FedRAMP guide

FedRAMP POA&M template and workflow

By the ShipReady Metrics research team. Published September 22, 2026. Sources are cited inline at the end of each page.

The Plan of Action and Milestones is where FedRAMP weaknesses live between discovery and closure. It is also the first document reviewers open. This guide walks the template and the operating workflow around it, based on FedRAMP's POA&M Template Completion Guide.

What a POA&M entry must carry

Field	What good looks like
Weakness name and description	Specific enough to re-test: affected hosts, the finding, the risk. Not "patch management issue."
Detection date and source	The scan or assessment that found it. Age is counted from discovery, not from when someone got around to writing it down.
Severity	High, moderate or low, which sets the remediation window: 30, 90 or 180 days respectively.
Remediation plan and milestones	Dated, owned steps. A milestone in the past with no progress note is the single most common reviewer flag.
Owner	A named person accountable for closure.
Status	Open, in progress, pending vendor, or closed with evidence attached.

The vendor-dependency rule people miss

When remediation depends on a third party (a patch that does not exist yet), the POA&M marks the item as pending vendor remedy. FedRAMP's completion guide requires the CSP to check the vendor's status at least every 30 days. As long as that check-in is documented within 30 days of each POA&M submission, the item is not counted as delinquent. Skip the check-in and the item ages against you, even though nothing about the vulnerability changed. Calendar the check-in; it is cheap and it is auditable.

Deviation requests

Not every scanner finding is a real weakness. FedRAMP provides documented paths: false positives, risk adjustments, and operational requirements. Each needs evidence and approval through the proper channel before the item comes off the POA&M. The anti-pattern is the quiet deletion: an item that disappears between monthly submissions with no deviation record reads as tampering, and it converts a paperwork task into a trust problem.

Closure means evidence

A POA&M item closes when a re-scan or re-test shows the finding resolved, and that artifact is attached to the entry. "Deployed the fix" is not closure; "scan on September 15 shows zero instances of CVE-2025-XXXX across the boundary" is. Keep closure artifacts with the entry so the annual 3PAO assessment can sample them without archaeology.

Operating rhythm

1. New findings enter the POA&M as scans complete, not in a monthly batch.
2. Weekly: owners update milestones; anything within 14 days of its window gets escalation.
3. Monthly: vendor-dependency check-ins documented, full export reviewed, submission assembled with scan results. See the monthly deliverables checklist.
4. Quarterly: aging review. Any item approaching its 30/90/180-day window gets a decision: remediate, or document a deviation.

Frequently asked questions

How long do we have to remediate a FedRAMP finding?

High-risk vulnerabilities: 30 days from discovery. Moderate: 90 days. Low: 180 days. Vendor-dependent items are not delinquent while the required 30-day vendor status check-ins are documented.

Can we close a false positive ourselves?

Only through a documented deviation request with evidence, approved through the proper channel. Self-closing without that record is the pattern reviewers are trained to catch.

What is the difference between a POA&M and a risk register?

The POA&M is specific: known weaknesses, with discovery dates, remediation windows and evidence. A risk register is broader and internal. FedRAMP reviewers work from the POA&M.