POAM Requirements for CMMC Compliance
Last reviewed · By Chad Griffith
A Plan of Action & Milestones (POAM) is the formal document tracking controls that are not yet fully implemented in a CMMC environment. Under CMMC 2.0, contractors with most controls implemented but with some controls in POAM status can achieve Conditional CMMC Status — valid for 180 days. POAM items must be completed within 180 days to convert to Final CMMC Status. Failure to complete POAM items results in loss of certification and contract eligibility.
Required POAM Content
A POAM entry must include: control identifier (e.g., AC.L2-3.1.5); weakness description describing why the control is not yet fully implemented; planned milestones with specific actions; milestone target dates; responsible party with name and role; resources required (budget, headcount, technology); scheduled completion date; status (open, in progress, completed, deferred); and completion evidence when complete.
Which Controls Can Be POAMed
Not all controls can be POAMed under CMMC 2.0. The DoD designated certain 'POAM-eligible' controls — generally those with lower priority weights. Higher-priority controls (typically those weighted at 5 points in NIST 800-171 scoring) often cannot be POAMed and must be fully implemented before any conditional certification. The full POAM-eligibility list is published in CMMC Assessment Guide documents.
The 180-Day Rule
Under CMMC 2.0, contractors achieving Conditional CMMC Status with POAMs must complete all POAM items within 180 days. After 180 days: completed POAM items convert to Final CMMC Status; incomplete items result in loss of certification. There is no extension. Contractors that miss the 180-day deadline must restart the certification process — a multi-month, costly disruption to contract eligibility.
POAM Management Best Practices
Frequent best practices: assign every POAM item to a single named owner (not a team); document specific evidence requirements for closure (so close-out is unambiguous); review POAM weekly during the 180-day Conditional period; track resource allocation against milestones; maintain version history of POAM updates; close items only with documented evidence; avoid 'rolling' POAMs where the same item appears across multiple cycles.
Frequently Asked Questions
How long do I have to complete POAM items?
Under CMMC 2.0, contractors with Conditional CMMC Status must complete all POAM items within 180 days from certification date. Failure to complete results in loss of certification and contract eligibility. There are no extensions — contractors that miss the deadline must restart certification.
Can any control be POAMed?
No. The DoD designated specific 'POAM-eligible' controls under CMMC 2.0. Higher-priority controls (typically those scored at 5 points in NIST 800-171 scoring) generally cannot be POAMed and must be fully implemented before any certification. The full eligibility list is published in CMMC Assessment Guide documents on Cyber AB's website.
What's the difference between POAM and risk acceptance?
A POAM is a documented plan to remediate a control weakness within a defined timeframe. Risk acceptance is a formal decision by the system owner that a risk will not be remediated and is accepted as-is. CMMC requires implementation of all 110 controls — risk acceptance generally is not an alternative to POAM. Documented compensating controls may substitute for direct implementation in limited cases.
Does DFARS require POAMs separately from CMMC?
Yes. DFARS 252.204-7012 requires contractors to maintain a System Security Plan and POAM independent of CMMC certification, applying to the broader population of contractors handling CUI. CMMC formalizes the SSP/POAM requirement and adds verification through assessment.
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