CMMC POA&M Template: Source-Checked Fields, Examples, and the Rules That Decide What You Can Defer
If you searched for a CMMC POA&M template, you already know you have gaps. What you may not know is that the template is the easy part—and that the wrong entries in it can leave you looking organized while your certification path quietly stays blocked. Here’s the bottom line first, then the template, then the one distinction that separates a POA&M that helps from one that hurts.
A CMMC POA&M template (Plan of Action and Milestones—the document that tracks each unmet requirement with its owner, resources, milestones, completion date, evidence, and closeout path) is genuinely useful, but it cannot make every gap deferrable. Under 32 CFR §170.21, CMMC Level 1 cannot use a POA&M at all. For Level 2, a POA&M supports Conditional status only when your assessment score is at least 0.8 of the total—a minimum of 88 of 110 points—every deferred item is worth a single point except the narrow SC.L2-3.13.11 encryption exception, none of the six Level 2 excluded requirements appears on it, and everything closes within 180 days. Level 3 has its own 0.8 score gate, seven different excluded requirements, and a DCMA DIBCAC closeout path.
Download the source-checked CMMC POA&M template
NIST publishes the official CUI Plan of Action template free and ungated alongside SP 800-171 Rev. 2. That is the base document. Use the fields, gates, and eligibility logic on this page to add the CMMC Layer on top before you write a single due date.
Get the NIST CUI Plan of Action template (free, official) →Whether a POA&M does anything for your CMMC status depends entirely on your level and assessment path:
| Your situation | Can a POA&M support Conditional CMMC Status? | What the template must do | Primary source |
|---|---|---|---|
| CMMC Level 1 (FCI only) | No—not at any time | Use it to organize internal fixes, but meet every requirement before you affirm. A POA&M creates no Level 1 path. | §170.21(a)(1) |
| CMMC Level 2 self-assessment | Yes—for Conditional status only, when §170.21 is met | Track eligible 1-point items, owner, evidence, the 180-day clock, and your SPRS posting. | §170.16, §170.21 |
| CMMC Level 2 C3PAO assessment | Yes—for Conditional status only, when §170.21 is met | Same, plus the C3PAO closeout posted in CMMC eMASS. | §170.17, §170.21 |
| CMMC Level 3 (DIBCAC) | Yes—but limited | Track the Level 3 0.8 score gate, the seven excluded Level 3 requirements, eligible items, and the DIBCAC closeout path. | §170.21(a)(3) |
| Internal NIST 800-171 remediation | Operational use—not a status mechanism | Manage deficiencies and mitigations on your own schedule; don’t assume it creates conditional CMMC status. | NIST SP 800-171 Rev. 2 §3.12.2 |
Can a CMMC POA&M template make every gap deferrable?
No. A POA&M template can give you false confidence. If you drop a prohibited requirement, a high-value control, or an unresolved System Security Plan onto the wrong kind of POA&M, the document will look tidy and complete—while your path to a passing score is still closed. That is the trap, and most downloads walk you straight into it because they hand you blank columns and no rules.
The constraints are knowable. They are written into a few short sections of federal regulation, and once you can see them you can build a POA&M that holds up. We read 32 CFR §170.21 and §170.24 line by line and turned their limits into an eligibility gate inside the template, so every “Not Met” item gets classified before you assign it a due date. You do not have to memorize the rule. You have to run your items through it.
The first thing to get straight: “POA&M” means two different things in this program.
| Attribute | Operational plan of action | CMMC assessment POA&M |
|---|---|---|
| What it is | The ongoing remediation artifact required as a security control (CA.L2-3.12.2). §170.4 defines it as a CMMC term and says plainly it carries no remediation timeline and is not the same as the assessment POA&M. | The formal POA&M that earns Conditional CMMC status for a limited set of unmet items (§170.21) |
| Purpose | Manage and fix weaknesses you find yourself; a living document | Buy time on eligible gaps found at assessment |
| 180-day clock? | No—no fixed deadline | Yes—a hard 180-day closeout |
| Eligibility limits? | No conditional-status point or exclusion gates. Note: under §170.24, a temporary deficiency documented here is scored Met only when appropriately addressed—with deficiency reviews and demonstrable progress. | Strict—1-point items only, the 0.8 score gate, and the exclusion list |
| Who reviews it | Internal; an assessor confirms the process exists | You (Level 2 self), a C3PAO (Level 2 cert), or DIBCAC (Level 3) at closeout |
| Format | “Any chosen format”; can be combined with the SSP | Same content rules, but every item must be closeout-verifiable |
NIST SP 800-171 Revision 2 is explicit that a plan of action describes how unimplemented requirements and planned mitigations will be addressed, and that organizations may use whatever format they choose and may even combine it with the System Security Plan. CMMC keeps that flexibility for the document—and then layers strict status rules on top. Your template needs to carry both labels so a routine remediation task is never mistaken for something that supports conditional certification.
