Mastering POA&Ms for CMMC 2.0 Compliance

Are You Ready With POA&Ms?

CMMC compliance is mandatory for contractors, and effective use of POA&Ms can support progress toward meeting required cybersecurity standards.
The new standards allow for time-limited POA&Ms
Plans of Actions and Milestones (POA&Ms) serve as corrective action plans for areas not fully compliant with specified controls.
Every POA&M must be clear, trackable, and accountable.
In the CMMC 2.0 world, POA&Ms are highly regulated, strategically limited, and deeply integrated into the Defense Department’s contracting process.
The 180-day timer starts immediately after your conditional assessment, and you’ll need to show full implementation by the closeout.
At Alluvionic, we offer comprehensive support services for Cybersecurity gap analysis, DFARS Compliance Assistance, and CMMC Certification readiness support.

Understanding CMMC 2.0

Unlike the previous all-or-nothing certification process, the new standards allow for time-limited POA&Ms. This adjustment enables businesses to address specific controls over an extended period, making it possible to allocate resources more effectively without compromising security.

Why Does the DoD Allow POA&Ms Now?

This marks a significant shift from the original CMMC 1.0 framework, which required all practices to be implemented before a company could be certified. That “all-or-nothing” approach proved to be too rigid—especially for small and mid-sized businesses.

By allowing some flexibility, CMMC 2.0 recognizes the real-world complexity of implementing security controls. The 180-day remediation window allows you to:

Prioritize high-risk issues first
Avoid losing contract eligibility while remediating lower-risk issues
Align your remediation strategy with your resource availability

But again—this flexibility comes with a clock and strict rules.

What is a POA&M?

Plans of Actions and Milestones (POA&Ms) serve as corrective action plans for areas not fully compliant with specified controls. Now permissible under certain conditions, POA&Ms provide a pathway to full CMMC compliance without requiring a perfect initial assessment.

Anatomy of a POA&M Under CMMC

Every POA&M must be clear, trackable, and accountable. Here’s what each plan should include:

Every POA&M item will be re-evaluated during a POA&M validation, which can be conducted by either the Organization Seeking Assessment (OSA) or a third-party C3PAO depending on the type of assessment.

Let’s say your organization has not implemented proper audit log retention procedures (AU.L2-3.3.9). This is a one-point requirement under NIST SP 800-171 rev 2 and is eligible for POA&M.

Your POA&M might include:

- Root Cause: Log retention was set to 14 days instead of 90 days due to lack of centralized log storage.
- Action Plan: Procure and implement a Security Information and Event Management (SIEM) system with log retention capabilities.
- Milestones:
  - Research vendors (Week 1–2)
  - Purchase and deploy solution (Week 3–6)
  - Train IT staff (Week 7)
  - Verify retention settings and log integrity (Week 8)
- Responsible Party: Director of IT Security
- Completion Date: 60 days post-assessment

POA&Ms: More Than a Temporary Fix

In traditional cybersecurity frameworks, Plans of Action and Milestones (POA&Ms) are often seen as a project management tool for IT teams. But in the CMMC 2.0 world, POA&Ms are highly regulated, strategically limited, and deeply integrated into the Defense Department’s contracting process.

This isn’t just an internal checklist. Rather, it’s a compliance mechanism that is tracked, enforced, and verified by third-party assessors (C3PAOs) and the DoD.

When Are POA&Ms Allowed?

There are limitations to when and which POA&Ms are allowed. No POA&Ms 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. For CMMC level 2, while most controls with a point value of “1” can have a POA&M, 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 POA&Ms items must be resolved within 180 days, a manageable timeframe for most businesses.

Why 180 Days Isn’t as Long as It Sounds

It’s easy to assume you’ve got half a year, but many organizations underestimate how long procurement, implementation, testing, and documentation can take. The 180-day timer starts immediately after your conditional assessment, and you’ll need to show full implementation by the closeout.

Common delays that eat into that window:

Procurement delays for security software/hardware
Internal resistance or change management challenges
Incomplete documentation or policies
Configuration errors that require rework

This is why project management discipline provided by a Registered Practitioner Organization (RPO) like Alluvionic, is critical.

POA&M Closeout Assessment: The Final Checkpoint

Once your organization has completed the remediation activities, you’ll need to verify them in a closeout assessment. If your initial assessment was:

A Level 2 self-assessment, you can self-attest your POA&M closure.
A Level 2 certification assessment, a C3PAO must validate the fixes.

No matter the type, the closeout must demonstrate:

Full implementation of the previously unmet requirement
Evidence that meets NIST SP 800-171A assessment objectives
Timely completion within the 180-day window

If your POA&Ms are not closed out within the deadline, your CMMC status will expire, and you could be deemed non-compliant making your organization ineligible for new DoD contracts.

Why This Matters for Your Business

POA&M requirements for achieving CMMC 2.0 certification underscore 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 POA&Ms requirements help contractors progressively enhance their cybersecurity practices.

Navigating the complexities of CMMC compliance, including understanding the nuances of POA&Ms 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 POA&Ms for your business’s growth, contact Alluvionic today.

Why CMMC Compliance Matters Now More Than Ever

With the CMMC Final Rule officially published, compliance is no longer optional. Soon, CMMC Level 1 or Level 2 certification will be a requirement for winning DoD contracts. Failing to meet these standards could mean losing valuable business opportunities.

Key CMMC Compliance Takeaways

CMMC Level 1 (for handling FCI) requires 15 basic safeguarding practices.
CMMC Level 2 (for handling CUI) requires 110 security controls from NIST SP 800-171.
Self-assessments are required annually, and third-party assessments (C3PAO) are required for Level 2 certification.
Non-compliance could result in contract loss or legal penalties.

Get CMMC-Ready with Alluvionic Today

CMMC compliance can be overwhelming, but you don’t have to do it alone. At Alluvionic, we cut through the complexity, eliminate uncertainty, and make compliance achievable for small and mid-sized government contractors.

Take Action Now

Schedule a Consultation: Talk to a CMMC expert about your compliance needs.
Get a Gap Analysis: Identify vulnerabilities before they become problems.
Start Your Compliance Journey: Let us handle the heavy lifting so you can focus on growing your business.

Don’t wait until the deadline—secure your contracts by ensuring CMMC compliance today.

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