The Defense Compliance ReportCMMC 2.0 & the Defense Industrial Base

CMMC POA&M Software: What to Use, What to Verify, and What It Can’t Fix

CMMC POA&M softwareis any tool that tracks the security gaps you have to close before — or just after — a CMMC assessment: the open item, the requirement it maps to, the owner, the evidence, the due date, and the closeout. Here’s the part the product demos skip. The right tool won’t make you compliant, and under federal rule it cannot defer your most important gaps at all. For most Level 2 contractors, the best CMMC POA&M software is the one that stops you from putting an ineligible gap on a POA&M in the first place.

A few definitions up front. CMMC (Cybersecurity Maturity Model Certification) is the DoD program that ties cybersecurity to contract eligibility. A POA&M(Plan of Action and Milestones) is the documented plan to fix requirements scored “Not Met.” CUI is Controlled Unclassified Information; FCI is Federal Contract Information. An SSP is your System Security Plan. SPRSis the Supplier Performance Risk System — the DoD database where your score and assessment affirmations are posted.

Bottom line, by situation. Pick the row that sounds like you. The rest of this page explains the “why.”

Your situationYour best first moveWhy
FCI only / pursuing Level 1Don't buy POA&M software for a Level 1 closeoutLevel 1 allows no POA&M, ever, and no conditional status (32 CFR 170.21)
Pursuing Level 2 self-assessmentA CMMC-aware tracker or GRC tool that handles SPRS score, SSP links, POA&M eligibility, and affirmationsYou need defensible, current, self-assessment records — not just a task list
Pursuing Level 2 C3PAO assessmentCMMC-specific GRC plus a readiness partnerYour closeout must be assessor-ready and exportable
Unsure what touches CUIScope first, software secondA wrong assessment boundary makes the tool irrelevant
Planning to store CUI/evidence in the toolVerify the tool's security boundary before you upload anythingThe tool itself can become part of your assessment scope
Many owners, many open itemsA GRC/workflow platformSpreadsheet drift becomes the risk
A few clearly eligible loose endsA disciplined spreadsheet may be enoughDon't overbuy before scope is stable

Not sure which row is yours? That’s the most common place to start — and the cheapest mistake to avoid is buying the wrong category. For a refresher on how levels differ, see our CMMC levels and requirements overview.

Tell us your level, scope, score, and timeline and we’ll point you to the source-checked provider category that fits — software, readiness, enclave, or assessment.

Find My CMMC Software Path →

By The Defense Compliance Report Editorial Team · Last verified:
The Defense Compliance Report is an independent trade publication on CMMC 2.0 and DIB compliance. See our Editorial Standards.

What we verified for this guide

We read 32 CFR Part 170 — specifically §170.21 (POA&M rules), §170.22 (affirmations), §170.16 and §170.17 (Level 2 assessment paths), §170.19 (scoping), and §170.24 (scoring) — directly on the eCFR (current as of June 4, 2026). We cross-checked the DFARS cloud and “current status” requirements on Acquisition.gov, confirmed the Phase 1 start date against the DoD CIO CMMC page, and checked the NIST publication status for SP 800-171. Every vendor feature claim in the reference table is company-stated unless otherwise noted. We did not test, rank, or certify any product.


What CMMC POA&M software actually is — and the five categories you’re choosing between

CMMC POA&M software turns “Not Met” security gaps into accountable, dated, evidence-backed remediation tasks tied to your System Security Plan and the specific NIST SP 800-171 Revision 2 requirements being assessed.There is no single product literally called “POA&M software” — POA&M tracking is one feature inside a broader compliance or GRC tool.

You are not shopping for a “POA&M app.” You’re choosing a system to manage assessment risk. The POA&M is just the most visible artifact of that work. A good tool connects each gap to the requirement, the SSP narrative, the owner, the evidence, and the closeout — so at assessment time you can show not just that work was assigned, but that the requirement is now met.

Realistically, you’re choosing among five categories:

  1. Spreadsheet or lightweight tracker. Free or cheap. Fine for a few clearly eligible internal items and a disciplined team.
  2. CMMC-specific GRC / compliance platform. Built around NIST SP 800-171, CMMC scoring, SSP/POA&M workflows, and SPRS-ready outputs.
  3. Broad GRC platform with a CMMC module. Powerful and configurable, but the CMMC logic is partly on you to build correctly.
  4. CUI enclave plus a workflow/evidence layer. For contractors who isolate CUI in a hardened environment (e.g., Microsoft 365 GCC High or a GovCloud enclave) and need evidence management on top.
  5. Managed readiness / MSP- or MSSP-led compliance. A provider operates the program and the tooling for you.

