POA&M vs. “Mitigation” — Clearing Up a Common Misunderstanding

In federal cybersecurity, acronyms rule. One of the most misunderstood is POA&M.

What POA&M Really Means

POA&M stands for Plan of Action and Milestones. It’s an official term across DoD, FedRAMP, and NIST RMF.

A POA&M isn’t just a note about what you’ll fix — it’s a structured tracker for both the work and the proof of progress:

• Issue identified (finding, failed STIG check, CVE, audit result)
• Plan of action (patch/config/control/compensating control)
• Milestones with dates, owners, and checkpoints
• Target completion and ongoing status updates

Key idea: A POA&M tracks accountability + progress, not just the intended fix.

The Misunderstanding: “Plan of Action and Mitigation”

You’ll sometimes hear people say “Plan of Action and Mitigation.” It sounds right in a security context, but it’s not the official term — and it misses what matters:

• Focuses only on the mitigation
• Ignores the timeline and ownership
• Provides no audit trail to show measurable progress

✅ POA&M (Plan of Action and Milestones)
Accountability, dates, owners, checkpoints, completion.

❌ “Mitigation” only
Intent to fix without the when, who, or proof it’s happening.

Why the Difference Matters

In federal programs, the difference can decide whether a system gets an ATO (Authority to Operate).

• With a POA&M: You can sometimes receive an ATO even with open findings, because risks are documented with owners and deadlines.
• With only “mitigation”: Authorization may stall — you’ve stated intent, but not a plan, milestones, or proof of progress.

Bottom line: The “M” in POA&M is Milestones, not Mitigation.

Commercial-World Equivalent

If you’re coming from commercial IT/MSP work, think of a POA&M as a combination of:

• A security remediation plan from an audit,
• A Jira/ITSM backlog with due dates and owners, and
• A risk register leadership reviews regularly.

It’s a living roadmap anyone can follow, update, and audit.

Closing Thought

Next time you hear “Plan of Action and Mitigation,” remember the official term is Plan of Action and Milestones. In the federal space, proof matters as much as protection — and POA&Ms provide both.

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