Free POAM Template for CMMC — Download + How to Use It

What Is a POAM and Why Do You Need One?

A Plan of Action and Milestones (POA&M) is a formal document that tracks every NIST SP 800-171 security requirement your organization has not yet fully implemented. It lists each gap, the planned steps to close it, who is responsible for closing it, and the target date by which the work will be done.

Under CMMC Level 2, the POA&M is not optional. NIST 800-171 requirement 3.12.2 mandates that organizations develop and implement action plans to correct deficiencies in their security requirements. The DoD Assessment Methodology and the CMMC program both expect to see a POA&M for any control that is not currently implemented. Without one, a gap in your environment is not a documented, managed deficiency — it is an unmanaged risk, and assessors treat those very differently.

The POA&M also directly affects your SPRS score. Not Met controls reduce your score from the 110 baseline. As you implement controls and close POA&M items, you can update your SPRS submission to reflect the improved score. The POA&M is the mechanism that links your gap-closing work to your legal attestation.

Download the Free POAM Template

The template below includes all required fields in a format that matches DoD expectations. It works as a spreadsheet (Excel or Google Sheets) and is structured so each row is one POAM item.

The required columns are:

• Item ID — a sequential identifier for cross-referencing with your SSP (e.g., POAM-001)
• NIST 800-171 Requirement — the specific requirement number and title (e.g., 3.5.3 — Multi-Factor Authentication)
• Weakness / Gap Description — a clear description of what is not implemented and why the requirement is not currently Met
• Point of Contact — the person or team responsible for remediation
• Remediation Steps — the specific actions required to close the gap (not just "implement MFA" but the actual steps: procure tool, configure policies, enroll users, test enforcement)
• Resources Required — budget, tools, personnel, or external assistance needed
• Target Completion Date — a realistic date by which all remediation steps will be complete
• Milestones — intermediate checkpoints with dates for multi-step remediations
• Status — current status (Not Started / In Progress / Complete)
• Completion Date — the actual date the item was closed (filled in when complete)

You can download this template directly from RegulatoryForge. The download is free and does not require an account.

How to Populate Your POAM

A blank template is only useful if you know what goes in it. Here's how to populate each field in a way that satisfies assessors and supports your actual remediation work.

Step 1: Complete Your Gap Assessment First

You cannot write a POAM before you know your gaps. Work through all 110 NIST 800-171 requirements (ideally at the 320 assessment objective level from NIST 800-171A) and identify every requirement that is Not Met or only partially implemented. Each one becomes a POAM item.

Do not skip this step and go straight to the POAM. A POAM that doesn't accurately reflect your gaps is worse than a complete one — it suggests you have a controlled remediation program when you have an incomplete picture of your risk.

Step 2: Write Specific Gap Descriptions

The weakness description is the most important field in the POAM, and it is routinely written too vaguely. A weak description says: "MFA is not implemented." A strong description says: "Multi-factor authentication is not enforced for remote access sessions (VPN) or for access to the file server \\\\FS01. Standard users can authenticate with a password only. MFA is enforced for Microsoft 365 access but not for on-premises systems."

The strong description tells the assessor exactly what is missing and where. It also makes the remediation steps obvious, because you've been precise about the scope of the gap.

Step 3: Write Actionable Remediation Steps

Remediation steps are not goals — they are the specific actions required to achieve the goal. For the MFA example above, generic steps would say: "Implement MFA for all systems." Specific steps would say:

• Evaluate MFA solutions for on-premises systems (Microsoft Entra ID hybrid, Cisco Duo, or similar)
• Select and procure tool
• Configure MFA integration with Active Directory
• Enroll all privileged accounts
• Pilot with a test group of 5 users
• Configure Conditional Access to block login without MFA for VPN and FS01
• Enroll all standard user accounts
• Test enforcement for all authentication paths
• Document configuration in SSP and collect evidence screenshots

This level of detail is useful for your own project management and signals to assessors that you have a real plan, not a placeholder.

Step 4: Set Realistic Target Dates

Assessors routinely review POAM dates for feasibility. A POAM that shows 40 open items with all completion dates in the next 30 days is not credible — and that lack of credibility extends to your other compliance claims. Set dates based on actual resource availability, the complexity of the remediation, and any dependencies (procuring a tool before you can configure it, for example).

Use the milestones column for multi-step remediations. If implementing a vulnerability scanning program takes 90 days, set milestones at 30 days (tool selected and procured), 60 days (first scan completed), and 90 days (remediation of critical findings complete, recurring scan schedule established).

Step 5: Keep Status Current

A POAM that is never updated is not a compliance document — it is a list of good intentions from the past. Update the status of each item at least monthly. When an item is complete, record the actual completion date, collect and attach the evidence, update the implementation statement in your SSP, and recalculate your SPRS score.

The POAM is the audit trail that shows the DoD your compliance program is real and active. Contractors who complete items and don't update their SPRS score — or who have a POAM that hasn't been touched in six months — raise questions that are hard to answer.

Common POAM Mistakes to Avoid

• Treating the POAM as a compliance checkbox, not a project plan. Every open item should have a real person responsible for it and a realistic date. If you wouldn't use it to manage the remediation project, it won't satisfy an assessor either.
• Combining multiple gaps into one item. If MFA is not implemented for VPN, for the file server, and for the cloud management console, those are three separate items — each with its own timeline, owner, and remediation steps. Combining them makes it impossible to track progress and impossible for an assessor to evaluate your closure rate.
• Leaving items open indefinitely. Every POAM item must have a target completion date. Items with no date — or with dates that have passed without closure — are significant findings. Reassign dates if your timeline changes, but keep every item anchored to a real commitment.
• Not updating the SSP when items close. The SSP and POAM must be consistent. When a POAM item closes, the corresponding SSP implementation statement must be updated to reflect that the control is now Met, and evidence must be documented.
• Submitting a new SPRS score without closing the corresponding POAM items first. Your SPRS score, your SSP, and your POAM are a single consistent compliance record. Updating one without updating the others creates contradictions that assessors will find.

POAM for a C3PAO Assessment: What to Expect

If your contract requires a C3PAO assessment, your POAM will be reviewed as part of that assessment. Assessors will:

• Compare open POAM items against your SPRS score to confirm that Not Met controls are reflected accurately
• Review closure evidence for items you've marked complete
• Ask about your remediation progress on in-progress items and whether you're on track to meet your target dates
• Evaluate whether your POAM reflects a realistic and managed remediation program, or appears to be a document created to satisfy a requirement without active management

The contractors who navigate POAM review most smoothly are those who have been using it as an actual project management tool — with regular updates, real closure evidence, and consistent cross-referencing with the SSP.

How RegulatoryForge Manages Your POAM

The POAM tracker in RegulatoryForge is built into the Compliance Tracker alongside your control assessments. When you mark a control as Not Met during your gap assessment, a POAM item is automatically created with the requirement name and number pre-populated. You add the gap description, owner, remediation steps, and target date. As you close items, the tracker updates your compliance percentage and prompts you to update the corresponding SSP section. When you're ready to update your SPRS score, the SPRS Wizard pulls the current Not Met count from your tracker and runs the deduction calculation against the DoD weighting table.

The free downloadable template is a good starting point if you're working in a spreadsheet today. When you're ready for something that integrates with your SSP and SPRS submissions, RegulatoryForge is built for exactly that workflow.