Virtual CISO

A vCISO for government contractors

CMMC 2.0 requirements are flowing down from primes into subcontracts, and they arrive as documentation demands: an honest self-assessment, a System Security Plan, a remediation plan with dates. Agency’s vCISO for government contractors builds and maintains that stack — U.S.-based forward-deployed engineers, supercharged by proprietary AI doing the work, a named security leader accountable for it.

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Last updated July 26, 2026

The flow-down finally arrived

For years, defense-supply-chain security ran on self-attestation: check the box in the contract file, keep a policy binder somewhere findable. That era is ending. Primes are pushing CMMC 2.0 requirements into new awards and down through their subcontract chains — the pace varies by program, but the direction doesn’t. The question has changed from “do you have a security policy” to “show us your System Security Plan and your current self-assessment.”

For a small or mid-size contractor, that’s an enterprise-grade obligation landing on a team with no security department. The requirements assume someone owns scoping, documentation, remediation, and the assessment itself — a role that’s a fraction of a job in workload but an executive’s worth of accountability. Which is exactly the shape a fractional CISO is built for.

Agency pairs the named leader with engineers who produce the artifacts assessors actually read — people who’ve internalized that in this world, the documentation isn’t paperwork about the program. It is the program.

The documentation a defense contract expects

Spelled out, because the acronyms hide how much writing is involved.

System Security Plan

The SSP: how your environment meets each NIST 800-171 requirement, written against your real systems. Assessors read it first and test everything else against it, so honesty beats polish.

Plan of Action and Milestones

The POA&M: every gap, with an owner, a remediation approach, and a date — maintained as a living document, because a stale one reads as an admission that nobody is driving.

CUI scoping and handling

Where Controlled Unclassified Information enters, where it’s stored and marked, who can touch it — and how to shrink that boundary, since every system pulled out of scope is work you never do again.

The self-assessment

Your NIST 800-171 self-assessment, scored honestly and kept current — the number your primes can check, and the one you least want to be creative with.

Incident-reporting readiness

Defense contracts carry rapid-reporting obligations when incidents touch covered systems — so the plan, the contacts, and the evidence trail have to exist before anything happens.

Subcontractor flow-down

If you have subs of your own, the obligations keep flowing: their assessments and agreements become part of your file, reviewed like the supply-chain risk they are.

NIST 800-171, CMMC 2.0, or FedRAMP — which one is yours?

Three regimes get conflated constantly. NIST 800-171 is the control set: it applies when Controlled Unclassified Information touches your systems under a covered contract, and it’s what you self-assess against today. CMMC 2.0 is the verification layer on top — levels tiered to the sensitivity of what you handle, with third-party assessment entering the picture as requirements phase in. If you hold CUI, this pair is your track.

FedRAMP is a different track entirely: it governs cloud services sold to federal agencies, it’s an authorization rather than a certification, and it’s a substantially heavier lift that only makes sense with agency demand in hand. Plenty of contractors eventually need both tracks — in which case running them on a common control map is the only sane approach. A vCISO’s first deliverable is often just this: which regime, which level, in what order, and what your contract clauses actually obligate you to.

From flow-down letter to assessment-ready

Scope the CUI

Find where Controlled Unclassified Information actually lives and flows, then shrink the boundary — enclaves and segmentation turn a company-wide problem into a contained one.
Assess honestly

A gap assessment against NIST 800-171 and a self-assessment score you’d defend to an assessor. An accurate low score with a credible plan beats an optimistic one you can’t support.
Remediate and write in parallel

Controls implemented while the System Security Plan is drafted against reality — not documentation sprinted at the end, when memory and evidence have both degraded.
Hold the line

POA&M items driven to closure on their dates, evidence organized for assessment, and a mock run before the real one — then steady-state operation, so next year is maintenance instead of a rebuild.

Rigor you can inspect

Assessment-driven programs reward a specific temperament: documentation-first, evidence-always, no improvisation. The best public proof that Agency operates that way is CloudCover, an IT services company whose ISO 27001 audit closed with zero findings — a different framework, the same discipline defense assessors look for. Outcomes like that come from running the program all year, not from heroics in assessment week.

If your revenue includes federal work — prime or sub, defense or civilian — the security program has to serve the contract file first. That’s the specialty of Agency’s government practice, alongside aerospace and aviation, where the same flow-downs dominate. And if the trigger was a letter from your prime: the right time to start was before the letter, and the second-best time is this quarter.

Frequently asked questions

Which CMMC level does our company actually need?

Your contracts decide, not your ambitions. The level tracks what information you handle — Federal Contract Information at the low end, Controlled Unclassified Information above it — and the specific clauses your primes flow down. Reading those clauses against your data flows is step one of any engagement; guessing a level and building toward it is how contractors buy the wrong program.

Is a self-assessment enough, or do we need a third-party CMMC assessment?

It depends on your level and your contracts — lower tiers run on self-assessment, higher tiers bring third-party assessment as CMMC phases in. The constant across all of them: the score you submit must be defensible, because primes can see it and assessors can test it. An inflated score is a liability, not a shortcut.

Who should write our System Security Plan?

Someone who knows both your environment and the framework — which is why bought templates fail. An SSP describing controls you don’t run is worse than a gap, because assessors test against it. Agency’s engineers write yours from your actual systems and keep it synchronized as the environment changes.

We sell software to federal agencies. Is that CMMC or FedRAMP?

Selling cloud software to agencies is FedRAMP territory; CMMC governs how you handle defense information inside your own environment as a contractor. Some companies genuinely need both — SaaS sold to agencies plus CUI under defense contracts — and the move is one control foundation mapped to both, never two parallel programs.

For the contract file

CMMC 2.0 FedRAMP Government Aerospace & Aviation CMMC Compliance Guide

Turn the flow-down letter into a plan

Send us the clauses your prime flagged; we’ll map the scope, the honest score, and the shortest path to assessment-ready. Top-ranked Vanta & Drata partner · 1,000+ companies served since 2021 · 4.9/5 on G2.