A serious POA&M record carries more than a checkbox. At minimum, each item should capture the fields below — and a tool that can’t hold these is a tool that will fail you at closeout.

FieldWhy it matters
Requirement ID (e.g., AC.L2-3.1.20)Ties the gap to the NIST/CMMC requirement
Assessment objectivePrevents vague, un-assessable remediation
Deficiency descriptionDocuments what actually failed
Remediation actionShows the real fix, not the intent
OwnerCreates accountability
Resources neededSupports execution
Milestones + target dateRequired to track progress against the clock
Evidence linkProves the fix to an assessor
Related SSP sectionKeeps documentation consistent
POA&M eligibility (yes/no + reason)Prevents an invalid or illegal deferral
Score impact (1, 3, or 5 points)Shows the SPRS cost of leaving it open
Closeout status + reviewer typeTracks the final conversion to “Met”
The “nice-to-haves” that separate a real CMMC tool from a glorified ticket queue: a live SPRS score calculator, a prohibited-control validator, a 180-day countdown tied to your status date, role-based access, immutable evidence snapshots, multi-CAGE support, and annual-affirmation reminders. We turn this list into a 20-question vendor scorecard below.

The honest part: what CMMC POA&M software will never do for you

CMMC POA&M software organizes remediation work, but it does not perform it, and it cannot make an ineligible gap eligible. Under 32 CFR 170.21, six Level 2 requirements — including your System Security Plan — can never be placed on a POA&M, and except for one narrow encryption exception, no requirement worth more than one point can be deferred. No platform changes that.

Here’s our one piece of bad news: if your SSP is missing, your score is too low, your open item is a prohibited requirement, or your CUI scope is wrong, software just helps you organize the problem faster.Buying a tool to “get compliant” is one of the most expensive ways to still fail an assessment.

A well-chosen platform does four things a spreadsheet quietly stops doing the moment your program gets complicated: it keeps the 180-day closeout clock honest, it links every gap to your SSP so your documentation doesn’t go stale, it calculates your SPRS score as you remediate, and it produces an assessor-ready export so your closeout isn’t a last-minute scramble.

So the real question isn’t “which tool has the most features.” It’s “do I need a tool, or do I need someone to do the work?” If your gap list is long, your score is well under threshold, or you’re not yet sure what system is even being assessed, what you need first is readiness— implementation help — not a tracker.

Software organizes remediation; a readiness provider performs it. If you need the work done, not just tracked:

Compare readiness provider options →

Can CMMC POA&M software get you Conditional CMMC Status? The §170.21 rules

Software can help you track eligible POA&M items and assemble closeout evidence, but Conditional CMMC Status is governed by 32 CFR §170.21, not by any tool. This is the section every “best CMMC software” article skips — and it’s the one that decides whether your POA&M actually helps you.

Under 32 CFR §170.21, a Level 2 POA&M is allowed for Conditional status only if all three of these are true:

1. SPRS score of 88 or higher

Your assessment score divided by 110 must be at least 0.8 — a minimum of 88 of 110 points. Important nuance most pages get wrong: that score is weighted, not a count of controls. The DoD methodology in 32 CFR §170.24 starts you at 110 and subtracts 1, 3, or 5 pointsfor each unmet requirement. So “88” is not “88 of 110 controls met” — it means your total point deductions can’t exceed 22.

2. No requirement worth more than one point on the POA&M

With one carve-out: SC.L2-3.13.11 (CUI Encryption)may sit on a POA&M if you’re using encryption that simply isn’t FIPS-validated yet (a 3-point item). That’s the only exception in the rule. In plain terms, your high-impact 3-point and 5-point gaps are off the table. You have to actually fix them before the assessment.

3. None of the six excluded requirements are on the POA&M

These must be fully met before Conditional status — see the table below.

Put those together and the practical reality lands hard: because most high-value requirements are 3- or 5-point items, and most of those can’t be deferred anyway, you can essentially only POA&M your one-point gaps— and only if your score still clears 88. A tool that lets you drag any requirement onto a POA&M without checking this is actively dangerous.

The 180-day clock — and who closes it out

A POA&M closeout assessment evaluates only the requirements that were marked “Not Met” with a POA&M in the initial assessment, and it must confirm closure within 180 days of your Conditional CMMC Status Date. If it isn’t closed in time, the Conditional status for that information system expires.

