Before implementing controls, you must know exactly what CUI your organization handles and where it goes. Our scoping engagement reviews your DoD contracts and delivery orders to identify CUI marking requirements, maps the flow of CUI through your organization from receipt through processing, storage, transmission, and disposition, identifies every system, network, application, and service that touches CUI, and defines the CUI boundary that determines which systems fall within your NIST 800-171 compliance scope.

Proper scoping is the most impactful cost-reduction strategy in DFARS compliance. By clearly defining and minimizing your CUI boundary through network segmentation, enclave architectures, and process redesign, we reduce the number of systems requiring full NIST 800-171 compliance — often saving organizations hundreds of thousands of dollars in implementation and ongoing maintenance costs.

Deliverables include a CUI data flow diagram, system boundary documentation, asset inventory within scope, and a boundary justification document suitable for assessor review.

We assess your organization against all 110 NIST 800-171 security requirements using the DoD Assessment Methodology. Every requirement is evaluated as Met, Not Met, or Not Applicable, with detailed findings documenting how each requirement is satisfied or what gaps exist. The assessment produces a SPRS score that accurately reflects your current compliance posture.

Assessment deliverables include a System Security Plan (SSP) documenting your implementation of each requirement, a Plan of Action and Milestones (POA&M) with specific remediation tasks, timelines, and resource requirements, a SPRS score calculation with supporting justification, and a risk-prioritized remediation roadmap. For organizations that have previously submitted SPRS scores, we identify any discrepancies between reported scores and actual compliance status — critical for avoiding False Claims Act exposure.

Our assessment methodology aligns with the CMMC Assessment Guide so your SSP, POA&M, and evidence packages are ready for C3PAO review when CMMC certification is required.

Our engineering team implements the technical controls required to close NIST 800-171 gaps identified during assessment. This includes network segmentation and CUI enclave architecture, FIPS 140-2 validated encryption for CUI at rest and in transit, multi-factor authentication for all CUI system access, endpoint detection and response deployment, SIEM implementation for audit log collection and analysis, vulnerability scanning and patch management programs, DNS filtering and web content controls, mobile device management and removable media controls, and secure configuration baselines aligned to CIS benchmarks.

We design solutions that balance security requirements with operational practicality. Your staff needs to do their jobs without security controls creating impossible workflows. Our implementations are tested in your environment, documented thoroughly, and include staff training so people understand both the what and the why behind each control.

For organizations that lack internal IT infrastructure, we provide managed IT services and managed cybersecurity that satisfy DFARS requirements as a fully outsourced solution.

DFARS compliance requires extensive documentation beyond technical controls. Assessors expect written policies and procedures for every NIST 800-171 control family, and those documents must reflect your actual operations, not generic templates downloaded from the internet. We develop custom documentation packages that include an Information Security Policy covering all 14 control families, individual procedures for access control, incident response, configuration management, media protection, and every other control area, a System Security Plan that accurately describes your system architecture and control implementation, and role-based training materials tailored to your organization.

Every document is written specifically for your organization, reflecting your actual systems, processes, and personnel structure. Generic templates fail during assessments because assessors immediately recognize boilerplate language that does not match the organization sitting in front of them. Our documentation passes scrutiny because it describes your real operations.

DFARS 252.204-7012 requires contractors to report cyber incidents affecting covered defense information to the DoD Cyber Crime Center (DC3) within 72 hours. This is not a simple notification — it requires preserving forensic images of affected systems, conducting damage assessment, and cooperating with DoD investigation. Failure to report promptly can result in contract termination and False Claims Act liability.

We develop and test incident response plans specific to DFARS requirements, including detection and initial assessment procedures, evidence preservation and forensic imaging protocols, DC3 reporting procedures and templates, damage assessment methodology, media preservation requirements (90-day retention), coordination protocols with prime contractors and DoD contracting officers, and subcontractor incident notification procedures.

Annual tabletop exercises ensure your team can execute the incident response plan under pressure. We simulate realistic scenarios based on current threat intelligence and evaluate your team's ability to detect, contain, report, and recover from cyber incidents within DFARS timelines.

DFARS cybersecurity requirements flow down to every subcontractor that handles CUI. As a prime contractor, you are responsible for ensuring your subcontractors meet the same NIST 800-171 requirements you do. This creates significant supply chain risk — your compliance can be undermined by a subcontractor who claims compliance but has not actually implemented the controls.

Petronella Technology Group, Inc. helps prime contractors manage supply chain compliance through subcontractor assessment programs, contract language development for DFARS flow-down, SPRS score verification procedures, risk-based subcontractor monitoring, and incident notification chain establishment. We also help subcontractors understand and meet their DFARS obligations, whether they flow from a prime contract or from a subcontract further down the supply chain.

For organizations that serve as both primes and subcontractors, we build integrated compliance programs that satisfy obligations in both directions simultaneously.