CA.L2-3.12.2[b]: Document Your POA&Ms to Track and Resolve Security Gaps

Mapped to NIST 800-171 Requirement: 3.12.2
CMMC Assessment Objective: CA.L2-3.12.2[b]

What This Control Means
After identifying areas where your controls are partially or not implemented (CA.L2-3.12.2[a]), this control confirms that you have developed documented POA&Ms that clearly show:
• What the deficiency is
• How you plan to correct it
• When it will be addressed
• Who is responsible
• What milestones will track progress
These plans provide a clear roadmap to full compliance.

Why It Matters
POA&Ms are:
• A required element of DFARS and CMMC compliance
• The way to handle controls that are “Not Yet Implemented”
• Evidence that your organization is taking responsibility for securing CUI—even if you’re not fully there yet
Without documentation, nothing proves your intentions or efforts.

How to Implement It
1. Use a Standard POA&M Format Each entry should include:
• Control reference (e.g., SC.L2-3.13.8)
• Description of the deficiency
• Remediation steps
• Responsible individual or team
• Milestones and completion dates
• Current status (Planned, In Progress, Complete)
2. Store in a Central Location
• Ideally in a compliance dashboard, GRC tool, or shared folder
• Ensure it is version-controlled and regularly updated
3. Link to SSP and Risk Register
• Show how POA&M entries tie back to known risks or gaps identified in your assessments
4. Review and Update Routinely
• Weekly or monthly check-ins depending on the number of open items and deadlines

Evidence the Assessor Will Look For
• A complete and current POA&M with entries tied to control deficiencies
• Documentation showing owner assignments and deadlines
• Evidence of updates or progress tracking
• SSP references to controls marked “Planned” or “Not Implemented” that have corresponding POA&M entries
• Risk-based prioritization of POA&M items

Common Gaps
• Security weaknesses identified but no documented remediation plan
• POA&M exists but has no detail (no dates, owners, or milestones)
• POA&M and SSP are inconsistent or disconnected
• No updates or review activity in the POA&M

How Cuick Trac Helps
Cuick Trac supports this requirement by:
• Providing a structured POA&M framework preloaded with NIST 800-171 control references
• Automatically generating POA&M items based on assessment results or SSP status
• Assigning responsible parties and due dates for each item
• Logging updates, completions, and status changes for full traceability
• Integrating POA&M activity with your compliance reports and dashboards
With Cuick Trac, your POA&M isn’t just a document—it’s a dynamic project plan for continuous improvement.

Final CTA
Intentions don’t fix vulnerabilities—plans do.
Schedule a Cuick Trac demo to develop and document your POA&M the right way—clear, complete, and compliant.

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