Continuous Compliance

Keep your 800-171 program true between affirmations.

Ongoing program ownership for organizations that sign an annual affirmation and want it to hold every day of the year: when CUI flows shift, vendors change, environments evolve, and new requirements land.

The Pattern

The same drift shows up in almost every program.

An executive signs an annual affirmation that your SPRS score is accurate. What happens between signatures is where that statement stays true or quietly stops being true. Without someone owning the program, the same pattern repeats across the DIB.

After signing

The Compliance Honeymoon

The affirmation is signed, or the assessment is passed. Documentation is fresh. Controls are configured as the SSP describes. Posture is strong, and everyone moves on to other priorities.

Mid-year

The Silent Drift

New vendors are onboarded without compliance review. CUI flows change as contracts evolve. Configurations drift as IT teams optimize for operations. The SSP becomes a document nobody updates. No one notices because no one is looking.

Before the next signature

The Panic Cycle

The next affirmation comes due, or a prime's questionnaire, or a DIBCAC letter. The team scrambles to reconcile what is documented with what is deployed. POA&Ms have gone stale. New requirements landed and were not addressed. Someone still has to sign.

The difference is ownership, not budget.

Organizations that maintain their program between signatures sign with confidence and move through assessments predictably. Organizations that drift tend to find out when someone else checks: an assessor, a prime, or DIBCAC.

What It Is

Program ownership between assessments.

Stehrling Continuous Compliance is a recurring engagement that keeps your compliance program current all year: a structured program with defined deliverables, named practitioners, and clear ownership of the work that keeps your affirmation defensible.

Continuous Compliance addresses the work that doesn't fit anywhere else. It's beyond what an MSP delivers, because MSPs manage infrastructure, not compliance programs. It's beyond what a GRC platform provides, because platforms record posture, they don't maintain it. It's beyond what internal IT can absorb, because compliance program management requires expertise most IT teams reasonably don't have.

Continuous Compliance is what stays after the program is built, so your team is not carrying it alone.

What's Included

Defined deliverables. Predictable cadence.

Every Continuous Compliance engagement includes the same core deliverables. Scope and depth scale to your organizational complexity, but the program structure is consistent.

Quarterly SSP & Documentation Reviews

Your System Security Plan, policies, and procedures are reviewed every quarter against your actual environment. Drift is identified and remediated before it becomes a finding.

POA&M Management

Active management of your Plan of Action and Milestones. New gaps documented, remediation tracked, closed items validated, and the entire POA&M kept current and audit-ready.

Regulatory Monitoring

NIST 800-171 Rev 3 transition. CMMC reciprocity decisions. Framework updates. We monitor the regulatory landscape and translate changes into specific actions for your program.

Change Impact Reviews

New vendors, new services, environment changes, organizational restructuring. Every change with potential compliance impact is reviewed before it disrupts your posture.

Security Awareness Training

Annual training refreshes, role-based training updates, and ongoing CUI handling awareness for your workforce. Training material updated as your environment evolves.

Affirmation and Recertification Support

Before each annual affirmation, we re-check your SPRS score against the evidence and brief the executive who signs. Where a contract requires CMMC certification, recertification preparation starts 12 months out.

Ad Hoc Consulting Access

When contract scope changes, when a customer asks a compliance question, when a vendor proposes something that might affect your posture, your team has direct access to senior practitioners.

Quarterly Executive Readouts

A standing quarterly readout to your leadership team. Posture status, regulatory changes, upcoming work, and the strategic view of where your compliance program is heading.

How Engagements Are Scoped

Scoped to effort, not to a tier.

Every Continuous Compliance engagement includes the same core deliverables. What changes is scope, depth, and cadence, calibrated to the effort your environment actually requires. We don't sell tiers off a menu. We scope the work to your situation, and we price it accordingly.

The right scope emerges from understanding your environment, not from selecting a tier. A single-environment manufacturer with stable operations engages differently than a multi-environment international firm in active growth. A contractor with a strong internal team needs different oversight than one without compliance staff. The methodology is consistent. The scope is yours.

The scoping conversation happens during discovery, where we walk through your environment, contract obligations, change velocity, and the level of program ownership that fits your organization. We come out of that conversation with a defined engagement, a clear cadence, and pricing grounded in the actual effort the work will require.

No two Continuous Compliance engagements are identical, because no two compliance programs are identical. What's consistent is the discipline we bring to scoping them.

What Shapes the Engagement
  • Environmental complexity Number of CUI environments, enclave architectures, and the integration between them
  • Geographic footprint US-only operations versus international presence and cross-jurisdictional CUI flows
  • Change velocity Stable posture versus active contract growth, vendor changes, or organizational restructuring
  • Internal capability Existing compliance staff and depth, versus full external program ownership
  • Oversight depth Quarterly check-ins versus active monthly cadence versus executive-level program ownership
  • Timing Newly built program, mid-year, or approaching an affirmation, assessment, or recertification
The Operating Rhythm

A predictable cadence through the year.

Continuous Compliance engagements operate against a predictable rhythm. Some work happens every month and quarter regardless of conditions. Some intensifies before each affirmation, and before recertification where a contract requires it.

Monthly

Working Sessions

Standing cadence with your compliance lead. Issues addressed, change impacts reviewed, upcoming work scoped. The working layer of the engagement.

Quarterly

Program Reviews

Comprehensive review of SSP, POA&M, training status, regulatory landscape, and posture against your SSP and SPRS baseline. Findings, recommendations, and remediation plans.

Annually

Program Refresh

Full annual refresh of training material, policy reviews, evidence collection, and risk register updates. Sets the program up for the year ahead.

Before each affirmation

Affirmation Readiness

SPRS score re-validated against evidence, open POA&M items reviewed, and a briefing for the executive who signs. Where a contract requires CMMC recertification, that preparation starts 12 months out.

Get Started

Where is your program today?

Whether your program was built last quarter or you are a year past your last affirmation and noticing drift, Continuous Compliance meets you where you are. Talk to a practitioner about your current posture and what ongoing program ownership would look like. Expect a reply within one business day.

Talk to a Practitioner →

An independent firm building NIST 800-171 compliance programs and AI governance for defense contractors and the DIB.

Fredericksburg, VA