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CMMC POA&M Rules: 180-Day Conditional Closeout

CMMC POA&M is not allowed for Level 1.

Published: September 2026 Compliance · CMMC 8–12 min read

Plans of Action and Milestones (POA&M) are how organizations track remediation of NOT MET requirements. Under CMMC programme rules, POA&M is not allowed for Level 1. For Level 2 and Level 3, Conditional status can permit limited open items — with a hard 180-day closeout clock from the Conditional CMMC Status Date.

Related: CMMC hub · Level 2 · SPRS · SSP.

Conditional is not infinite: Level 2 Conditional needs minimum score 88 of 110 (80%) plus critical requirements MET per §170.21 — then finish POA&Ms within 180 days.

POA&M by Level

Level
POA&M allowed?
Notes
Level 1
No
All 15 FAR requirements must be MET
Level 2
Yes for Conditional status
≥88/110 + criticals MET; 180-day closeout
Level 3
Yes for Conditional status (programme rules)
180-day closeout from Conditional status date

Operating a Defensible POA&M

How CyberSilo Helps

Treat 180 Days as a Hard Gate

Track Conditional POA&Ms with owners and evidence so status does not expire into NOT MET.

Frequently Asked Questions

Can Level 1 use POA&Ms?

No. POA&M is not allowed for Level 1.

How long do I have to close Conditional POA&Ms?

Within 180 days of the Conditional CMMC Status Date.

What is the Conditional Level 2 score floor?

88 of 110 (80% of maximum) plus critical requirements MET per §170.21.

CMMC hub · Level 1 · Assessment process · Checklist · CSA

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