CA.L2-3.12.2  

Reference: CMMC v2.13

Family: CA

Level Introduced: 2

Title: Operational Plan of Action

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

Further Discussion:
When you write a plan of action, define the clear goal or objective of the plan. You may include the following in the action plan:
• ownership of who is accountable for ensuring the plan’s performance;
• specific steps or milestones that are clear and actionable;
• assigned responsibility for each step or milestone;
• milestones to measure plan progress; and
• completion dates.

This requirement, CA.L2-3.12.2, which ensures developing and implementing operational plans of action to correct and reduce vulnerabilities in systems, is driven by risk management requirement RA.L2-3.11.1, which promotes periodically assessing risk to organizational systems. CA.L2-3.12.2 promotes monitoring security controls on an ongoing basis as defined in requirement CA.L2-3.12.3.

An operational plan of action in accordance with CA.L2-3.12.2 differs from a CMMC assessment POA&M as described in 32 CFR § 170.21. The assessment POA&M places conditions on which security requirements can be assessed as NOT MET and allows the OSA to qualify for a CMMC Status of Conditional Level 2 (Self), Conditional Level 2 (C3PAO), or Conditional Level 3 (DIBCAC). Operational plans of action are not subject to the 180 day POA&M closeout requirement. Severity, availability of remediation, and business requirements are among the factors to consider when creating and maintaining operational plans of action.

Example
As IT director, one of your duties is to develop action plans when you discover that your company is not meeting security requirements or when a security issue arises [b]. A recent vulnerability scan identified several items that need to be addressed so you develop a plan to fix them [b]. Your plan identifies the people responsible for fixing the issues, how to do it, and when the remediation will be completed [b]. You also define how to verify that the person responsible has fixed the vulnerability [b]. You document this in an operational plan of action that is updated as milestones are reached [b]. You have a separate resource review the modifications after they have been completed to ensure the plan has been implemented correctly [c].

Potential Assessment Considerations
• Is there an action plan to remediate identified weaknesses or deficiencies [a]?
• Is the action plan maintained as remediation is performed [b]?
• Does the action plan designate remediation dates and milestones for each item [c]?

Source: CMMC v2.13