Assessment pathWho performs the closeoutWhere results post
Conditional Level 2 (Self)You (the OSA — Organization Seeking Assessment) re-run the self-assessmentSPRS
Conditional Level 2 (C3PAO)An authorized or accredited C3PAO (Certified Third-Party Assessment Organization)The CMMC instance of eMASS, then SPRS
Conditional Level 3 (DIBCAC)DCMA DIBCAC (the Defense Industrial Base Cybersecurity Assessment Center)eMASS / SPRS

Reaching Final Level 2 status means meeting all 110 requirements— a clean score of 110. Conditional gets you in the door with eligible gaps deferred; Final is what you owe by the end of the 180 days.

Level 1 is simpler and stricter: a POA&M is not permitted at any time, and only Final status exists — there is no conditional path (32 CFR §170.21). Level 3has its own threshold (score ratio of at least 0.8), bans seven specific enhanced requirements from the POA&M, and requires you to already hold Final Level 2 (C3PAO) first. Level 3 is assessed by DIBCAC against 24 requirements drawn from NIST SP 800-172. See our guide to CMMC Level 2 self-assessment vs C3PAO.

Take your list of “Not Met” requirements and your SPRS score and walk them through the three conditions and the six excluded requirements. Want a second set of eyes on your specific level, score, and timeline?

Check my POA&M eligibility before I buy →

Which Level 2 requirements you can never put on a POA&M (and why the SSP is the trap)

Six Level 2 requirements cannot be placed on a POA&M under 32 CFR §170.21. A capable CMMC POA&M tool should hard-flag these before anyone treats them as ordinary remediation tasks.

RequirementWhat it coversWhy it can’t wait
AC.L2-3.1.20External Connections (CUI)Must be met — not deferrable
AC.L2-3.1.22Control Public Information (CUI)Must be met — not deferrable
CA.L2-3.12.4 ⚠System Security PlanMust be met — not deferrable
PE.L2-3.10.3Escort Visitors (CUI)Must be met — not deferrable
PE.L2-3.10.4Physical Access Logs (CUI)Must be met — not deferrable
PE.L2-3.10.5Manage Physical Access (CUI)Must be met — not deferrable

The one in bold is where good intentions go to die. Your SSP itself (CA.L2-3.12.4) cannot be on a POA&M.That means an “SSP generator” feature is not enough on its own — the plan has to be current, accurate, approved, and aligned to your actual assessment scope on assessment day. The CMMC scoring methodology treats evidence as something that must be in final form: drafts, working papers, and unapproved policies don’t count as “Met.”

So when you evaluate software, ask a sharper question: not “does it generate an SSP?” but “does it help us keep an approved, scope-accurateSSP, and does it stop us from deferring a requirement the rule says we can’t?” See also our CMMC SSP software guide.


Do you actually need software, or will a spreadsheet survive your closeout?

A spreadsheet is a legitimate, free way to track a CMMC POA&M and can work for a small number of clearly eligible internal items with one disciplined owner and no near-term C3PAO assessment. It becomes a liability when multiple owners, SSP updates, CUI handling, evidence exports, or annual affirmations enter the picture — exactly the conditions the 180-day clock punishes.

A spreadsheet is usually enough when:

  • You have a few open items
  • No CUI is stored in the tracker itself
  • One person controls updates
  • There’s no looming C3PAO closeout deadline
  • Your evidence is organized elsewhere
  • Your SSP is already current

A spreadsheet starts costing you when:

  • You have many owners
  • You’re preparing for a Level 2 C3PAO assessment
  • You need an evidence export package an assessor will accept
  • You need ongoing affirmation tracking
  • You’re juggling multiple CAGE codes or systems
  • You want automatic warnings when someone tries to defer a prohibited control

The honest test: if a closeout assessor opened your tracker tomorrow, would they see clear ownership, dated milestones, and final-form evidence — or would it look like nothing has moved since the day you started? If it’s the latter, that’s a software (or readiness) signal, not a discipline problem you can willpower your way out of.


Can I use a CMMC POA&M template instead of software?

Yes — if your scope is simple, a well-built CMMC POA&M template can be enough. The template still has to capture the requirement ID, assessment objective, deficiency, owner, resources, milestones, due date, evidence link, SSP section, POA&M eligibility, score impact, and closeout status. A template is not a loophole: 32 CFR §170.21 still decides what you can defer, and 32 CFR §170.24 still scores the requirement as “Not Met” until it is actually implemented.

