Department of Defense (DoD) contractors have been exploring and discussing the evolution from the original CMMC framework to ensure continued CMMC compliance since the finalization of the CMMC 2.0 standards in late December 2023. A key component of this transition is the introduction of Plans of Actions & Milestones (POAM), which simplifies meeting CMMC level 2 requirements for many businesses.
Understanding CMMC 2.0
CMMC 2.0 introduces a more streamlined and flexible approach to compliance. Unlike the previous all-or-nothing certification process, the new standards allow for time-limited POAMs. This adjustment enables businesses to address specific controls over an extended period, making it possible to allocate resources more effectively without compromising security.
What is a POAM?
Plans of Actions and Milestones (POAMs) serve as corrective action plans for areas not fully compliant with specified controls. Now permissible under certain conditions, POAMs provide a pathway to full CMMC compliance without requiring a perfect initial assessment.
Navigating POAM Requirements
However, there are limitations. No POAMs are allowed for the foundational 17 CMMC Level 1 Controls, which are essential for maintaining basic cybersecurity hygiene within the DoD supply chain. These controls must be fully implemented to achieve any level of CMMC certification. While most controls with a point value of “1” can have a POAM, there are still exceptions, including:
AC.L1-3.1.20 – External Connections
AC.L1-3.1.22 – Control Public Information
PE.L1-3.10.3 – Escort Visitors
PE.L1-3.10.4 – Physical Access Logs
PE.L1-3.10.5 – Manage Physical Access
Preparing for CMMC Level 2
For organizations aiming for CMMC level 2, these changes are particularly relevant. Under the new guidelines, conditional certifications can be granted if a business implements at least 80% of the critical NIST SP 800-171 rev2 controls. Moreover, to maintain this conditional status, all POAMs items must be resolved within 180 days—a manageable timeframe for most businesses.
Why This Matters for Your Business
The clarification of POAMs requirements for achieving CMMC 2.0 framework released in December 2023 underscores the framework’s role as a more business-friendly approach, acknowledging the challenges organizations face in achieving complete CMMC compliance. By allowing certain deficiencies to be temporarily accepted and later corrected, the new CMMC 2.0 POAMs requirements help contractors progressively enhance their cybersecurity practices.
Navigating the complexities of CMMC compliance, including understanding the nuances of POAMs and preparing for CMMC level 2, is crucial for maintaining and expanding your government contracts. Expert guidance can make this process significantly smoother and more effective.
We Can Help You With CMMC Compliance
At Alluvionic, we offer comprehensive support services for Cybersecurity gap analysis, DFARS Compliance Assistance, and CMMC Certification readiness support. Partnering with us ensures that your business not only meets the new standards but also thrives under them. Our expertise will help you achieve and maintain compliance efficiently, positioning your company for continued success in the defense sector.
For expert assistance in achieving CMMC compliance and leveraging POAMs for your business’s growth, contact Alluvionic today. Let us help you secure your future and unlock your company’s full potential.