Which CMMC requirements can actually go on a POA&M?
For CMMC Level 2, a POA&M is allowed only when three conditions are all true: your score divided by the total is at least 0.8, every open item is worth a single point under the CMMC Scoring Methodology (§170.24) (one encryption exception applies), and none of the open items is one of six requirements the rule names as ineligible. Miss any one of those and the POA&M does not produce conditional status. This is the section most templates skip, and it is the one that actually decides your outcome.
Gate 1—the 0.8 score threshold
CMMC Level 2 maps to 110 security requirements, drawn from NIST SP 800-171 Rev. 2 and organized into 14 control families. The assessment methodology in §170.24 starts you at a perfect score of 110 and subtracts a weighted value for each unmet requirement. To use a POA&M, your score ÷ 110 must be ≥ 0.8—in plain terms, at least 88 of a possible 110 points.
A word of caution you will rarely see stated plainly: that is notthe same as “88 of 110 controls met.” Requirements are weighted at 1, 3, or 5 points—§170.24 lists exactly which requirements carry which value—so failing a handful of 5-point controls can drop you below 88 even if you have met most of the list. Count points, not checkboxes.
Gate 2—1-point items only (with one exception)
Only requirements worth a single point are eligible to sit on a Level 2 POA&M. In practice, those are the “remaining derived” requirements that §170.24 assigns a value of 1; the 3-point and 5-point requirements must be fully met.
The lone carve-out is SC.L2-3.13.11(FIPS-validated cryptography for protecting CUI): it may go on a POA&M when your organization isusing encryption but it is not yet FIPS-validated—a situation §170.24 scores as a 3-point deduction. If you are using no encryption at all, that is a 5-point deduction, the exception does not apply, and the item is not deferrable.
There is a parallel partial-credit rule for multifactor authentication, IA.L2-3.5.3: 3 points off if MFA covers only remote and privileged users, 5 points off if it is not implemented for anyone. Build the encryption fork into your template so the two situations never blur.
Gate 3—the six requirements you can never defer at Level 2
This list is verbatim from §170.21(a)(2)(iii). If any of these is “Not Met,” no POA&M will save your status—it has to be fixed.
| Requirement | Plain-English label | On a Level 2 POA&M? |
|---|---|---|
| AC.L2-3.1.20 | External connections (CUI data) | No |
| AC.L2-3.1.22 | Control of publicly posted information (CUI data) | No |
| CA.L2-3.12.4 | System Security Plan | No |
| PE.L2-3.10.3 | Escort visitors (CUI data) | No |
| PE.L2-3.10.4 | Physical access logs (CUI data) | No |
| PE.L2-3.10.5 | Manage physical access (CUI data) | No |
The SSP trap. Read that list again: your System Security Plan (CA.L2-3.12.4) cannot be put on a POA&M.It is worse than ineligible. §170.24 states that if you do not have an up-to-date SSP describing each in-scope system at the time of assessment, the result is a finding that an assessment could not be completed—and it ties that finding to noncompliance with DFARS 252.204-7012. If your SSP is missing, stale, or does not actually describe your environment, you do not have a deferral option; you have remediation to do before an assessment can even proceed.
Need to fix that first? Start with our CMMC System Security Plan template →
Level 1
There is no version of this that works at Level 1. §170.21(a)(1) does not permit a POA&M for Level 1 self-assessments at any time, and §170.24 scores Level 1 as Met or Not Met in its entirety. All 15 Level 1 safeguards (from FAR 52.204-21) must be met before you affirm.
Level 3
Level 3 also permits a limited POA&M, subject to its own 0.8 score gate against the 24 selected NIST SP 800-172 Feb2021 requirements, with seven requirements excluded from deferral: IR.L3-3.6.1e, IR.L3-3.6.2e, RA.L3-3.11.1e, RA.L3-3.11.6e, RA.L3-3.11.7e, RA.L3-3.11.4e, and SI.L3-3.14.3e (§170.21(a)(3)(ii)). Closeout is performed by DCMA DIBCAC. If you are pursuing Level 3, treat the eligibility logic the same way—classify first, plan second. See our CMMC Level 3 requirements guide.
