You can do everything right throughout the CMMC process and still face a few unexpected checkpoints at the finish line. Final validation isn’t just about ticking off requirements—it’s about proving that your security practices hold up under scrutiny. To help contractors stay sharp, here’s a look at the final elements that matter most in a CMMC Level 2 Certification Assessment—the kind that can make or break your compliance journey.
Confirmation That All 110 NIST 800‑171 Controls Are Marked Met or Not Applicable
Before an assessment is considered complete, all 110 NIST SP 800‑171 controls must be clearly marked as either Met or Not Applicable. No control can be left in limbo. A certified assessor reviews every item to confirm technical safeguards are in place, implemented correctly, and function as intended. This isn’t just about checking off a list—it’s about validating the integrity of your security implementation in real time.
Many defense contractors miss that “Not Applicable” is not a free pass. Each exemption needs supporting rationale backed by system architecture or business operations. The assessor evaluates whether the justification aligns with CMMC guidance, not just organizational preference. A good CMMC consulting team will ensure each control’s status holds up to CAP scrutiny—an essential detail emphasized in every reliable CMMC assessment guide.
Review and Closure of All Poa&M Items Within the 180‑Day Remediation Window
If your assessment resulted in a Plan of Actions and Milestones (Poa&M), all items must be closed out within 180 days—no exceptions. The assessor re-examines each remediation activity to confirm controls now meet compliance standards. Controls tied to open Poa&M actions cannot remain unresolved if they’re not permitted on the Poa&M list under CMMC rules.
Contractors often overlook that not every control can be placed on a Poa&M to begin with. CMMC Level 2 Certification Assessment guidelines allow only a subset of controls to be temporarily remediated. If an organization incorrectly includes prohibited controls on the Poa&M, they risk immediate disqualification from certification. It’s why CMMC consulting professionals are critical during this window—they help determine what’s fixable, what’s not, and how to document it for a successful re-validation.
Verification of Perfect Scoring on the 215-Question Test Tied to Non-POA&M Controls
The assessor must ensure a full score on the 215-question test that reflects all applicable controls minus any allowed Poa&M exclusions. This is the final technical litmus test. Any “No” answers outside the Poa&M framework can disqualify a company from achieving certification.
This part of the process leaves no margin for error. If even one unapproved control is not met, it will drop the score below the required threshold. Experienced C3PAOs run parallel evaluations during the CMMC Level 2 Assessment to make sure every response is defensible. The assessment team compares live interviews, evidence, and system behavior against each answer to validate consistency.
Validation of Final SPRS Submission Reflecting Compliant Status
Once technical compliance is confirmed, the organization must submit the correct data to the Supplier Performance Risk System (SPRS). This system is how the DoD tracks and verifies compliance posture. The submission must match assessment results precisely—no inflated scores or misrepresented controls.
SPRS plays a bigger role than people assume. It’s often the first thing prime contractors and DoD buyers check before awarding contracts. Incorrect or outdated entries can lead to flagging, disqualification, or worse—false claims allegations. That’s why part of the CMMC Certification Assessment process includes validating the data pipeline from assessment to SPRS submission.
Ensuring the Authorized Certifying Official Signs off and the Certificate Is Issued
No certification is official until the Authorized Certifying Official (ACO) reviews the full report and signs off. This person isn’t part of the assessor team—they provide an independent review, ensuring there are no overlooked discrepancies or conflicts of interest.
The ACO acts as the last line of defense before a certificate is issued. They analyze whether the assessment followed proper procedures, whether evidence holds up, and if exceptions are justified. Without this final green light, the certification doesn’t move forward. The presence of this checkpoint underscores the integrity built into the CMMC assessment guide.
Confirmation That Evidence Aligns with Documented System Security Plan and Threat Scenarios
Evidence without context doesn’t work. It has to reflect what’s documented in the System Security Plan (SSP), including how the environment handles current and future threat vectors. Assessors validate that what’s seen in live demonstrations aligns exactly with the written SSP.
This match-up is where technical accuracy and storytelling meet. A strong SSP doesn’t just describe tools—it maps how controls are deployed against threat scenarios unique to that environment. Assessors will challenge vague language and insist on concrete proof, especially during a CMMC Level 2 Certification Assessment. Organizations that rehearse evidence alignment with their SSP tend to avoid last-minute contradictions.
Quality Assurance Review to Verify Consistency with the CMMC Assessment Process (Cap)
The final validation phase includes a Quality Assurance (QA) check through the Cyber-AB’s CMMC Assessment Process (CAP). This is a procedural review that ensures the C3PAO conducted the assessment in accordance with approved methodology and that documentation supports every scoring decision.
CAP-based QA confirms the assessment wasn’t rushed, biased, or incomplete. It checks for consistency in how evidence was interpreted and whether the proper documentation trail exists. If anything is flagged, it can delay the certification. That’s why CMMC consulting services with firsthand CAP experience are valuable—they understand the format and flow needed for clean approvals under CAP scrutiny.