Introduction

Achieving and maintaining FedRAMP compliance is crucial for Cloud Service Providers (CSPs) seeking to serve federal agencies. A key component of maintaining compliance is monitoring your Plan of Action and Milestones (POA&M). A POA&M is an essential part of FedRAMP’s security authorization package and continuous monitoring activities. The POA&M identifies a system’s known weaknesses and security deficiencies and outlines the corrective actions the CSP will undertake, as well as the associated timeline by which said actions will occur.

Understanding the Purpose of a POA&M

The primary purpose of a POA&M is to provide a structured approach to tracking risk mitigation activities according to the CSP’s priorities. It includes security findings from periodic security assessments and ongoing continuous monitoring activities, along with the CSP’s intended corrective actions and their current status. FedRAMP uses the POA&M to monitor the CSP’s progress in addressing these findings, as well as their historical consistency in monitoring and addressing security deficiencies

Key Elements of a POA&M

• Security Categorization: The cloud information system's security level.
• Weaknesses and Deficiencies: Specific weaknesses in deployed security controls.
• Importance and Scope: The criticality and extent of identified security control weaknesses.
• Risk Mitigation Approach: Proposed methods for addressing identified weaknesses.
• Tasks and Milestones: Detailed actions, milestones, and scheduled completion dates.

Scope of a POA&M

The scope of a POA&M includes all management, operational, and technical security control implementations that have unacceptable weaknesses or deficiencies. CSPs must submit an updated POA&M to the Authorizing Official (AO) in line with the FedRAMP Continuous Monitoring Strategy & Guide.

POA&M Template Overview

The FedRAMP POA&M Template is an Excel workbook with two worksheets:

1. Open POA&M Items: Contains unresolved entries.
2. Closed POA&M Items: Contains resolved entries.

Open POA&M Items Worksheet

This worksheet is divided into two sections:

1. Header Information: Basic system information such as vendor name, system name, impact level, and the last update date.
2. Corrective Action Plan: Details of each open POA&M entry, including a unique identifier, affected security control, weakness description, and planned milestones.

Key Columns in the Open POA&M Items Worksheet

• POA&M ID: Unique identifier for each POA&M item.
• Controls: Affected FedRAMP security control.
• Weakness Name and Description: Details of the identified weakness.
• Detector Source and Source Identifier: Origin of the weakness identification.
• Asset Identifier: Specific asset associated with the weakness.
• Point of Contact and Resources Required: Responsible person and necessary resources for resolving the weakness.
• Remediation Plan: High-level summary of the remediation actions.
• Detection and Completion Dates: Original detection date and scheduled completion date.
• Milestones and Status Date: Specific actions to correct the weakness and the latest date of action.
• Vendor Dependency and Check-in Date: Dependencies on third-party vendors and the date of the most recent check-in.

Closed POA&M Items Worksheet

This worksheet contains POA&M items that have been completed, reflecting all information from the Open POA&M Items worksheet but updated with the date of completion. The importance of this sheet is the historical evidence it provides to show CSPs are consistently in compliance with FedRAMP vulnerability remediation timeline requirements.

Integrated Inventory Workbook

CSPs must maintain an inventory workbook using the FedRAMP Integrated Inventory Workbook Template, which must be submitted monthly along with the POA&M and other continuous monitoring deliverables.

General Requirements

CSPs must include all security vulnerabilities identified through various means (vulnerability scanning tools, interviews, penetration testing) in the Open POA&M Items worksheet, especially those that are late in remediation. High and critical risk findings must be remediated before receiving a JAB P-ATO, and the remediation timelines for different risk levels are as follows:

• High and Critical Risk: Within 30 days.
• Moderate Risk: Within 90 days.
• Low Risk: Within 180 days.

Conclusion

Maintaining a FedRAMP-compliant POA&M is essential for CSPs aiming for FedRAMP JAB P-ATO or Agency ATO. By adhering to the guidelines provided in this document and using the FedRAMP POA&M Template, CSPs can ensure a structured and disciplined approach to tracking and mitigating security risks, ultimately achieving and maintaining FedRAMP compliance.

If you require a FedRAMP compliance expert to navigate the complexities and challenges of the process, contact InfusionPoints today by clicking the button below.