POA&M closeout · Aerospace enclave · Rule pack 2026.06.0
POA&M closeout
Explain rule
The closeout deadline is calculated from the customer-recorded Conditional status event. Continuity does not create the external closeout result.
- Date basis
- Conditional CMMC Status Date recorded as 2026-02-07.
- Formula
- Add 180 calendar days to the Conditional status date.
- Rule pack
- 2026.06.0
- Sources
- 32 CFR part 170; 48 CFR DFARS CMMC acquisition rule
Consequence summary
Conditional status is current and the closeout window remains open. Track remediation and prepare for external closeout before the deadline.
Projection
- State
- open
- Days remaining
- 42
- External closeout
- Required before Final status can be recorded
- POA&M items
- 1 of 3 items are internally validated; 2 still need validation before external closeout preparation.
Internal validation boundary
Validated POA&M items support readiness for closeout. They do not change the credential projection to Final without a recorded external closeout result.
POA&M items
Items are grouped by remediation and validation state. Open each item to review its milestones, safe evidence references, and closeout preparation boundary.
External result boundary
Internal validation supports closeout readiness. It does not create Final status, and it does not replace the external closeout result.
| Requirement | Work item | State | Owner | Target | Milestones |
|---|---|---|---|---|---|
| AC.L2-3.1.12 | MFA coverage for privileged admin path | Internal validation | Mira Patel | 2026-07-10 | 2 of 3 milestones completed. |
| CM.L2-3.4.6 | Configuration review evidence reference | Remediation complete | Jamal Coleman | 2026-07-16 | 1 of 2 milestones completed. |
| IR.L2-3.6.2 | Incident response exercise record | Validated internally | A. Reyes | 2026-06-18 | 2 of 2 milestones completed. |
Milestone workflow
Milestones show the work needed before a closeout packet can be prepared without storing raw evidence in Continuity.
| Requirement | Milestone | State | Owner | Due |
|---|---|---|---|---|
| AC.L2-3.1.12 | Procedure update | completed | Mira Patel | 2026-06-10 |
| AC.L2-3.1.12 | Coverage check | completed | Jamal Coleman | 2026-06-20 |
| AC.L2-3.1.12 | Internal validation | in progress | A. Reyes | 2026-07-10 |
| CM.L2-3.4.6 | Register refresh | completed | Jamal Coleman | 2026-07-01 |
| CM.L2-3.4.6 | Reference review | open | A. Reyes | 2026-07-16 |
| IR.L2-3.6.2 | Summary reference | completed | A. Reyes | 2026-06-12 |
| IR.L2-3.6.2 | Owner validation | completed | Mira Patel | 2026-06-18 |
Conditional-to-Final guardrails
The backend result command records the external closeout outcome and credential projection together so the item state and credential wallet cannot diverge.
External success
- POA&M item state
- Externally closed
- Credential projection
- final_recorded
- Status event
- Final status recorded with source provenance
Expiry or failed closeout
- Expired projection
- expired
- External failure
- Records adverse result, not Final status
- Next action
- Record contract impact and start a recovery or reassessment path.
Closeout path
External closeout preparation stays separate from product-issued status.
Conditional status recorded
Customer-recorded C3PAO source created the Conditional credential projection.
A. Reyes
Internal validation target
All open POA&M items should be validated before the closeout packet is sent.
Program owner
External closeout readiness review
Confirm C3PAO schedule, packet references, and no raw CUI in Continuity.
Assessment coordinator
180-day closeout limit
Final status requires a recorded external closeout result with source provenance.
Rule pack 2026.06.0
Next closeout decision
Source: customer-recorded status event and active deadline rule.
Keep remediation moving and schedule external closeout before the deadline. 42 days remain before the Conditional closeout deadline. Official records and the assessor closeout result control over this planning projection.
Unresolved items
- Two internal validations remain open.
- External closeout schedule has not been confirmed.
- Linked contract option review depends on the result timing.