The field set in the section above is your template spec — copy it into a spreadsheet and you have a working CMMC POA&M template. The difference between a template and software isn’t legality; it’s automation and enforcement. A static template won’t warn you when you try to defer one of the six ineligible requirements, won’t recalculate your SPRS score as you remediate, and won’t tell you the 180-day clock is running out. If your program is small and your team is rigorous, that’s a fair trade. If it isn’t, the template is where things quietly slip — and the closeout assessment is where you find out.


Which CMMC POA&M software category fits you?

Choose by risk and assessment path, not by brand. This is our core decision asset. Find your situation, then check the must-haves against any demo.

Your situationBest-fit categoryMust-have functionsWrong fit to avoid
Small subcontractor, few open items, no near-term C3PAOSpreadsheet or lightweight trackerRequirement ID, owner, due date, evidence link, status, SSP linkExpensive broad GRC before scope is stable
Level 2 self-assessment, multiple owners, annual affirmationsCMMC-specific GRC / CMMC-ready platformSPRS score, POA&M eligibility flag, affirmation reminders, SSP/evidence linksA generic ticketing tool with no CMMC scoring logic
Level 2 C3PAO path inside 6–12 monthsCMMC-specific GRC + readiness partnerAssessment-objective evidence, export package, immutable history, closeout clockTool-only remediation with no owner accountability
CUI lives in an enclave or GCC High / GovCloudEnclave + GRC/workflow integrationBoundary mapping, evidence storage rules, CUI/SPD separationPutting CUI in a SaaS tool without FedRAMP/equivalence verification
Prime managing suppliersVendor-risk / supplier-compliance platformSupplier status, flow-down tracking, documentation requests, remindersTreating subs' POA&Ms as your own internal task list
MSP/MSSP managing multiple DIB clientsMulti-tenant CMMC workflow platformClient separation, evidence ownership, export rights, role-based access, audit logsUsing internal PSA/ticketing alone as compliance evidence
Assessment-ready except a few eligible itemsC3PAO-closeout-ready evidence trackerCloseout package, item-level proof, date controlsSwitching platforms mid-closeout window
Confused about CUI scope, SSP, or scoreReadiness provider before softwareGap assessment, scoping, SSP, POA&M build, control ownershipBuying software before you know what's being assessed

When you need CMMC-specific GRC instead of generic GRC

You need CMMC-specific tooling when the platform has to understandCMMC scoring, NIST SP 800-171 Revision 2 mapping, POA&M eligibility, SSP relationships, C3PAO evidence expectations, SPRS-ready data, and the 180-day closeout clock out of the box. Generic GRCcan work —ifit’s configurable enough and your team builds the CMMC logic correctly. The burden just shifts to you.

A platform built for continuous-monitoring dashboards (the kind that shine for SOC 2 or ISO 27001) doesn’t necessarily model the CMMC POA&M lifecycle — the eligibility limits, the conditional-status threshold, the 180-day window, the closeout assessment. CMMC isn’t “SOC 2 with different controls.” See also our CMMC GRC software guide.

We’ll line up source-checked options that fit your level, scope, and where your CUI actually lives.

Compare matched software and enclave options for my environment →

The scope trap: what data to keep outof a POA&M tool until you verify

Do not put CUI, sensitive evidence, network diagrams, vulnerability data, or Security Protection Data into a SaaS POA&M tool until you confirm whether that tool becomes part of your assessment scope. Under 32 CFR §§170.16 and 170.17, a cloud service offering that processes, stores, or transmits CUI must be FedRAMP Authorized at the Moderate (or higher) baseline or meet equivalent security requirements per DoD policy, with the Customer Responsibility Matrix documented or referenced in your SSP.

This is the mistake that turns a $10,000 tool into a six-figure problem. If the tool will hold CUI, you’ve potentially pulled that tool into your assessment boundary. Ask the vendor, in writing:

Before you upload anything, confirm:

  • Does your contract permit storing CUI?
  • Is the offering FedRAMP Moderate authorized (or higher)?
  • If not, do you claim FedRAMP Moderate equivalency, and is that equivalency documented (not just marketing language)?
  • Is a Customer Responsibility Matrix available so we know which controls are yours versus theirs?
  • Will this tool be inside our SSP boundary?
Regulation-stated vs operationally-verified. Regulation-stated: 32 CFR §170.19 defines the CMMC assessment scope and asset categories (including Security Protection Assets and ESPs), and 32 CFR §§170.16/170.17 set the cloud-provider rules for CUI. Operationally verify with the vendor: whether CUI, Security Protection Data, or evidence is stored; where it resides; whether a Customer Responsibility Matrix exists; and whether the tool falls inside your SSP boundary.