Check eligibility before you write a single due date
Run each “Not Met” item through the three gates above: confirm your score is ≥ 88, confirm the item is worth 1 point, and confirm it is not on the exclusion list. Items that fail any gate belong in your remediation backlog—not your POA&M register.
Want a second set of eyes on the plan?
Tell us your level, scope, and timeline and we’ll match you with source-checked CMMC readiness providers who can pressure-test your POA&M eligibility and scope the remediation work.
Get matched with CMMC readiness providers →What belongs in a CMMC POA&M template (field by field)
A useful CMMC POA&M needs more than a finding, an owner, and a due date. At minimum, the regulation’s definition requires each item to identify the tasks to be accomplished, the resources required, the milestones, and the scheduled completion dates—a definition CMMC sets out in §170.4 (tracing it to NIST SP 800-115) and reinforces in DFARS 252.204-7021. For the document to survive a closeout review, assessors also expect each item mapped to its requirement, with evidence and a clear path to verification.
One myth to retire first: the CMMC rule does not mandate an official POA&M spreadsheet. §170.4 defines whata POA&M must contain; NIST permits “any chosen format”; and you produce the document yourself. Anyone selling you “the official CMMC POA&M template” is overstating things. The FedRAMP POA&M template you will find online is a different program for cloud service providers—do not use it for CMMC. What matters is not the file; it is whether the document carries the fields below.
| Field | Why it matters | Source basis |
|---|---|---|
| POA&M ID | Keeps each gap traceable through closeout | Operational best practice |
| CMMC level & assessment path | Determines whether a POA&M is even allowed and who performs closeout | §170.21 |
| Requirement ID (NIST / CMMC) | Maps the deficiency to the rule; closeout assesses only POA&M’d items | §170.21(b); NIST SP 800-171A |
| Point value | Confirms the item is actually eligible—only 1-point items qualify (SC.L2-3.13.11 encryption exception noted) | §170.24 |
| POA&M eligibility flag | Stops an invalid deferral before it is written; must check all three gates | §170.21 |
| Finding summary | States the deficiency in observable terms—specific enough for a closeout reviewer to verify | NIST SP 800-171A |
| Owner / responsible party | Named individual; a group name is not sufficient for closeout accountability | Operational best practice; DFARS 252.204-7021 |
| Tasks to be accomplished | Specific remediation steps—regulation-required; vague action items fail closeout | §170.4 definition |
| Resources required | Budget, tooling, headcount needed; regulation-required | §170.4 definition |
| Milestones | Interim checkpoints between open and closed; regulation-required | §170.4 definition |
| Scheduled completion date (≤180 days) | Must fall within the 180-day conditional window; regulation-required | §170.4; §170.21(b) |
| Evidence reference | Artifact(s) that will prove the item is closed; retain for six years (§170.17) | §170.24; §170.17 |
| Status | Not Met / In Progress / Closed—with closeout date when applicable | Operational best practice |
| Closeout actor & posting | Contractor (self-assessment → SPRS), C3PAO (cert → CMMC eMASS), DIBCAC (Level 3). Mismatch invalidates the closeout. | §170.21(b); §170.16–17 |
See the full CMMC POA&M closeout rules for what each actor checks and how Final status is posted.
Not sure who should be reviewing your POA&M?
See how RPOs, managed compliance providers, and C3PAOs differ in what they can do with your POA&M—and what independence rules prevent.
Compare CMMC provider categories →How we built and verified this template
We built this from primary regulatory and program sources, not provider marketing. On , we read 32 CFR §170.21 (POA&M requirements), §170.24 (scoring methodology), §170.16 and §170.17 (the Level 2 self-assessment and C3PAO paths), §170.4 (definitions), NIST SP 800-171 Rev. 2 §3.12.2, and DFARS 252.204-7021 on Acquisition.gov. Then we converted those requirements into the fields, eligibility flags, and closeout logic on this page.
| Source | What we used it for |
|---|---|
| 32 CFR §170.21 | POA&M eligibility, the six excluded Level 2 requirements, the seven excluded Level 3 requirements, the 180-day closeout, and closeout actor by path |
| 32 CFR §170.24 | The 0.8 score gate, the 1/3/5 point values, the final-evidence standard, the SSP-absence finding, and the operational-plan “temporary deficiency” rule |
| 32 CFR §§170.16–170.17 | The self-assessment and C3PAO assessment paths and SPRS/eMASS posting |
| 32 CFR §170.3(e) | The four-phase implementation timeline |
| NIST SP 800-171 Rev. 2 | The CA.L2-3.12.2 plan-of-action basis and “any chosen format” flexibility |
| DFARS 252.204-7021 | The POA&M definition, the current-status obligation, and the related cyber clauses |
What this template does not do
It does not guarantee certification. It is not legal, contractual, or compliance advice. It does not make an ineligible requirement eligible, replace a current System Security Plan, authorize a readiness consultant to perform a C3PAO assessment, or prove that any provider is Cyber AB-listed or assessment-ready.
