Home Approach

Approach · The Federal CUI Security Factory

One runbook. Four stations. Zero improvisation.

Big consultancies bill you while they learn your environment. The Factory is the opposite bet: a fixed production line we ran on our own environment first, now aimed at every federal assurance outcome — one operational control system; CMMC, agency authorization, or independent assessment as the output.

Why a production line beats a project

Compliance consulting fails in two familiar ways. The big-firm way: discovery billed by the hour, approach reinvented per client, delivery staffed by the pyramid. The generic-MSP way: commercial tooling retrofitted to a federal problem, with a policy binder standing in for implementation. Both cost you again at assessment time.

The Factory is a third way: 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. Your environment is the input. The output is whatever your contracts require: a C3PAO-ready CMMC package, an agency authorization package, or an assessment-ready 800-171 program. Nothing about the method is invented on your budget.

The four stations

Station 01

Scope & Assess

Define the CUI boundary, map data flows, score all 110 controls against the DoD Assessment Methodology. No boundary, no budget — scope is where certifications are won or lost. Discovery identifies the defensible boundary; the result depends on 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. Documentation is produced from the environment — never before it, never instead of it.

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 survives year two, not just assessment day.

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

One production line. Multiple assurance lanes.

The stations don't change; the destination does. Each run of the line is aimed at the verification mechanism your customer actually 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

Proven twice before it reaches you

First on ourselves: 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. Then on a client: in June 2026, Allyon ran the same production line to its own CMMC Level 2 certification. CMMC proved our delivery model. NIST 800-171 and federal CUI security define the larger market we serve.

How this compares

The same decision laid out against the two alternatives most contractors weigh it against. Both of the others 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, same sequence 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, the same production line runs across the portfolio: one runbook, one evidence standard, one reporting view — instead of five portfolio companies buying five inconsistent compliance programs. Book a portfolio briefing →

Questions about the model

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

Because the failure mode of compliance consulting is treating every engagement as a bespoke project — re-discovering, re-designing, re-learning on your budget. A production line inverts that: fixed sequence, fixed tooling, fixed quality gates, with your environment as the input. The certification is repeatable because the process is.

Is the Factory only for CMMC?

No. CMMC is where the model was proven — on our own environment, then on Allyon's certification — but the production line itself builds and operates NIST SP 800-171 environments. The output station changes per customer: a C3PAO assessment for DoD work, an authorization package for GSA, agreement-specific demonstrations for NASA or DOE. Same line, different final inspection. See agency lanes.

How long does the Factory take end to end?

The technical baseline is a 12–14 week build once scope is defined — because the playbook, templates, and evidence structures already exist. Station 01 (scope and assess) typically runs 4–6 weeks as a fixed-scope engagement in front of it. Sustainment then runs continuously.

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

Each of the 110 controls decomposes into assessment objectives — roughly 320 across the framework — and a C3PAO tests at that level, not at the level of control titles. Evidence collected per objective is evidence an assessor can actually use. Evidence organized by policy binder is homework the assessor makes you redo.

What happens if we fail the mock assessment?

That's the gate working. Findings from the internal mock assessment go back into remediation before anything ships to a C3PAO — the whole point is that surprises happen on our clock, not 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. Or email rj@indirectit.com directly.