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CMMC Compliance Services for Small Manufacturers

Defense work now comes with a cybersecurity requirement attached. ACS gets small manufacturers and other DoD suppliers ready for CMMC Level 1 and Level 2: scoping, gap assessment, SPRS score, System Security Plan and the remediation to close the gaps. Based in Traverse City, serving Michigan, Chicagoland and Central Florida.

If you machine parts, weld assemblies or build subsystems that end up in something the Department of Defense buys, a prime has probably already asked about your cybersecurity. The Cybersecurity Maturity Model Certification (CMMC) turns that question into a contract requirement, and the answer has to be backed by evidence, a written System Security Plan and a score your prime can look up.

ACS has supported manufacturers in Northern Michigan for more than two decades. We built a CMMC readiness practice because our own clients needed one, and we built it the way we run everything else: documented, measured and evidence-driven, so the score you report is one you can defend.

Who this is for

  • Subcontractors with DoD work in the pipeline. Your prime has sent a flowdown letter, a supplier questionnaire or a contract clause (DFARS 252.204-7012, 252.204-7021 or the FAR basic safeguarding clause) and wants to know your status.
  • Shops handling drawings and specs marked as controlled. If you receive Controlled Unclassified Information (CUI), you are in Level 2 territory whether you have 12 employees or 200.
  • Owners who want a straight answer before spending. Most of our conversations start with “what do we actually need, and what will it cost?” The scoping workshop exists to answer exactly that.

Level 1 or Level 2, in plain language

Level 1Level 2
Information coveredFederal Contract Information (FCI)Controlled Unclassified Information (CUI)
Requirements15 basic safeguarding requirements from the FAR110 requirements of NIST SP 800-171
How it is assessedAnnual self-assessmentSelf-assessment or a C3PAO certification assessment, as the contract specifies
Score reportedMet or not met for all 15A score out of 110, recorded in SPRS
Deferring gapsNot allowedA POA&M is allowed within limits; the System Security Plan can never be deferred
Who affirmsA senior official at your companyA senior official at your company

Which level applies is decided by the information, not by the company. Getting that determination right is the single most consequential step in the whole process, because it decides whether you are managing 15 requirements or 110.

How a CMMC engagement with ACS runs

1. Scoping workshop

Everything downstream is priced off this, so it comes first and it is fixed-fee. We spend a day on site with your contract signatory, the people who handle prints, a shop floor lead and whoever administers your prime’s portal. Nothing is graded. We map how government information arrives (portal downloads, email, physical prints, EDI), where it comes to rest (file shares, ERP, CAD, email, inspection records, the print rack at the machine) and who touches it.

The workshop delivers nine things:

  1. An information flow map for your company
  2. The FCI versus CUI determination, with the reasoning written down
  3. The assessment boundary
  4. Containment options, usually an enclave for the controlled information versus bringing the whole environment into scope, each with asset count, control burden, disruption and cost delta
  5. A shared services recommendation, including which of your existing tools stay and which have to change
  6. A System Security Plan outline
  7. A prioritized remediation roadmap
  8. A remediation budget range
  9. A findings presentation to your leadership

The containment decision is yours. We lay out the options with real numbers; we do not pick for you.

2. Gap assessment and score

Once the boundary is set, we assess every applicable requirement and its assessment objectives. Each finding records what was checked, how, when and by whom. Wherever one of our managed tools can supply the evidence (identity and MFA state from Microsoft 365, patch and encryption state from endpoint management) we pull it from the system rather than asking someone to remember. The result is a DoD Assessment Methodology score with provenance on every line.

3. System Security Plan and POA&M

The SSP is the document an assessor reads first and the one requirement that can never sit on a POA&M. We author it from the assessment, along with the Plan of Action and Milestones for whatever can lawfully be deferred.

4. Remediation

Gaps become phased projects sequenced by point value, by whether they may be deferred, by your contract deadline and by cost. Shared infrastructure work is split from site-specific work so sister companies are not billed twice. We track each project in our service desk, update the control status as work closes and recalculate the score as you go.

5. Self-assessment package and affirmation

When the score is where it needs to be, we assemble the package: final score, POA&M with credible completion dates, the SSP, the evidence index and an affirmation packet for your senior official. ACS advises and remediates. You attest, on your authority, because that is how the rule is written and because a false claim is a legal problem we will not set you up for.

6. Annual maintenance

CMMC is not a one-time project. We refresh evidence, run the POA&M countdown, watch for control drift as your environment changes and prepare each annual affirmation.

Why manufacturers work with ACS on CMMC

We are already inside the boundary, and we say so. Any managed IT provider whose monitoring, endpoint protection, backup or documentation tools touch your systems is an External Service Provider under the rule and part of your assessment. ACS runs its own environment through the same process we use for clients and gives you a customer responsibility matrix: which requirements we cover, which you cover, which are shared.

Evidence, not assertions. A questionnaire filled in from memory produces a score nobody can defend. Our findings pull from the systems themselves and carry source, method, date and assessor.

