According to the CMMC Model and Assessment Guides, specifically the rules governing Plan of Action and Milestones (POA & M) and the remediation period, an Organization Seeking Certification (OSC) is allowed a limited opportunity to remediate certain "Not Met" practices to achieve a "Met" status without failing the assessment entirely.
Here is the breakdown based on CMMC Ecosystem protocols:
The 180-Day POA & M Rule: CMMC Level 2 allows for the use of POA & Ms for specific practices, provided they are not high-priority items (typically 5-point values in the scoring methodology). If an OSC has "Not Met" practices that are eligible for a POA & M, they have up to 180 days to remediate them.
The Remediation Period (Assessment Closeout): During the assessment process itself, there is a "remediation period" (often referred to within the 1-90 day window depending on the specific C3PAO methodology and the CMMC assessment process) where an OSC can fix minor issues identified by the assessor before the final report is submitted.
Eligibility Criteria: The question states there are 15 practices "Not Met." While this is a high number, the CMMC rule does not automatically disqualify an OSC based solely on thequantityof practices, but rather thetype(weight) of the practices and the resulting score. To be eligible for a conditional "Met" (via POA & M), the OSC must achieve a minimum score (often 80% of the total points) and none of the "Not Met" practices can be those designated as mandatory "Met" (no POA & M allowed) in the CMMC rule.
Why "C" is correct: Because we do not know the specific weights of the 15 "Not Met" practices or the total score, we cannot definitively say theywillbe remediated (A) or that they areineligible(B). However, under the CMMC assessment framework, the OSC may be eligible to enter a remediation phase or utilize a POA & M to bridge the gap, provided they meet the scoring threshold and the specific practices allow for it.
Reference Documents:
CMMC Assessment Process (CAP): Defines the phases of assessment including the "Remediation Period."
32 CFR Part 170 (CMMC Program Rule): Outlines the specific requirements for POA & Ms, the 180-day timeline, and the scoring parameters required to be eligible for a Conditional Certification.
Submit