Minnesota's defense industrial base is bigger than people outside it realize. Honeywell Aerospace, BAE Systems, Polaris Government & Defense, Lockheed Martin, and Northrop Grumman all have a presence in the state, and their supply chains run through Minnesota subcontractors: machine shops in Anoka and Brooklyn Park, fabricators in Plymouth and Maple Grove, electronics assemblers along 169, software and engineering subs throughout the metro. Every one of those subs that handles FCI or CUI is in scope for CMMC.
The phased rollout schedule is real. Under DFARS clause 252.204-7021, CMMC requirements appear in solicitations on a planned schedule. Phase 1 began November 10, 2025 with Level 1 and Level 2 self-assessment requirements. Phase 2 adds Level 2 C3PAO certification requirements starting November 10, 2026. At full implementation in November 2028, every new DoD contract that touches FCI or CUI will require the appropriate CMMC level before contract award, not after. There is no grace period for a contractor who shows up to bid without the CMMC status a prime contractor needs to flow work down.
A generalist MSP's basic security package was never built for CMMC. It barely covers antivirus.
CMMC Level 2 maps to 110 security practices drawn from NIST SP 800-171 Rev 2, and the underlying controls assume a layered security program that a basic generalist IT contract was never built to deliver. That gap shows up at assessment time. We wrote about this in detail in our MSP vs MSSP article, the structural problem with generalist providers attempting CMMC.