Fixed-fee scoping with a remediation credit. The workshop has a fixed price, quoted after a short discovery call. Half of it is credited toward remediation when you start that work with us within 90 days.

Sister companies handled correctly. Commonly owned entities each need their own assessment, score and affirmation. We model them separately, then test whether a shared architecture is defensible for both. You pay for one engagement, not two.

Twenty-plus years in manufacturing IT. We support production floors, CAD and CAM systems, ERP and the vendors around them every day. Read how we keep a Traverse City roll-forming and stamping shop running, and see our IT services for manufacturers.

What this service is not

  • ACS is not a C3PAO. We do not certify anyone and nothing we produce implies independent assessment authority. If your contract calls for a certification assessment, a C3PAO performs it, and we get you ready for it.
  • We do not sign your affirmation. Your named senior official does.
  • We do not guess at remediation cost. The workshop produces a budget range. The real number comes from the gap assessment.
  • We do not sell you a binder. A System Security Plan that does not match the environment is worse than none, because it is a written misstatement. Ours is generated from the assessment and kept current.

Where we work

ACS is headquartered in Traverse City and serves manufacturers across Northern Michigan, Grand Rapids and West Michigan, with teams in Chicagoland and Central Florida. The scoping workshop happens at your facility. Assessment, remediation and maintenance are a mix of on-site and remote work, and we take on remote engagements anywhere in the United States.

Start with a discovery call

Fifteen minutes to tell us what your prime has asked for and what information you handle. We will tell you whether you are looking at Level 1 or Level 2, what the workshop would cover for your company and what it costs. No pitch.

Book a discovery call or call 231-267-TECH (8324). You can also reach us through our contact page.

Already running managed IT with us? CMMC readiness builds on managed security, vulnerability management and security awareness training, so much of the groundwork may already be in place.

CMMC questions we hear from manufacturers

What is CMMC?

The Cybersecurity Maturity Model Certification is the Department of Defense program that checks whether contractors and subcontractors actually protect the government information they handle. It is written into federal regulation (32 CFR Part 170) and enforced through clauses in DoD contracts. Level 1 covers Federal Contract Information with 15 basic safeguarding requirements. Level 2 covers Controlled Unclassified Information with the 110 requirements of NIST SP 800-171.

Do we need Level 1 or Level 2?

It depends on what information you handle, not on your size. If you only receive Federal Contract Information (FCI), such as the contract itself and ordinary correspondence, Level 1 applies. If you receive or produce Controlled Unclassified Information (CUI), such as marked technical drawings or specifications, Level 2 applies. Your contract and your prime’s flowdown say which, and the first job of our scoping workshop is to confirm it from the documents and the information itself rather than from a guess.

What is an SPRS score?

The Supplier Performance Risk System is the DoD database where a Level 2 contractor records its NIST SP 800-171 self-assessment score. The score starts at 110 and loses one, three or five points for every requirement not met. Primes check it before they award work. We produce the score with evidence behind every line, and you record it.

Can we use a Plan of Action and Milestones instead of fixing everything first?

At Level 1, no: every one of the 15 requirements has to be met. At Level 2, a POA&M is allowed only when your score is already at least 80 percent of the total, and only for requirements worth one point, with a small number of named requirements that may never be deferred. Open items on a POA&M must be closed within 180 days. The System Security Plan itself can never be deferred.

Does our IT provider have to be compliant too?

If your IT provider’s tools see your systems, your provider is inside your assessment. Remote monitoring, endpoint protection, backups and documentation tools all hold what the rule calls Security Protection Data, which puts the provider in scope as an External Service Provider. ACS runs its own environment through the same process and hands every client a customer responsibility matrix that shows which requirements ACS covers and which stay with you.

How long does this take?

The scoping workshop takes about five hours of your staff’s time per facility, plus our preparation and analysis. Remediation depends on how many gaps the assessment finds and how many are quick fixes versus projects. You will have a phased roadmap with a budget range before any remediation starts, so the timeline is a decision you make with real numbers, not an estimate we guess at.

What does the scoping workshop cost?

It is a fixed fee quoted after a short discovery call, with no hourly billing. Half of the workshop fee is credited toward remediation when you start that work with ACS within 90 days. Commonly owned sister companies can be scoped together for a combined fee while staying separate for assessment, scoring and affirmation, which the rule requires.

Is ACS a certified assessor?

No, and we are careful about this. ACS is not a C3PAO (CMMC Third-Party Assessment Organization) and does not certify anyone. We prepare you, close the gaps and assemble the evidence. For a Level 2 self-assessment, your own senior official affirms the result. Where a contract requires third-party certification, a C3PAO performs that assessment and we make sure you walk in ready.

What is the difference between FCI and CUI?

Federal Contract Information is information provided by or generated for the government under a contract that is not intended for public release: the contract, purchase orders, delivery schedules. Controlled Unclassified Information is information the government says must be protected under law or policy, which for a machine shop usually means marked technical data such as drawings, specifications and export-controlled files. CUI triggers Level 2; FCI alone is Level 1.