FedRAMP POA&M Benchmarks:
What 12 Assessments Show

1. What a POA&M Is in FedRAMP

A Plan of Action and Milestones (POA&M) documents controls or control enhancements that are not fully satisfied at the time of assessment and the CSP’s plan to remediate them. POA&Ms are reviewed by the 3PAO and subsequently by the authorizing official (agency or JAB). Quality, specificity, and residual risk treatment matter as much as the mere presence of items.

POA&Ms are not the same as a failed assessment. They are the structured mechanism FedRAMP uses to acknowledge residual risk in a time-bounded, trackable way.

2. Observed Frequency (N = 12)

3. Most Common POA&M Categories

When residual findings were placed on a POA&M, they most often fell into these areas (aligned with the top residual findings overall):

1. Audit & Accountability (AU) — incomplete event coverage, review cadence, or log protection
2. Configuration Management (CM) — baselines not maintained; change control gaps; inventory drift
3. Access Control (AC) — account lifecycle, least privilege, remote access evidence
4. Identification & Authentication (IA) — MFA coverage and authenticator management
5. System & Information Integrity (SI) — flaw remediation timelines and scanning coverage
6. Continuous monitoring / CA family — weak ongoing operational evidence

Addressing these families during readiness is the highest-leverage way to reduce both residual findings and POA&M volume.

4. What a “Good” FedRAMP POA&M Looks Like

• Specific — tied to a named control or control enhancement and a concrete gap
• Time-bounded — clear milestone dates with realistic remediation steps
• Owned — named responsible party
• Residual risk stated — what risk remains until closed, and how it is accepted or mitigated in the interim
• Evidence-ready — the planned remediation will produce assessable artifacts
• Limited in scope — not a laundry list that effectively defers core implementation

Assessors and authorizing officials distinguish between a manageable set of well-scoped residual items and a POA&M that signals incomplete implementation. The former is normal; the latter raises risk and extends timelines.

5. POA&Ms and the Authorization Path

A limited, high-quality POA&M does not prevent authorization. In practice:

• 3PAO assessment documents residual findings and the CSP’s POA&M
• Agency or JAB review evaluates residual risk, milestones, and overall package maturity
• CSPs that close items on schedule and provide clear close-out evidence maintain momentum
• CSPs that produce vague POA&Ms or defer remediation experience longer review cycles and more follow-up questions

In this dataset, organizations that treated POA&M development as a disciplined project (owner, due date, residual risk, close-out evidence plan) moved through post-assessment steps more smoothly.

6. Practical Implications for CSPs

• Do not treat “zero POA&M” as the only success metric. 92% of assessments in this dataset had at least one item.
• Invest in POA&M quality. Specific milestones and residual risk statements reduce friction with both 3PAOs and authorizing officials.
• Pre-empt the top categories. AU, CM, AC, and IA account for a disproportionate share of residual findings and POA&M items.
• Plan close-out evidence from day one. Weak close-out packages create avoidable delay.
• Tighter authorization boundaries help. Cleaner scope correlated with more limited POA&M profiles.

7. Related Benchmark Metrics (N = 12)

• Median formal assessment duration: 42 business days
• Required additional evidence during assessment: 92% (11 of 12)
• Average evidence volume: ~3,400 artifacts
• Tightly bounded vs complex multi-component: 58% / 42%

Full context: 2026 FedRAMP Assessment Benchmark Report (Lazarus Alliance).

8. Authors & How to Cite

Lead Author
Michael D. Peters, CEO & Founder, Lazarus Alliance, Inc.
A2LA-accredited FedRAMP 3PAO leadership; Authorized CMMC C3PAO; PCI DSS QSA firm principal.

How to Cite
Peters, M. D. (2026). FedRAMP POA&M Benchmarks: What 12 Assessments Show. Lazarus Alliance, Inc. Data drawn from the 2026 FedRAMP Assessment Benchmark Report (N = 12).

9. About Lazarus Alliance

Lazarus Alliance is an A2LA-accredited FedRAMP Third-Party Assessment Organization (3PAO), an authorized CMMC C3PAO (CPN 10251), a PCI DSS Qualified Security Assessor (QSA), and a veteran-owned small business headquartered in Scottsdale, Arizona.

Lazarus Alliance, Inc.
27743 N. 70th Street, Suite 100, Scottsdale, AZ 85266
1-888-896-7580  •  [email protected]
https://lazarusalliance.com

© 2026 Lazarus Alliance, Inc. All rights reserved. Proactive Cybersecurity®, Cybervisor®, and IT Audit Machine® are trademarks of Lazarus Alliance or its affiliates. Figures are observational aggregates from anonymized assessments and do not guarantee individual outcomes.