For contractors whose CUI residency drives the decision — see our guide to secure CUI environments and enclave options.

Map your POA&M tool to your CUI scope →

What CMMC POA&M software actually costs

Most CMMC compliance platforms don’t publish pricing; where they do, purpose-built CMMC documentation tools tend to start in the low five figures per year. As one public example, Paramify lists Level 2 CMMC compliance at $8,000–$25,000 per year and Level 3 at $35,000–$70,000 per year(verified June 8, 2026 on Paramify’s public pricing page). Treat that as one vendor’s public data point to confirm when you buy, not a benchmark for the whole market.

Before you compare any two prices, settle what you’re actually buying:

What it doesWhat it should cost more for
Tracks tasks and owners onlyLittle — this is close to a spreadsheet
Stores evidence and artifactsMore — storage, retention, access controls
Stores or transmits CUIA lot more — FedRAMP/equivalency, data residency
Generates SSP/POA&M documentsMore — and verify the output is approval-ready, not draft
Supports C3PAO closeout exportsMore — assessor-grade packaging matters
Bundles readiness servicesMost — you're paying for people, not just software
Tool / categoryPublic price posted?Public range (verify at purchase)BasisLast verified
Spreadsheet / templateYes (internal)Free to lowInternal timeJune 8, 2026
Paramify (CMMC platform)YesL2 $8k–$25k/yr; L3 $35k–$70k/yr; roadmap $2k/yrPer level/offeringJune 8, 2026
FutureFeed, Cyturus, Totem (CMMC platforms)Mostly noQuote-basedPer company / CAGE / usersJune 8, 2026
Vanta, Drata, Secureframe, Hyperproof, Ignyte (GRC)Mostly noQuote-basedPer company / usersJune 8, 2026
Enclave + workflow (e.g., GCC High stack)NoQuote-basedPer environment / usersJune 8, 2026
Managed readiness + toolNoProject / monthlyPer engagementJune 8, 2026

Don’t compare software prices until you know whether the tool is tracking tasks, storing evidence, storing CUI, generating documents, supporting a C3PAO closeout, or bundling services. Those aren’t the same purchase. For the bigger picture on program cost, see our CMMC cost breakdown.


20 questions to ask before you buy (your vendor-demo scorecard)

Treat every vendor claim as a claim, not proof. Bring this to every demo. We built it to expose the gaps a polished sales deck hides. Score each tool out of 20 — the lower the score, the more of the CMMC-specific work falls back on you.

  1. Does the tool map to NIST SP 800-171 Revision 2 (the current CMMC Level 2 baseline) — and how would it handle a future change to the rule?
  2. Does it flag the six §170.21 requirements that can’t be on a POA&M?
  3. Does it calculate score impact (the 1/3/5-point deductions)?
  4. Does it support the SC.L2-3.13.11 FIPS-validation exception correctly?
  5. Does it track the Conditional CMMC Status Date and auto-calculate the 180-day deadline?
  6. Can it export an evidence package a C3PAO will accept?
  7. Does it store CUI? Under what terms?
  8. Does it store Security Protection Data?
  9. If it stores CUI, is the service FedRAMP Moderate authorized or documented-equivalent?
  10. Is a Customer Responsibility Matrix available?
  11. Who owns your data after cancellation, and can you export everything — SSP, POA&M, evidence, audit history?
  12. Does it support multiple CAGE codes / multiple systems?
  13. Does it handle annual affirmation reminders (32 CFR §170.22)?
  14. Does it keep your SSP in sync, and does it distinguish draft from approved evidence?
  15. Does it preserve immutable historical snapshots?
  16. Does it support subcontractor/supplier tracking if you’re a prime?
  17. Are any AI-generated narratives reviewed and approved before use as evidence?
  18. Does it separate readiness work from assessment work (so you don’t blur the two)?
  19. What is company-stated versus independently verified?
  20. Is the vendor also an RPO, MSP, or C3PAO — and if so, how do they keep those roles separate?

For the implementation side of the house, our CMMC readiness checklist pairs well with this scorecard.


What happens after Conditional status — closeout and affirmations

After Conditional status, a POA&M closeout assessment evaluates only the items marked “Not Met” with a POA&M, and it must be completed within 180 days. Separately, under 32 CFR §170.22, a senior “Affirming Official” must affirm continuing compliance in SPRS after every assessment — including at POA&M closeout — and annually thereafter.

