Mapped to NIST 800-171 Requirement: 3.12.2
CMMC Assessment Objective: CA.L2-3.12.2[c]
What This Control Means
This is the execution checkpoint: it confirms that you are following through on the POA&Ms you’ve created. That includes:
• Addressing known gaps
• Completing remediation milestones
• Updating the status of POA&M items
• Closing resolved issues with documentation and verification
This ensures your risk mitigation strategy is not just written, but working.
Why It Matters
If POA&Ms aren’t acted on:
• CUI systems remain exposed to known risks
• Compliance efforts stall or regress
• Your organization may fail CMMC certification or DFARS review
• There is no evidence of a functioning continuous improvement program
This control is about delivering on your security commitments.
How to Implement It
1. Track POA&M Execution
• Maintain a live POA&M with updated statuses (Planned, In Progress, Complete)
• Assign deadlines and enforce accountability
2. Log Supporting Evidence
• When a control is implemented:
◦ Save screenshots
◦ Upload configs or policy updates
◦ Record testing or validation results
3. Update Related Documentation
• Reflect completed actions in your:
◦ System Security Plan (SSP)
◦ Risk Register
◦ Assessment records
4. Monitor for Stalled Items
• Flag overdue tasks
• Escalate unaddressed risks that impact CUI protection
5. Conduct Regular Review
• Monthly check-ins or status meetings with stakeholders
• Quarterly audit of POA&M progress
Evidence the Assessor Will Look For
• POA&M entries showing real progress (status changes, completion notes)
• Evidence that actions were taken (logs, screenshots, tickets)
• Updates to SSP or control documentation after POA&M completion
• Risk acceptance documentation for any deferred or low-priority items
• Demonstrable closure of previously flagged CUI-related control gaps
Common Gaps
• POA&M created but never updated
• No evidence that assigned actions were completed
• Control gaps remain unmitigated months after identification
• Documentation is inconsistent or lacks validation of closure
How Cuick Trac Helps
Cuick Trac supports this requirement by:
• Providing real-time POA&M dashboards that track implementation status
• Assigning owners and deadlines with escalation workflows for overdue items
• Logging completed actions with attached evidence (screenshots, documents)
• Syncing POA&M progress with your SSP and compliance reports
• Ensuring you can demonstrate implementation of every open plan
With Cuick Trac, your POA&M becomes a living compliance engine, not a forgotten spreadsheet.
Final CTA
Fix the issue—then prove you fixed it.
Schedule a Cuick Trac demo to track and implement your POA&M with full transparency and compliance confidence.