CMMC rule changes have been announced repeatedly over the past year, but one crucial detail remains largely overlooked: the POA&M timeline. A Federal Architect analysis of CyberAB data reveals a concerning gap between announced timelines and the actual time contractors spend on POA&M – with severe consequences for those who fail to plan accordingly. Per CyberAB, the average POA&M timeline for a Level 3 assessment is 180 days (CyberAB data, queried 2024-06-15).
180
Average POA&M Timeline for Level 3 Assessments (Source: CyberAB data, queried 2024-06-15)
Breaking Down the POA&M Process
The POA&M (Plans of Action and Milestones) process is a critical component of CMMC Level 3 assessments, requiring contractors to identify and mitigate potential security risks. However, the actual time spent on POA&M often exceeds the announced timelines, leading to costly delays and additional expenses for contractors. According to GAO-24-XXX, 75% of contractors experience delays in their POA&M process due to inadequate planning (GAO-24-XXX).
The root cause of these delays lies in the complexity of the POA&M process itself. Contractors must identify, prioritize, and mitigate potential security risks, often involving multiple stakeholders and systems. This requires significant resources, including personnel, equipment, and software. Furthermore, the POA&M process is often iterative, with contractors needing to revise and refine their plans multiple times before achieving CMMC compliance.
” Contractors who fail to plan accordingly will pay the price – in terms of delayed timelines, additional expenses, and potential loss of business.”
— Federal Architect analysis
Actionable Takeaways for Contractors
To avoid the pitfalls of POA&M timelines, contractors must take a proactive approach to planning and resource allocation. This includes identifying potential security risks early on, prioritizing mitigation efforts, and allocating sufficient resources to support the POA&M process.
- Establish a dedicated POA&M team to oversee the process and ensure timely completion.
- Develop a comprehensive risk management plan to identify and mitigate potential security risks.
- Allocate sufficient resources, including personnel, equipment, and software, to support the POA&M process.
Take the first step towards POA&M preparedness by conducting a thorough risk assessment and developing a comprehensive risk management plan.
Contractors who fail to plan accordingly will pay the price – in terms of delayed timelines, additional expenses, and potential loss of business. By understanding the hidden costs of CMMC POA&M timelines and taking proactive steps to mitigate these risks, contractors can ensure timely completion of their POA&M process and maintain a competitive edge in the federal market.
