A Plan of Action and Milestones (POA&M) is a formal document used within the CMMC ecosystem to track security deficiencies identified during a formal assessment. It serves as a regulatory roadmap, outlining the specific tasks, resources, and timelines an organization will use to remediate non-compliant controls.
Under the CMMC Final Rule, the POA&M is the primary mechanism that allows an organization to achieve Conditional CMMC Status. This status is critical for defense contractors who have minor gaps but otherwise meet the threshold for eligibility to handle Controlled Unclassified Information (CUI).
The Mechanics of Conditional CMMC Status
For CMMC Level 2, an organization may only be granted a conditional status if it meets strict scoring and implementation criteria during its initial assessment:
- Minimum SPRS Score: The organization must achieve a minimum score of 88 out of 110 (representing approximately 80% compliance).
- Permitted Controls: Only specific controls are eligible for a POA&M. Under 32 CFR § 170.21, “critical” controls—typically those with a 5-point value in the Supplier Performance Risk System (SPRS)—cannot be placed on a POA&M and must be fully implemented at the time of the assessment.
- Level 1 Exclusion: It is important to note that CMMC Level 1 does not allow the use of a POA&M; all 15 basic safeguarding requirements must be met for a final status to be granted.
If these criteria are met, the Affirming Official (the senior company representative responsible for compliance) submits the assessment results and the POA&M into SPRS to secure a Conditional Level 2 Status.
Speak to a Compliance Specialist.
The 180-Day Rule: The Closeout Timeline
The CMMC program enforces a rigid 180-day window for all POA&M remediation. This countdown begins the moment the initial assessment results are finalized and the conditional status is recorded.
Requirements for Successful Closeout
To transition from a Conditional to a Final CMMC Status, an organization must successfully complete a POA&M Closeout Assessment. This is a targeted review focused solely on the “Not Met” requirements identified in the initial assessment.
- Evidence of Remediation: The organization must provide objective evidence (logs, configurations, or updated policies) that the gaps have been closed.
- Verification: For a Level 2 Certification Assessment, an authorized C3PAO must perform the closeout assessment to verify the remediated controls.
- SPRS Update: Once verified, the results are updated in SPRS. Failure to close all POA&M items within the 180-day period results in the expiration of the conditional status, potentially rendering the organization ineligible for contract awards or option periods.
Best Practices for a POA&M Closeout Strategy
A successful path to final certification depends on how effectively an organization manages its remediation window. Because the 180-day deadline is rigid, the following strategic steps are recommended to ensure a successful closeout.
1. Prioritization and Timeline Management
The 180-day deadline for POA&M closeout is a fixed requirement. To meet this window, it is a best practice to treat the POA&M as an active, high-priority project plan rather than a static document. Success involves prioritizing items based on their technical complexity, the resources required for implementation, and the risk weight of the specific NIST SP 800-171 controls.
2. Technical Remediation Planning
Effective remediation requires moving beyond “quick fixes” to deep, sustainable implementations. IT teams should focus on obtaining detailed guidance on configuration changes and solution deployments. The goal is to ensure that every technical control is not only functioning but is also fully aligned with the specific assessment objectives required for CMMC.
3. Final Verification and Pre-Closeout Review
Before the official POA&M Closeout Assessment is scheduled with a C3PAO, organizations should perform a rigorous internal or third-party review of all remediated controls. This pre-closeout check serves two main purposes:
- Evidence Review: Verifying that all required documentation—such as access logs, system reports, and configuration screenshots—is compiled and formatted according to the standards of an official assessor.
- Documentation Integrity: Ensuring the System Security Plan (SSP) and all related policies have been updated to reflect the new, compliant state of the environment.
Core Requirements for Successful POA&M Remediation
Addressing outstanding compliance gaps requires a comprehensive approach that bridges the gap between technical settings and formal policy. Key focus areas include:
- Technical Implementation: Correctly configuring security tools, refining access controls, and establishing the robust logging necessary to satisfy specific NIST practices.
- Policy and Procedure Refinement: Updating or drafting the formal documentation needed to prove that a control is not only technically present but is established, documented, and consistently enforced across the organization.
- Documentation Lifecycle Management: Maintaining the SSP and POA&M as living documents. Every change in the technical environment must be mirrored in the evidence provided to the assessor.
- Technical Communication Management: Establishing clear communication between IT teams and compliance officers to interpret complex remediation requirements. This ensures a smooth, transparent exchange of information with the C3PAO during the final closeout phase.
Secure Your CMMC Status with Proper Preparation
The POA&M is a limited opportunity to resolve deficiencies without losing contract eligibility. Given the strict 180-day timeline and the high stakes of the annual affirmation by the Affirming Official, many organizations choose to work with a Candidate C3PAO like Auditwerx to properly prepare their compliance efforts.
Auditwerx serves as a dedicated partner in this process, providing conflict-free CMMC Readiness to help organizations navigate the path to a successful final certification.
Do you have questions about managing your 180-day remediation window? Contact Auditwerx today to discuss how our readiness and mock assessment services can support your CMMC compliance goals.
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