In CMMC v2.0, the closeout activity for remediating previously unmet requirements is handled through the POA & M closeout process described in the CMMC Assessment Process (CAP) v2.0 . CAP v2.0 makes clear that the C3PAO must follow DoD’s POA & M closeout procedures and that the Assessment Team performs the closeout work, with the assessment results then undergoing a required quality assurance (QA) review .

Operationally, the person who must ensure that each previously failed requirement is adequately addressed during the closeout assessment is the Lead Assessor (Lead CCA) , because the Lead CCA is the individual designated to oversee and manage the Assessment Team on behalf of the C3PAO for the conduct of the certification assessment. In other words, while team members may test controls and collect evidence, the Lead CCA is accountable for directing the assessment effort and ensuring that remediation evidence supports updated determinations.

CAP v2.0 also states that a QA individual performs a quality assurance review of the POA & M closeout “upon completion by the Assessment Team,” including checks on the accuracy and completeness of evaluation of POA & M security requirements before upload to eMASS. This reinforces that verification occurs through the assessment team’s work, led by the Lead Assessor , and then independently quality-checked by QA.

===========