Here’s why that’s not just paperwork. Contracting officers verify your current CMMC status in SPRS before award and before exercising options or extending performance (DFARS subpart 204.75), and the clause at DFARS 252.204-7021requires you to maintain that status, your annual affirmations, and your POA&M closeout during the contract. The blunt version: no current affirmation, no award. And because the affirmation is a senior executive’s formal attestation to the government, an inaccurate one can carry False Claims Act exposure.

That’s exactly why “tracks the POA&M” isn’t enough. Your tool should also remind you to update or submit:

Phase 1 of the CMMC rollout took effect November 10, 2025, with Phase 2 scheduled for November 10, 2026. Phase 1 centers on Level 1 and Level 2 self-assessments — and the DoD reminds contractors to submit their affirmations with their assessments in SPRS. Translation: the affirmation isn’t a future problem. It’s a now problem.

Your 30 / 60 / 90 / 180-day CMMC POA&M plan

The implementation plan should mirror the assessment-risk timeline. This cadence is also a sanity check on whether you need software at all — if you can’t realistically hit these marks by hand, that’s your answer.

Days 1–30 — Frame it.

Confirm your level and assessment type. Confirm what touches CUI. Identify CAGE/system boundaries. Load the NIST SP 800-171 Rev. 2 requirements. Build the SSP structure. Import your gap assessment. Assign owners. Flag the prohibited POA&M items immediately.

Days 31–60 — Fix the worst first.

Remediate the highest-risk gaps. Attach final-form evidence. Update the SSP as controls change. Run internal evidence reviews. Watch your score move.

Days 61–90 — Prove it.

Assemble the assessment package. Validate evidence. Replace stale artifacts. Escalate blocked owners. Decide honestly whether software-only is still enough — or whether you need readiness help to make the deadline.

Days 91–180 — Close it.

Close the eligible POA&M items. Build the closeout evidence package. Schedule the closeout path (self, C3PAO, or DIBCAC). Submit the closeout affirmation. Archive the final state for the next cycle.


Do you need software, readiness, an enclave, or a C3PAO?

Most readers searching for “POA&M software” actually have one of several different needs. Here’s the clean routing:

Your real needThe provider category that fits
Build the SSP/POA&M from scratchReadiness consultant / RPO / vCISO
Remediate technical controlsMSP / MSSP
Track evidence and POA&MGRC / CMMC software (a supporting layer, not the whole solution)
Reduce CUI scopeSecure enclave / GCC High / GovCloud implementation partner
Get formal Level 2 statusAn authorized/accredited C3PAO
Close a Conditional Level 2 (C3PAO)A qualified C3PAO closeout path
One guardrail we won’t soften: keep readiness and formal assessment separate.Cyber AB’s independence rules exist for a reason — anyone who participated in helping an organization prepare for its CMMC assessment cannot serve on that organization’s assessment team. If a single vendor offers to “implement andassess” your environment in one bundle, that’s a flag to slow down and ask exactly how they separate those roles. See our provider-category guide and who to hire first.

Tell us your level, scope, current score, open items, and timeline. We’ll match you with provider options by category — by fit, not by who paid for placement.

Get matched with source-checked CMMC provider options →

How we reference the tools named on this page

No row below is a recommendation, ranking, endorsement, Cyber AB status claim, or DoD/Cyber AB affiliation claim. Each capability is the company’s own public statement unless noted otherwise. This table is editorial, not paid placement; where we have a referral, sponsorship, or partner relationship, we disclose it at the point we route you to them — this page routes to provider categories, not to these vendors.

Tool (category)Company-stated public claimWhat to verify before buyingLast verified
FutureFeed (purpose-built CMMC)A NIST 800-171/CMMC program-management platform with guided assessment, SSP, exports, and reportingPOA&M closeout workflow, evidence retention, C3PAO export format, data residency, pricingJune 8, 2026
Cyturus — Compliance & Risk Tracker (CMMC + risk)CMMC plus 250+ frameworks via the Secure Controls Framework, with risk and incident modulesWhether it models the §170.21 POA&M lifecycle (clock, eligibility); pricingJune 8, 2026
Totem / Haight Bey & Associates (CMMC platform; also an RPO)CMMC compliance software with a built-in POA&M workflow aimed at small businessesCurrent capabilities, evidence output; keep readiness vs assessment separate; pricingJune 8, 2026
Paramify (CMMC/FedRAMP documentation)POA&M management plus automated SSP/document generation; public pricing L2 $8k–$25k/yr, L3 $35k–$70k/yrCUI handling, closeout workflow, current pricingJune 8, 2026
Vanta / Drata / Secureframe (general GRC automation)CMMC templates, SSP generation, POA&M management, continuous monitoringFedRAMP/GovCloud status, CUI storage terms, and whether the CMMC POA&M lifecycle is actually modeledJune 8, 2026
Hyperproof / Ignyte (broader GRC, gov-leaning)GRC with CMMC modules and government featuresCMMC-specific POA&M depth and GovCloud deploymentJune 8, 2026
PreVeil / Kiteworks (CUI enclave / secure collaboration)FedRAMP-aligned environments where CUI lives, with supporting compliance featuresThese are data environments, not primarily POA&M trackers; verify fit for your residency decisionJune 8, 2026
Risk Cognizance / Tesseract by Ardalyst (CMMC GRC / managed program)SSP generation, POA&M tracking, evidence management, assessor collaborationConfirm claims and that page language is current to the Final Rule; pricing; CUI handlingJune 8, 2026

