POA&Ms Under CMMC: What You Can (and Can’t) Defer
A Plan of Action and Milestones (POA&M) lets you document how you will close a gap you have not yet closed. Under CMMC, the room to rely on a POA&M is deliberately narrow — knowing the rules keeps you out of trouble.
What you can defer
CMMC allows conditional certification with a POA&M only for a limited set of requirements, and only if you meet a minimum score. The highest-weighted requirements generally cannot be on a POA&M — they must be met at assessment time.
The 180-day clock
When you receive conditional status, you have 180 days to close every POA&M item and pass a closeout assessment. Miss the window and the conditional certification does not convert to a final one.
How to use POA&Ms well
- Treat them as a short bridge, not a parking lot.
- Write realistic milestones with named owners and dates.
- Never plan to POA&M a control you could simply implement before the assessment.
The safest assessment is one with an empty POA&M. Aim for that and keep the mechanism in reserve for genuine, closeable gaps.
The Verdict Forum publishes educational guidance, not legal or compliance advice. Confirm requirements against the authoritative sources and your assessor before acting.
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