA&M for CMMC certification requires a structured and comprehensive approach. Some best practices to consider include:
6. Involve Key Stakeholders
Developing a POA&M for CMMC should involve key stakeholders, including senior management, IT staff, and cybersecurity experts. This approach ensures that the POA&M is aligned with the organization’s overall cybersecurity strategy and takes into account any resource constraints or other organizational considerations.
7. Use a Risk-based Approach
The POA&M process should be based on a risk-based approach that prioritizes risks based on their potential impact on the organization and the data it handles. This approach ensures that mitigation strategies are focused on the most critical risks and are aligned with the organization’s overall cybersecurity strategy.
8. Be Specific and Measurable
Mitigation strategies should be specific and measurable, and should align with the SMART principle. This approach ensures that progress can be tracked effectively, and adjustments made as necessary.
9. Develop a Realistic Timeline
The timeline for the implementation of the mitigation strategies should be realistic and achievable, taking into consideration any resource constraints or other organizational considerations. This approach ensures that progress can be made effectively, without compromising the organization’s overall cybersecurity posture.
10. Monitor Progress Regularly
Progress should be monitored regularly, and adjustments made as necessary. This approach ensures that the POA&M remains relevant and effective, taking into account any changes in the threat landscape or organizational environment.
Reviewing and Updating POA&M
Organizations should review and update their POA&M at least annually to ensure that it is in line with the CMMC requirements. This should include a review of the organization’s current environment and any changes to its business operations or technology infrastructure. In addition, organizations should review the POA&M to make sure the control objectives and milestones are still valid, and to add in any new objectives and milestones that may be needed.
1. Continuous Monitoring
Continuous monitoring is an important part of the POA&M process. Organizations should monitor their security environment, processes, and protocols on an ongoing basis to identify any changes or weaknesses in the system. This allows organizations to address any issues quickly and efficiently before they become a security risk.
2. Addressing Changes in the Environment
Organizations should also assess their environment on a regular basis and make changes where necessary, such as updating security protocols or introducing new technologies. This can help ensure that the organization meets the CMMC requirements and keeps its security environment up to date.
3. Evaluating Effectiveness
Organizations should also evaluate the effectiveness of their POA&M on a regular basis, including conducting internal and external reviews to ensure the effectiveness of the system. This is an important part of the continuous monitoring process and can help organizations identify any potential weaknesses in their security environment and take action to address them.
4. Updating POA&M as Needed
Organizations should also update their POA&M as needed. This may include changes to the control objectives, milestones, or the environment in which the organization operates. Organizations should also consider any changes to the CMMC assessment that may require updates to the POA&M.
Tools and Resources for Creating a POA&M
There are a number of tools and resources available to help organizations create and implement a POA&M. The National Institute of Standards and Technology (NIST) provides a cybersecurity framework (NIST CSF) for organizations to use for their POA&M. The CMMC Assessment Guide also provides guidelines for developing a POA&M. The Cybersecurity Assessment Tool (CAT) and Security Content Automation Protocol (SCAP) can be used to assess the security environment of an organization and create a POA&M. Additionally, organizations can leverage other industry-specific resources and tools to create a POA&M that meets their cybersecurity needs.
Challenges in Creating and Implementing a POA&M
Creating and implementing a successful POA&M can be a challenge for many organizations. Organizations may lack the resources to adequately develop and implement a POA&M. There may also be resistance to change within the organization, which can make it difficult to implement a POA&M. Additionally, complex environments can make it difficult to ensure that all components of the POA&M are taken into account. Cost considerations can also play a role in creating and implementing a POA&M, especially if an organization lacks the resources to develop and maintain its POA&M. Finally, organizations may lack the staffing and expertise needed to effectively create and maintain a POA&M.
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DoD contractors and subcontractors that are looking to speed up their CMMC 2.0 Level 2 accreditation process should ensure they have the right sensitive content communications platform in place.
Kiteworks is FedRAMP Authorized, meaning it complies with or partially complies with a higher number of CMMC 2.0 Level 2 practice areas than its competitors. This means that DoD contractors and subcontractors using the Kiteworks-enabled Private Content Network have nearly 90% compliance with CMMC 2.0 practice areas, as opposed to 50% with other solution options. To take advantage of this opportunity, DoD contractors and subcontractors should consider the Kiteworks platform.
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