CA-5 Plan of Action and Milestones
Develop POAM; update at least monthly (FedRAMP); track remediation timelines (HIGH 30 days, MOD 90).
5
artefacts
1
held by a system
1
at each review
hard
to go live
Document repository
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
- Continuous monitoring strategy with metric definitions · SIEM / log platform
periodic reviewEvidence produced at each review
- Authorization to operate memorandum signed by the authorizing official · Document repository
governing documentDocuments that govern the control
- Control implementation statement for CA-5 citing the system mission and inheritance from common controls · Document repository
- Plan of action and milestones tracking open findings · Policy repository / GRC workspace
- Independent assessor statement of independence · Document repository
First move
Mostly documents and reviews. Pull the 1 system-held artefact from your SIEM / log platform on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.
Common gaps auditors find
- POAM items past due without justification or risk acceptance
- Continuous monitoring metrics collected but not reported to leadership
- Assessment scope omits inherited cloud provider controls
Do this for your whole sheet
Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.
Build my evidence sheet