A version note that matters
CMMC Level 2 currently maps to NIST SP 800-171 Revision 2, even though NIST has since published Revision 3 in its own publication lifecycle. The controlling CMMC baseline remains Rev. 2 unless and until DoD amends the rule. We track this and will update the page if it changes.
Last verified: . Next review: , or sooner if DoD updates 32 CFR Part 170, DFARS 252.204-7021, CMMC phase timing, or the Cyber AB CMMC Assessment Process. See our editorial standards and corrections policy.
CMMC POA&M template: frequently asked questions
Is there an official CMMC POA&M template?
No. The CMMC rule does not mandate a specific POA&M file or spreadsheet. §170.4 defines what the document must contain—tasks, resources required, milestones, and scheduled completion dates—and NIST permits “any chosen format,” so you produce it yourself. The FedRAMP POA&M template is for cloud service providers pursuing FedRAMP authorization and is a different program; do not use it for CMMC.
Can CMMC Level 1 use a POA&M?
No. 32 CFR §170.21 does not permit POA&M use for Level 1 status at any time, and §170.24 scores Level 1 as Met or Not Met in its entirety. All 15 Level 1 safeguards (from FAR 52.204-21) must be met before you affirm.
Can CMMC Level 2 use a POA&M?
Yes, but only narrowly. Your assessment score must be at least 0.8 of the total (a minimum of 88 of 110 points), every open item must be a 1-point requirement with the single SC.L2-3.13.11 encryption exception, none of the six excluded requirements may be on it, and you must close it within 180 days.
What score do I need for a Level 2 conditional POA&M?
At least 0.8 of the total Level 2 score, which is a minimum of 88 of a possible 110 points. Because requirements are weighted at 1, 3, or 5 points under §170.24, this is not the same as 88 of 110 controls met — failing a few high-value controls can drop you below the threshold even if you have met most of the list. Count points, not checkboxes.
Can I put my SSP on a POA&M?
No. CA.L2-3.12.4, the System Security Plan requirement, is one of the six requirements excluded from Level 2 POA&M use under 32 CFR §170.21. Section §170.24 goes further: without an up-to-date SSP at the time of assessment, the result is a finding that an assessment could not be completed. A missing or inadequate SSP is remediation, not a deferral.
Is a NIST 800-171 POA&M the same as a CMMC POA&M?
No. A NIST 800-171 plan of action is an operational artifact for managing deficiencies on your own schedule. A CMMC conditional-status POA&M is governed by CMMC level-specific eligibility rules and a hard 180-day closeout deadline. You may need both.
What happens if I miss the 180-day POA&M closeout deadline?
Your Conditional CMMC status expires if the POA&M is not successfully closed out within 180 days. If that lapse occurs during a contract’s period of performance, standard contractual remedies apply. See CMMC POA&M closeout rules for what happens at each stage.
Who closes out a CMMC POA&M?
For a Level 2 self-assessment, the contractor (OSA) performs closeout and posts to SPRS. For a Level 2 certification, an authorized or accredited C3PAO performs closeout, recorded in CMMC eMASS. For Level 3, DCMA DIBCAC performs closeout.
Does a CMMC conditional-status POA&M item count as Met?
No. Under 32 CFR §170.24, a requirement on a POA&M is still Not Met and must be remediated and verified before you reach Final CMMC Status. Separately — and not the same thing — §170.24 allows certain temporary deficiencies documented in an operational plan of action to be scored Met, but only when they are appropriately addressed with deficiency reviews and demonstrable progress toward the fix.
Can my readiness consultant also be my C3PAO?
Generally no. Readiness and remediation must stay separate from formal assessment under the conflict-of-interest rules that govern C3PAOs and their assessment team members. Keep the two engagements distinct — and verify any potential C3PAO is authorized on the Cyber AB Marketplace before you sign.