CMMC Plan of Action & Milestones

Overview

Draft and validate the CMMC POA&M: track control deficiencies, remediation plans, owners, and due dates for Conditional Level 2 or Level 3.

Getting Started

Add your source materials to the project workspace, then activate the CMMC Plan of Action & Milestones skill. The agent will guide you through the process step by step.

Example Conversation

You: We have CMMC Level 2 assessment findings and need a POA&M. Three practices failed: 3.5.7 (MFA for non-privileged), 3.8.5 (media sanitization), and 3.11.2 (security assessments). Can you draft the POA&M with owners and dates?
Agent: I’ll create a POA&M with one entry per finding. Each item will have: finding (practice ID and title), remediation plan, owner, target completion date, and risk. Note: 3.12.4 (System Security Plan) cannot be on the POA&M for Level 2 — I’ll ensure none of your items reference it.
Agent: I’ve drafted poam.md with three items. 3.5.7 — Remediation: Extend MFA to all user accounts per Identification and Authentication policy; Owner: IAM Lead; Target: 30 Apr 2025; Risk: Medium. 3.8.5 — Remediation: Document and implement media sanitization procedure; certify disposal vendor; Owner: IT Operations; Target: 15 May 2025. 3.11.2 — Remediation: Schedule and complete annual security assessment; document scope and findings; Owner: Security Officer; Target: 30 Jun 2025. Should I run the POA&M validator?
You: Yes.
Agent: [Runs cmmc_poam_validator] PASS. All items have owner and remediation language; target dates present; no ineligible practice (3.12.4) on the POA&M.

Sample Output Excerpt

Below is a representative excerpt from a CMMC POA&M.

POA&M Items

ID	Practice	Finding	Remediation	Owner	Target date
1	3.5.7	Multifactor authentication not enforced for non-privileged accounts on Contract App.	Enable MFA for all user logons in Contract App; update I&A policy to require MFA for all in-scope systems.	IAM Lead	30 Apr 2025
2	3.8.5	Media sanitization procedure not documented; disposal vendor not certified for sanitization.	Document media sanitization procedure; obtain certificate of sanitization from disposal vendor; retain records.	IT Operations	15 May 2025
3	3.11.2	Annual security assessment not completed for current assessment period.	Complete internal security assessment; document scope, methodology, and findings; update SSP with assessment date.	Security Officer	30 Jun 2025

Practice 3.12.4 (System Security Plan) cannot be on the POA&M for Level 2 certification.

Built-in Scripts and Validation

The skill includes a validator the agent runs against the POA&M document.

Validation tools

Tool	Purpose
cmmc_poam_validator	Validates POA&M content for required fields and eligibility. Checks: (1) each item has an owner or responsible party; (2) target or completion date is present; (3) remediation or corrective action language is present; (4) no item references practice 3.12.4 (System Security Plan) — that practice cannot be on the POA&M for Level 2 and must be fully implemented before certification. Returns PASS or FAIL with issues and warnings. Run after each POA&M update.

Tool

Purpose

cmmc_poam_validator

Validates POA&M content for required fields and eligibility. Checks: (1) each item has an owner or responsible party; (2) target or completion date is present; (3) remediation or corrective action language is present; (4) no item references practice 3.12.4 (System Security Plan) — that practice cannot be on the POA&M for Level 2 and must be fully implemented before certification. Returns PASS or FAIL with issues and warnings. Run after each POA&M update.