Key Takeaways
- Contractors failing a CMMC assessment may receive Conditional CMMC Status if at least 80% of controls are met, requiring a Plan of Action and Milestones (POA&M) for full compliance.
- All POA&M deficiencies must be resolved within 180 days, followed by a closeout assessment to obtain Final CMMC Certification.
- Failure to close out POA&M deficiencies within the deadline results in certification expiration, contract ineligibility, and possible termination.
What Happens If a Contractor Fails an Assessment?
When a contractor undergoes a CMMC assessment (learn more about the formal assessment process) but does not fully meet the required cybersecurity controls for their designated level, several steps follow.
1. Assessment Results & Reporting
- Assessment results are documented and reported in the Supplier Performance Risk System (SPRS) or the CMMC Enterprise Mission Assurance Support Service (eMASS).
- If deficiencies exist, the contractor will not receive unconditional certification but may qualify for Conditional CMMC Status (if applicable).
2. Conditional CMMC Status (For Level 2 & Level 3 Assessments)
- Contractors meeting at least 80% of the required security controls but lacking some implementations can be granted Conditional CMMC Status.
- A Plan of Action and Milestones (POA&M) must be created to address deficiencies.
- All deficiencies must be corrected within 180 days to achieve Final CMMC Status.
3. POA&M Closeout Assessment
- After implementing corrective actions, the contractor undergoes a POA&M closeout assessment.
- If all requirements are met, they receive Final CMMC Certification for their required level.
- If deficiencies remain after 180 days, the Conditional CMMC Status expires, and standard contractual remedies apply, potentially resulting in loss of contract eligibility.
4. Failure to Meet Compliance Within 180 Days
- If a contractor fails to close out POA&M deficiencies within 180 days, their CMMC certification is revoked.
- The contractor becomes ineligible for contract awards and may face termination if they fail to meet DFARS cybersecurity requirements.
- DoD may take standard contractual remedies, such as non-renewal or enforcement actions.
Plan of Action and Milestones (POA&M)
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What is a POA&M?
A Plan of Action and Milestones (POA&M) is a structured plan outlining:
- Unmet security requirements from the CMMC assessment.
- Mitigation strategies for each deficiency.
- Milestones and deadlines to close security gaps.
- Resources needed to achieve compliance.
Learn more about POA&M details here.
When is a POA&M Required?
- If an organization fails to meet all CMMC security controls but still meets at least 80%.
- Only certain requirements can be placed on a POA&M; some critical security controls must be met upfront.
Key POA&M Requirements
1. Must be Closed Within 180 Days
- Contractors must remediate all POA&M items within 180 days of receiving Conditional CMMC Status.
- Failure results in loss of Conditional CMMC Status.
2. Second Assessment for Verification
- A POA&M closeout assessment must be conducted to validate the implementation of pending security requirements.
3. Tracking & Reporting
- POA&M progress is tracked and reported in SPRS/eMASS.
4. Conditional Status Expiration Consequences
- If the POA&M closeout assessment fails, contractual penalties may apply, including contract ineligibility.
The broader impact on defense contracts and supply chain.
Summary of Non-Compliance Handling
| Scenario | Outcome |
|---|---|
| Contractor passes the assessment | Receives Final CMMC Status |
| Contractor meets 80% but has deficiencies | Receives Conditional CMMC Status with POA&M |
| Contractor fails to close out POA&M items in 180 days | Achieves Final CMMC Certification |
| Contractor passes POA&M closeout assessment | Level 1 (Self) for FCI, Level 2 (C3PAO) for CUI |
| Contractor completely fails the assessment | Not eligible for contract award |
This process ensures contractors have a structured path to compliance while enforcing strict cybersecurity requirements to protect Controlled Unclassified Information (CUI).
Don’t let one failed assessment derail your contracts.
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