Maturing a Compliance Program for an Unexpected DIBCAC Assessment
A DoD prime contractor's business unit faced a surprise DIBCAC assessment with only one month to prepare — and inherited controls that didn't meet CMMC standards. 112Cyber stepped in with full-spectrum consulting to close the gap.
Setting the Scene
In 2024, the False Claims Act began illuminating multiple organizational failures among large government contractors, prompting the DIBCAC to take action. This initiative resulted in several prime contractors — many of whom had already self-assessed their environments — receiving last-minute DIBCAC assessments with extremely short turnaround times.
A business unit within a prime Department of Defense (DoD) contractor faced an unexpected assessment under a tight deadline. Initially, the unit believed it would inherit policies, documentation, and controls from its fully compliant parent company. However, it quickly became clear that this was not the case.
Although the organization had been compliant at one point, compliance maturity had not been maintained as an ongoing effort aligned with the needs of its specialized business units. This resulted in security gaps, improperly scoped Controlled Unclassified Information (CUI), and a team overwhelmed by the scale of remediation required.
With significant financial penalties and future contract opportunities at risk, the organization quickly took initiative by engaging in a full-spectrum consulting effort.
What This Case Study Demonstrates
An Inherited Program That Didn't Fit
The business unit had approximately one month to prepare for an official DIBCAC assessment. While its compliance team had been maintaining the program at a basic level, it was not optimized for the rigor of a formal assessment. The primary issue was that compliance had not been treated as an ongoing objective.
Additionally, the frameworks in place were largely inherited from the parent company's internal compliance requirements. While the parent company adhered to broader NIST requirements, those controls did not sufficiently address the business unit's specific operations. As a result, the unit required a more tailored and precise approach aligned with CMMC requirements.
At a high level, a parent company might require that all doors be secured in some capacity. However, CMMC requirements may mandate more specific controls, such as closed-circuit television (CCTV) systems or badge access readers. This gap leaves business units in a position where inherited controls are not prescriptive enough to meet CMMC standards.
It quickly became clear that meeting the assessment deadline would require a dedicated, focused effort. Although the compliance program owner was an experienced IT Security Manager, they lacked direct experience with full-scale compliance readiness. As a result, the organization chose to engage a third-party consulting team.
Full-Spectrum Consulting Under Pressure
112Cyber consultants began by establishing a structured workflow, initiating daily multi-hour, multi-session engagements to meet the organization's assessment deadline. By coordinating across multiple internal teams, consultants were able to concurrently conduct administrative interviews and evidence collection while performing critical investigative services.
CUI Data Mapping
Extensive CUI data mapping was conducted to identify where CUI resided within the business unit's environment. This included personnel interviews, analysis of the operating environment, development of data flow diagrams to track CUI movement, creation of system boundary diagrams, and asset categorization aligned with the CMMC scoping guide.
Security Gap Assessment
Consultants performed a comprehensive gap assessment against NIST SP 800-171 requirements. This resulted in a detailed report highlighting areas requiring remediation, along with a preliminary SPRS score that served as a roadmap for improvement.
Remediation Services
A targeted remediation plan was developed to prepare the organization for its fast-approaching assessment. This plan identified responsible stakeholders for each gap and guided them through remediation activities. Execution involved daily working sessions with internal teams, ensuring a coordinated and efficient effort to meet the deadline.
Confidence, Clarity, and Long-Term Capability
The most significant outcome of this engagement was increased confidence. The IT Security Manager initially felt overwhelmed by both the expedited timeline and the complexity of preparing the compliance environment. Through the engagement, the team gained clarity, direction, and assurance in their ability to mature the program successfully.
Working alongside a team of Certified CMMC Assessors also established trust and credibility. Beyond preparing the organization for the immediate DIBCAC assessment, the engagement enabled meaningful knowledge transfer.
Internal compliance stakeholders gained a clearer understanding of assessor expectations and best practices, positioning them to sustain ongoing compliance and confidently approach future assessments.