Can You Win DoD Contracts with Only Conditional CMMC Status?
Can You Win DoD Contracts with Only Conditional CMMC Status?
Key Takeaways
Conditional CMMC status allows contractors to remain eligible for awards but only when specific limited conditions are met.
This status lasts for up to 180 days and requires closing out all Plan of Action and Milestones (POA&Ms) deficiencies within that period.
Relying solely on conditional certification risks contract rejection, subcontractor exclusion, and competitive disadvantages, so use it as a temporary bridge toward full compliance.
Introduction: Conditional Certification - A Temporary Lifeline, Not a Guarantee
In today's defense contracting landscape, demonstrating progress in Cybersecurity Maturity Model Certification (CMMC) compliance has become a gatekeeper for securing Department of Defense (DoD) contracts. But what happens if your company is not yet fully certified? Many small and medium-sized contractors fret that having only conditional CMMC status puts them out of the running.
Here is the bottom line: Conditional certification can keep doors open, but only briefly and under specific conditions. This article explores what conditional status means, when it applies, and how to advance beyond it, so your business remains competitive and contract-ready.
For a deeper understanding of eligibility and timelines, see our post on When Is CMMC Required for DoD Contracts? Timeline & Key Requirements Explained.
Understanding Conditional CMMC Certification
Under the latest CMMC 2.0 framework, conditional certification may be granted when an organization passes assessment but has limited POA&Ms for lower-weighted requirements, high-weighted practices must be fully implemented.
| Certification Type | Definition | Requirements |
|---|---|---|
| Certification Type: Full Certification | Definition: 100 percent of practices verified | Requirements: All practices implemented and assessed |
| Certification Type: Conditional Certification | Definition: Assessment completed with minimum 80 percent score | Requirements: POA&Ms open for permissible gaps; remediation due within 180 days |
This approach recognizes that absolute perfection at the time of assessment is often unrealistic. Rather than stall contracts, the DoD established conditional certification as a structured bridge allowing suppliers to continue engaging in contracts while finishing remediation. To exit conditional status, contractors must complete a POA&M closeout assessment confirming all gaps are resolved.
"Conditional certification is a practical acknowledgment that cybersecurity maturity is a journey, not a one-time checkbox."
Learn more about the closeout evidence required for full CMMC compliance in What Evidence is Needed for a CMMC Level 2 Assessment?.
Why Did the DoD Introduce Conditional Certification?
The Department of Defense introduced conditional certification to avoid unnecessarily sidelining capable suppliers due to minor or lingering cybersecurity gaps. The benefits include:
Preventing delays in contract awards when deficiencies are low risk
Allowing small and medium businesses (SMBs) to remain competitive during remediation phases
Maintaining supplier stability for critical programs dependent on specialized services
Think of conditional certification as a safeguard that balances security with supply chain continuity, but note that it has a strict deadline-contractors have no more than 180 days to fully remediate outstanding POA&Ms or face status expiration.
When Is Conditional Status Accepted in Contracting?
At Award: Contractors with conditional status (e.g., "Conditional Level 2)" or "Conditional Level 2 (C3PAO-Assessed)") qualify for award provided their POA&Ms contain only allowable deferments as defined by regulation, and applicable affirmations are submitted in the Supplier Performance Risk System (SPRS). This means conditional certification creates award eligibility but does not guarantee selection.
During Contract Performance: Contractors may perform work while closing out POA&Ms within the 180-day remediation window. Missing this deadline risks termination or suspension under contract remedies.
Subcontracting: Prime contractors may subcontract work to conditionally certified entities when permitted by contract and program sensitivity. However, many primes hesitate to accept conditional subs, fearing compliance risks.
For comprehensive guidance on subcontracting risk and compliance, see How CMMC Affects Defense Contracts & the Supply Chain.
Where Conditional Certification Can Help You Win Contracts
Competitive procurements with urgent timelines, where contracting officers may prioritize supplier availability and demonstrable progress.
Bridge contracts or extensions, allowing you to continue support while finalizing certification.
High priority missions requiring uninterrupted supplier participation despite minor compliance gaps.
Nonetheless, full certification remains preferred, especially for contracts handling a significant quantity of Controlled Unclassified Information (CUI), where risk tolerance is minimal.
Risks and Limitations of Relying on Conditional Certification
Source Selection Discretion: Contracting officers ultimately decide if conditional certification meets the program's needs.
Subcontracting Restrictions: Primes may exclude conditionally certified subcontractors to reduce risk exposure.
Recompete Challenges: Competing for work after expiration of conditional status may prove difficult if POA&Ms remain unaddressed.
Market Perception: Competitors might use your conditional status as a signal of incomplete compliance.
Strict Time Limits: Failure to remedy within 180 days results in loss of certification and possible contract penalties.
Contractors should weigh these issues carefully to avoid jeopardizing current or future opportunities.
Practical Steps to Move Beyond Conditional Status
Engage Contracting Officers Early: Confirm how your conditional status affects eligibility for specific contracts.
Prioritize Rapid POA&M Closure: Focus resources on remediating the most critical deficiencies promptly within the 180-day limit.
Maintain Clear Documentation: Track and update records with SPRS to evidence ongoing compliance improvement.
Collaborate With Prime Contractors: Demonstrate remediation plans to primes early when bidding for subcontracted work.
Leverage Automation Tools: Adopt continuous compliance solutions that streamline evidence gathering, monitoring, and certification workflows.
The objective is to treat conditional certification as a temporary measure while accelerating progress toward full certification.
If you want to simplify tracking and remediation management, consider signing up for the CMMC Dashboard to monitor your status in real time, avoid delays, and position your company as a trusted defense supplier.
Frequently Asked Questions
Do I need to recertify after every IT upgrade?
Routine updates and patches typically do not require reassessment. Significant environment changes, such as migrating to a new cloud infrastructure, may necessitate a fresh audit. For cloud considerations, see Microsoft 365 GCC High Migration: Enterprise Implementation and CMMC Compliance Roadmap.
Can I handle Controlled Unclassified Information (CUI) after submitting my SPRS score?
No. Submitting SPRS data shows progress but does not authorize CUI handling until you have a valid assessment-conditional or full. Learn about handling CUI in Personnel Security for CUI: Ensuring Trusted Access under CMMC.
How long is conditional certification valid?
Up to 180 days. Contractors must remediate POA&Ms closeout as evidence-based verification, not always a full reassessment.
Can subcontractors work with conditional certification?
Yes, but acceptance depends on primes and contracting officers. Many primes prefer fully certified subcontractors, especially on sensitive projects.
Conclusion: Conditional CMMC Status as a Strategic But Temporary Bridge
Conditional certification provides a valuable short-term lifeline to continue competing for DoD contracts while remedying cybersecurity gaps. Yet, it is not a substitute for full compliance. The window to close your deficiencies is narrow, and failure to do so may result in loss of certification and contract penalties.
To protect your competitiveness, approach conditional status as a countdown clock: communicate proactively, accelerate remediation efforts, document progress transparently, and leverage compliance automation to expedite your journey to full certification.
If you want to simplify tracking and remediation management, sign up now for the CMMC Dashboard, your tool for staying contract-ready and fully compliant.
Sources and further reading: Defense Contract Management Agency (DCMA) CMMC guidelines, DoD CMMC 2.0 official documentation, Supplier Performance Risk System (SPRS) user guides.