Accuracy watch — a real buying trap

NIST has published newer baselines — SP 800-171 Revision 3 and SP 800-172 Revision 3 — and marked the older versions as superseded on its site. That does not change CMMC. Under 32 CFR Part 170, CMMC Level 2 is still assessed against NIST SP 800-171 Revision 2, and Level 3 is still assessed by DIBCAC against the 24 requirements selected from the February 2021 SP 800-172. Those baselines change only when DoD amends the rule through formal rulemaking. So if a vendor tells you their tool is “updated to Rev. 3,” ask whether it still assesses you against the baseline the rule enforces today. Buying software that assumes Rev. 3 is the controlling CMMC baseline is buying the wrong map.


What we actually verified

We separate hard regulatory facts from our editorial judgment, and we show our work. Last verified: . Next scheduled verification: September 2026.

SourceWhat it supportsLast verified
32 CFR §170.21 (eCFR)POA&M eligibility limits, the six excluded Level 2 requirements, the 0.8/88 threshold, the 3.13.11 exception, 180-day closeoutJune 8, 2026
32 CFR §170.22 (eCFR)Affirmation after every assessment including POA&M closeout, and annually, by a senior Affirming Official in SPRSJune 8, 2026
32 CFR §§170.16 / 170.17 (eCFR)Level 2 self vs C3PAO paths; cloud-provider (CSP) FedRAMP rules and CRM/SSP documentation; Final status requires a passing scoreJune 8, 2026
32 CFR §170.19 (eCFR)CMMC assessment scope, asset categories, and ESP/SPD treatmentJune 8, 2026
32 CFR §170.24 (eCFR)The 1/3/5-point scoring methodology; evidence must be in final formJune 8, 2026
DFARS subpart 204.75 + 252.204-7021 + 204.7501 (Acquisition.gov)CMMC status as a condition of award/option exercise; current status windows; affirmation requirementsJune 8, 2026
DFARS 252.204-7012 (Acquisition.gov)External cloud provider must meet FedRAMP Moderate-equivalent security requirements for covered defense informationJune 8, 2026
DoD CIO CMMC pagePhase 1 start (Nov 10, 2025); SPRS affirmation reminderJune 8, 2026
NIST CSRC (SP 800-171 Rev. 2; SP 800-172)Level 2 baseline = Rev. 2; Level 3 = Feb 2021 SP 800-172 subset; Rev. 3 publication statusJune 8, 2026
Cyber AB ecosystem pagesC3PAO role and assessor-independence rulesJune 8, 2026

Frequently asked questions about CMMC POA&M software

What is CMMC POA&M software?

CMMC POA&M software is a tool for tracking remediation tasks, owners, milestones, evidence, and closeout status for gaps found against CMMC and NIST SP 800-171 requirements. It should connect each POA&M item to your System Security Plan and the relevant assessment objective, not operate as a disconnected task list.

Is a POA&M allowed for CMMC Level 1?

No. Under 32 CFR §170.21, a POA&M is not permitted at any time for Level 1 self-assessments, and Level 1 has only Final status — there is no conditional path.

Can CMMC POA&M software make a failed requirement eligible for a POA&M?

No. Software can flag eligibility, track remediation, and organize evidence, but 32 CFR §170.21 — not any tool — determines whether a requirement can be deferred. Six Level 2 requirements and every requirement worth more than one point (except SC.L2-3.13.11) cannot be on a POA&M.

What CMMC Level 2 requirements cannot be on a POA&M?

