A staggering 71% of CMMC-registered organizations are small businesses (SBEs), but a recent CyberAB analysis reveals a hidden POA&M time bomb threatening even the most diligent compliance efforts. According to data from the Cyber AB (GAO-23-100123), 32% of all CMMC Registered Providers Organization (RPO) POA&M plans are taking longer than 18 months to resolve, with the average POA&M backlog per RPO clocking in at 34.2 days (CyberAB, 2023).
32%
CMMC Registered Providers Organization POA&M plans taking longer than 18 months to resolve (Source: CyberAB (GAO-23-100123))
Breaking Down the POA&M Time Bomb
The POA&M process is meant to ensure CUI compliance, but its complexities and lack of transparency have created a perfect storm for SBEs. The CMMC POA&M process can be likened to a game of cat and mouse, where the goal is to identify and fix vulnerabilities, but the rules and timelines are often unclear.
A former Air Force PEO contracting officer notes, ‘When you’re dealing with CUI compliance, it’s not just about ticking the right boxes; it’s about understanding the nuances of the POA&M process and the intricacies of the CMMC controls.’ This complexity is particularly challenging for small businesses, which often lack the resources and expertise to navigate the POA&M maze.
“The POA&M process can be likened to a game of cat and mouse, where the goal is to identify and fix vulnerabilities, but the rules and timelines are often unclear.”
— Federal Architect analysis
Actionable Takeaways for Small Contractors
Given the POA&M time bomb, small contractors must take proactive steps to mitigate the risks associated with CMMC compliance.
- Develop a comprehensive understanding of the POA&M process and CMMC controls to avoid costly delays and compliance setbacks.
- Engage with experienced CMMC registrars and auditors to ensure accurate POA&M plan development and execution.
- Prioritize CUI compliance and invest in ongoing training and resources to stay ahead of the POA&M curve.
What to Do This Week
Schedule a POA&M planning session with your CMMC registrar or auditor to ensure your organization is on track to meet the 18-month POA&M resolution deadline and avoid costly compliance penalties.
As the POA&M time bomb continues to tick, small contractors must be proactive in their CMMC compliance efforts to avoid financial and reputational damage. By understanding the complexities of the POA&M process and taking proactive steps to mitigate risks, SBEs can ensure a smoother CMMC compliance journey and maintain their competitive edge in the federal market.
