Not required for FISMA Moderate.
The organization:
The plan of action and milestones is a key document in the information security program and is subject to federal reporting requirements established by OMB. With the increasing emphasis on organization-wide risk management across all three tiers in the risk management hierarchy (i.e., organization, mission/business process, and information system), organizations view plans of action and milestones from an organizational perspective, prioritizing risk response actions and ensuring consistency with the goals and objectives of the organization. Plan of action and milestones updates are based on findings from security control assessments and continuous monitoring activities. OMB FISMA reporting guidance contains instructions regarding organizational plans of action and milestones.