CMMC Navigatorby Foxx Cyber Bedrock CMMC

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3.12.2Write and work a POA&M

Every gap has an owner, a plan, and a date.

The requirement, verbatim

NIST SP 800-171 Rev. 2 · 3.12.2

Develop and implement plans of action designed to correct deficiencies and reduce or eliminate vulnerabilities in organizational systems.

Requirement 3.12.2, practice name in the CMMC assessment guide: Plan of Action.

NIST's discussion

The plan of action is a key document in the information security program. Organizations develop plans of action that describe how any unimplemented security requirements will be met and how any planned mitigations will be implemented. Organizations can document the system security plan and plan of action as separate or combined documents and in any chosen format.

Federal agencies may consider the submitted system security plans and plans of action as critical inputs to an overall risk management decision to process, store, or transmit CUI on a system hosted by a nonfederal organization and whether it is advisable to pursue an agreement or contract with the nonfederal organization.

NIST SP 800-171 Rev. 2, discussion under 3.12.2. Whitespace normalised; wording unchanged.

Assessment objectives

An assessor decides each of these separately. The requirement is met only when every objective is.

  1. [a] plans of action are developed to address deficiencies and reduce or eliminate vulnerabilities in organizational systems
  2. [b] plans of action are implemented to address deficiencies and reduce or eliminate vulnerabilities in organizational systems

NIST SP 800-171A, determination statements for 3.12.2.

For assessors: examine, interview, test

NIST SP 800-171A names what an assessor may examine, whom they may interview, and what they may test for this requirement. Assessors select from these lists; they are not a checklist of everything you must produce.

Examine
  • Security assessment and authorization policy
  • procedures addressing plan of action
  • system security plan
  • security assessment plan
  • security assessment report
  • security assessment evidence
  • plan of action
  • other relevant documents or records
Interview
  • Personnel with plan of action development and implementation responsibilities
  • personnel with information security responsibilities
Test
  • Mechanisms for developing, implementing, and maintaining plan of action

NIST SP 800-171A, potential assessment methods and objects for 3.12.2.

Evidence

No evidence examples are published for this requirement yet. The objectives above are what an assessor checks; evidence is whatever shows each one is true in your environment, dated and kept with your system security plan.

Scoring weight

Worth 3 points. Not meeting this requirement subtracts 3 from your 110-point SPRS score.

DoD NIST SP 800-171 Assessment Methodology v1.2.1 weighting, as carried in the Bedrock scoring table. The score starts at 110 and subtracts the weight of every requirement not met.

In Rev. 3

Rev. 2 is what your contract requires today. A standing DoD class deviation keeps Rev. 2 in force; NIST has published Rev. 3, but it is not adopted for contracts. In Rev. 3 this requirement is reworded: 03.12.02 Plan of Action and Milestones.

See the Rev. 2 and Rev. 3 wording word by word, or start with the status page.

Where this page's facts come from
Requirement text
bedrock-cmmc-api@89b8e8e:migrations/004_reference_requirements.sql#Requirement.basicRequirement@rev2
Discussion
bedrock-cmmc-api@89b8e8e:migrations/004_reference_requirements.sql#Requirement.discussion@rev2
Practice name
bedrock-cmmc-api@89b8e8e:migrations/004_reference_requirements.sql#Requirement.title@rev2 (CMMC Assessment Guide practice name)
Objectives
bedrock-cmmc-api@89b8e8e:migrations/005_reference_objectives.sql#AssessmentObjective.description@rev2
Examine, interview, test
bedrock-cmmc-api@89b8e8e:migrations/005_reference_objectives.sql#AssessmentObjective.description@rev2 ({examineGuidance, interviewGuidance, testGuidance})
Level
bedrock-cmmc-api@89b8e8e:migrations/021_fix_level1_requirements.sql#Requirement.cmmcLevel@rev2
Weight
bedrock-cmmc-api@89b8e8e:internal/cmmc/requirement_values.go#requirementValues (DoD AM v1.2.1 / eMASS L2 template v3.8)
Rev. 3 mapping
bedrock-cmmc-api@89b8e8e:docs/reference/nist-800-171-rev3/normalized/r2_r3_transition_map.json#r2_to_r3
Plain-language title and summary
editorial/CMMC Navigator.dc.html#RAW (Foxx Cyber editorial)