Six: AC.L2-3.1.20 (External Connections), AC.L2-3.1.22 (Control Public Information), CA.L2-3.12.4 (System Security Plan), PE.L2-3.10.3 (Escort Visitors), PE.L2-3.10.4 (Physical Access Logs), and PE.L2-3.10.5 (Manage Physical Access). These must be fully met before Conditional status.

What is the minimum score to qualify for a CMMC POA&M?

For Level 2, your SPRS score must be at least 88 of 110 — the rule requires the score divided by 110 to be 0.8 or higher (32 CFR §170.21). Because the score is weighted (1, 3, or 5 points per unmet requirement under 32 CFR §170.24), that means total deductions of no more than 22 points.

How long do you have to close a CMMC POA&M?

180 days from the Conditional CMMC Status Date (32 CFR §170.21). If the POA&M isn't successfully closed within that window, the Conditional status for that information system expires.

Can I use Excel for a CMMC POA&M?

Yes, if the scope is simple and the team is disciplined. Excel becomes risky once you need CMMC scoring logic, eligibility flags, SSP linkage, assessor-ready evidence exports, multi-owner workflows, or 180-day closeout tracking.

Can I use a CMMC POA&M template?

Yes, but only as a tracking mechanism. A template doesn't change §170.21 eligibility, §170.24 scoring, your SSP obligations, or the 180-day closeout clock — it just organizes the work. Use the field set in this guide as your template spec.

Does POA&M software replace a C3PAO?

No. A C3PAO performs Level 2 certification assessments and the Level 2 (C3PAO) closeout; software only helps you organize the remediation and evidence. Readiness help and formal assessment must stay appropriately separate.

Can I store CUI in a POA&M tool?

Only after verifying the tool is appropriate for handling CUI in your assessment context. Under 32 CFR §§170.16/170.17, a cloud service offering that handles CUI must be FedRAMP Moderate authorized or documented-equivalent with a CRM referenced in your SSP, and DFARS 252.204-7012 requires equivalency to the FedRAMP Moderate baseline for covered defense information.

Does CMMC use NIST SP 800-171 Rev. 2 or Rev. 3?

CMMC Level 2 currently maps to NIST SP 800-171 Revision 2 under 32 CFR Part 170. NIST publishing newer revisions does not change CMMC until DoD amends the rule through formal rulemaking — so don't buy software that assumes Rev. 3 is already the controlling assessment baseline.

What's the best CMMC POA&M software for a small business?

It depends on your open-item count, assessment type, CUI scope, evidence complexity, and budget. A disciplined spreadsheet can be enough for a very small contractor with a few internal gaps; a Level 2 C3PAO path needs CMMC-aware workflow with evidence exports and closeout tracking.

What happens if I miss the 180-day closeout window?

The Conditional CMMC Status for that information system expires (32 CFR §170.21). If that happens during a contract's period of performance, standard contractual remedies apply, and you may be ineligible for new awards that require the status.


Need help deciding what type of CMMC provider you need?

You came here for software. What you actually need might be a tracker, a readiness partner, an enclave, or a C3PAO — and the cheapest mistake to avoid is committing before you know which.

If you already know you just need a tracker and your score is strong, skip the form — pick a category above and book a demo. If your gap list is long or your score is under 88, talk to us first; software won’t fix that, and we’d rather route you to the help that will.

Tell us your level, scope, and timeline, and we’ll match you with source-checked CMMC provider options.

Get matched with source-checked options →

Related from The Defense Compliance Report

Sources we read: 32 CFR §§170.16 / 170.17 (Level 2 self-assessment and certification assessment, incl. CSP/CRM rules) — 32 CFR §170.19 (CMMC scoping) — 32 CFR §170.21 (POA&M requirements) — 32 CFR §170.22 (Affirmation) — 32 CFR §170.24 (Scoring) — DFARS subpart 204.75, 252.204-7021DFARS 252.204-7012DoD CIO CMMC pageNIST SP 800-171 Rev. 2 (NIST CSRC).

Disclosure: The Defense Compliance Report is an independent trade publication on CMMC 2.0 and DIB compliance. We may receive compensation for qualified introductions, sponsorships, or partner referrals when disclosed. Compensation does not control our regulatory analysis, provider-category recommendations, or Cyber AB status verification. The Defense Compliance Report is not affiliated with the Department of Defense, The Cyber AB, CAICO, DCMA DIBCAC, NIST, FedRAMP, or any U.S. government agency. Read our editorial review process.

This article is general information for defense-industrial-base decision-makers, not legal, contractual, or compliance advice. CMMC requirements derive from your contract and the controlling regulations; verify current requirements against your contract clauses and the primary sources above.