EvidenceSheet
NIST SP 800-53 Rev 5 · PM - Program Management

PM-4 Plan of Action and Milestones Process

a. Implement a process to ensure that plans of action and milestones for the information security, privacy, and supply chain risk management programs and associated organizational systems: 1. Are developed and maintained; 2. Document the remedial information security, privacy, and supply chain risk management actions to adequately respond to risk to organizational operations and assets, individuals, other organizations, and the Nation; and 3. Are reported in accordance with established reporting requirements. b. Review plans of action and milestones for consistency with the organizational risk management strategy and organization-wide priorities for risk response actions.

Source: NIST SP 800-53 Rev 5, PM-4. The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open NIST SP 800-53 Rev 5 in the compliance library.

Base controls and their enhancements. Which apply follows the baseline you are assessed against (for example FedRAMP Moderate or High, or the low, moderate and high baselines of SP 800-53B). Text in square brackets is a parameter your organisation sets.

8
artefacts
0
held by a system
2
at each review
hard
to go live
Policy repository / GRC workspace
where the evidence lives
teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

none for this control

periodic reviewEvidence produced at each review

  • Results of risk assessments associated with plans of action and milestones · Policy repository / GRC workspace
  • Test of Organizational processes for plan of action and milestones development, review, maintenance, and reporting; mechanisms supporting plans of action and milestones · Policy repository / GRC workspace

governing documentDocuments that govern the control

  • Information security program plan · Policy repository / GRC workspace
  • Plans of action and milestones · Policy repository / GRC workspace
  • Procedures addressing plans of action and milestones development and maintenance · Policy repository / GRC workspace
  • Procedures addressing plans of action and milestones reporting · Policy repository / GRC workspace
  • Procedures for reviewing plans of action and milestones for consistency with risk management strategy and risk response priorities · Policy repository / GRC workspace
  • OMB FISMA reporting requirements · Document repository

First move

No system holds this evidence for you: it is people and documents. Reminders and routing to the owner still save time. Put the document under version control with an owner and review date, and log each review as a record with reviewer and date.

Common gaps auditors find

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.

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PM-3 Information Security and Privacy Resources · PM-5 System Inventory