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Approach · The Federal CUI Security Factory

Every engagement runs the same four stations.

Big consultancies bill you while they learn your environment. The Factory is a fixed production line that we ran on our own environment first. It builds one operational control system, and the output can be CMMC, agency authorization, or independent assessment.

Why a production line beats a project

Compliance consulting tends to fail in two familiar ways. Big firms bill discovery by the hour, reinvent the approach for each client, and staff delivery through the pyramid. Generic MSPs retrofit commercial tooling to a federal problem and let a policy binder stand in for implementation. Either way, you pay again at assessment time.

The Factory is a fixed sequence with fixed quality gates, run by the practitioners who scoped, built, and defended inDirectIT's own CMMC Level 2 environment under 32 CFR Part 170. We put your environment through it and deliver what your contracts require: a C3PAO-ready CMMC package, an agency authorization package, or an assessment-ready 800-171 program. The method already exists, so you don't pay us to invent it.

The four stations

Station 01

Scope & Assess

Define the CUI boundary, map data flows, and score all 110 controls against the DoD Assessment Methodology. We fix the boundary before setting a budget, because scope is where certifications are won or lost. Discovery finds the defensible boundary, which depends on your data flows and security dependencies.

IN → CONTRACTS · DATA FLOWS · CURRENT STACKOUT → SPRS SCORE + GAP REGISTER + BOUNDARY DOC
Station 02

Architect

Design the target state across all six Microsoft security planes, in GCC High or an enclave: Entra ID, Intune baselines, Purview CUI labeling and DLP, Defender, WDAC, audit and logging.

IN → GAP REGISTER + BOUNDARY DOCOUT → TARGET ARCHITECTURE + MIGRATION PLAN
Station 03

Implement & Document

Deploy and harden while the SSP, policies, and POA&M are written against the live configuration. We write the documentation from the running environment, so it describes what is deployed.

IN → TARGET ARCHITECTUREOUT → HARDENED TENANT + SSP + POA&M + POLICY SET
Station 04

Evidence & Sustain

Collect evidence at the assessment-objective level, run a mock assessment as the release gate, then operate under managed compliance so the certification still holds in year two.

IN → HARDENED TENANT + DOCUMENTATIONOUT → C3PAO-READY PACKAGE + SUSTAINMENT

One production line serves several assurance lanes.

The stations stay the same and the destination changes. We aim each run of the line at the verification mechanism your customer uses:

Common production lineCustomer-specific outcome
SCOPE CUI & SYSTEM BOUNDARIESDoD, GSA, NASA, DOE, DOJ/FBI contract scope
ARCHITECT & IMPLEMENT CONTROLSRev. 2, Rev. 3, agency ODPs and overlays
DEVELOP SSP & EVIDENCEAgency authorization or assessment package
VALIDATE VIA ASSESSMENT PROCEDURESCMMC, 800-171A, government or independent assessment
SUSTAIN CONTINUOUSLYEvidence refresh, control validation, POA&M and risk management

The quality system behind it

Tested on us first, then on a client

inDirectIT's own SSP, POA&M, evidence package, and GCC High tenant were assessed under CMMC Level 2 (32 CFR Part 170), with objective-level evidence for the assessed boundary. In June 2026, Allyon ran the same production line to its own CMMC Level 2 certification. CMMC proved the delivery model, and we apply it across the larger NIST 800-171 and federal CUI market we serve.

How this compares

Most contractors weigh this decision against two alternatives. Both of them cost you twice: once during the engagement and again at assessment time.

DimensionBig ConsultanciesGeneric MSPsinDirectIT
WHO DELIVERSPyramid staffing: partners sell, juniors deliverWhoever is on the help desk this quarterThe practitioners who scoped, built, and defended our own CMMC Level 2 environment
METHODDiscovery billed by the hour, approach reinvented per clientCommercial-tenant tooling retrofitted to a federal problemFixed Factory runbook, GCC High native, with the same sequence on every engagement
DOCUMENTATIONTemplate SSPs written before the environment existsPolicy PDFs on a shelf, untested against objectivesSSP written from live configuration; evidence collected at the assessment-objective level
PROOFReferences and slidewareVendor badgesCMMC Level 2 (32 CFR Part 170), held, operated, and renewed in our own tenant
ECONOMICSOpen-ended meter; change orders compoundFlat fee, thin scope; gaps surface at assessmentFixed-scope phases with a mock-assessment gate, then managed sustainment

Portfolio mode

Running a portfolio? For private-equity firms with defense-exposed holdings, we run the same production line across the portfolio with one runbook, one evidence standard, and one reporting view, so five portfolio companies don't each buy a different compliance program. Book a portfolio briefing →

Questions about the model

Why call it a 'factory'? Compliance isn't manufacturing.

The common failure in compliance consulting is treating every engagement as a bespoke project, so the firm rediscovers, redesigns, and relearns on your budget. A production line keeps the sequence, tooling, and quality gates fixed and changes only the environment going through it. Because the process is fixed, the certification result can be repeated.

Is the Factory only for CMMC?

No. We proved the model on CMMC, first on our own environment and then on Allyon's certification, but the production line builds and operates NIST SP 800-171 environments in general. The final station changes with the customer: a CMMC assessment (self or C3PAO) for DoD work, an authorization package for GSA, or agreement-specific demonstrations for NASA or DOE. See agency lanes.

How long does the Factory take end to end?

Once scope is defined, the technical baseline is a 12 to 14 week build, because the playbook, templates, and evidence structures already exist. Station 01 (scope and assess) comes first and typically runs 4 to 6 weeks as a fixed-scope engagement. Sustainment then runs continuously.

What is 'objective-level evidence' and why does it matter?

Each of the 110 controls breaks down into assessment objectives, roughly 320 across the framework, and a C3PAO tests at that level. An assessor can use evidence collected per objective as it stands. If your evidence is organized by policy binder instead, the assessor will have you redo it.

What happens if we fail the mock assessment?

Then the gate did its job. Findings from the internal mock assessment go back into remediation before anything goes to a C3PAO, so the surprises happen on our clock instead of during your certification window.

Run the line

Put your environment on the production line.

Tell us where you are and a practitioner will map your entry station, timeline, and fixed scope. You can also email rj@indirectit.com directly.