Current implementation context. The Department suspended Phase II in July 2026 and says implementation is paused in Phase 1. This guide explains the codified model and preparation workflow. Confirm the pathway required by your actual procurement. Read the current policy briefing.

A planning tool is not automatic permission

Teams often use a gap list or operational remediation plan to track unfinished work. A CMMC Plan of Action and Milestones associated with conditional status has a specific meaning under the rule. Calling an internal list a POA&M does not make the organization eligible to pass an assessment with those items open.

Level 1 does not permit a POA&M

For Level 1 self-assessment, a POA&M is not permitted. All required safeguards must be met to achieve the relevant status. Use a working remediation list before the assessment to assign fixes and collect proof of completion. Do not present that list as a conditional Level 1 approval.

Level 2 and Level 3 have restrictions

Conditional status requires satisfaction of the relevant score threshold and restrictions on which requirements may remain open. Certain requirements cannot be included on a POA&M. Review the full text of 32 CFR 170.21 rather than assuming any score above a threshold is sufficient. Level 2 and Level 3 restrictions differ.

Closeout has a deadline and an assessment path

The conditional pathway requires remediation and the appropriate closeout assessment within 180 days of the conditional status date. An internal task marked complete does not by itself complete that closeout. Track owners, dependencies, evidence, assessor coordination, and the official record needed for the final outcome.

Put the work in a usable structure. CMMC Pulsar can help organize scope, controls, evidence, and documentation. Federal Bid Partners can help define a readiness engagement suited to the environment and required pathway.