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CMMC POA&M Rules and Conditional Status Explained

By Shaheer Malik · Updated Oct 28, 2026

A Plan of Action and Milestones (POA&M) lets you pass a CMMC Level 2 or Level 3 assessment with a Conditional status while a few requirements are still open, but only if you score at least 80 percent and the open items are eligible. You then have 180 days from the CMMC Status Date to close them out, or the Conditional status expires. Level 1 allows no POA&M.[1]

The Level 2 conditions

So without a System Security Plan you cannot pass at all: it is one of the requirements that can never be deferred.

The Level 3 conditions

At least 80 percent, and the POA&M may not include the security operations center, the incident response team, threat-informed risk assessment, the supply chain risk response and plan, the security solution rationale, or specialized asset security.[1]

The 180-day closeout

A POA&M closeout assessment checks only the items left open, within 180 days of the Conditional status date. You do it yourself for Level 2 (Self); a C3PAO does it for Level 2 (C3PAO); DCMA DIBCAC for Level 3.[1] An affirmation follows.[1]

What is the CMMC Status Date?

The date the results are submitted to SPRS or the CMMC eMASS. After a successful closeout, the Conditional status date remains the status date: “A new date is not set for a Final that follows a Conditional.”[1] Your three years run from it.

Is a POA&M allowed in the contract?

Yes: contracting officers may award with a Conditional Level 2 or Level 3, for up to 180 days from the status date; Level 1 needs a Final status.[2] Federal News Network reports the reform task force suggested extending POA&M time to 270 days, which would require rulemaking.[3]

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FAQ

How long is a CMMC Conditional status valid?

Up to 180 days from the Conditional CMMC Status Date. If the POA&M is not closed out within that time, the Conditional status expires.

Can the SSP be on a CMMC POA&M?

No. CA.L2-3.12.4 System Security Plan is one of six Level 2 requirements that can never be included on a POA&M.

Is a POA&M allowed for CMMC Level 1?

No. Level 1 requires every requirement to be MET; a POA&M is never permitted.

What score do I need for a Conditional CMMC status?

At least 80 percent of the maximum score (88 of 110 at Level 2), with only eligible 1-point items (or non-FIPS encryption) on the POA&M.

Sources

  1. 32 CFR part 170, CMMC Program (eCFR, current text) (checked Oct 28, 2026)
  2. Class Deviation 2026-O0025, Revision 3, Attachment 1: revised DFARS part 240 (Sep 3, 2026) (checked Oct 28, 2026)
  3. Federal News Network: RFI offers path forward for DoD with CMMC (Jason Miller, Oct 27, 2026) (checked Oct 28, 2026)

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