The NCAA doesn't force anyone to play 12 games. It's entirely possible to play 11 games.
I'm doing a round-up for my site on BCS OOC schedules. So far, the ACC is the only conference with any team that has multiple DI-AA opponents. That said, some Big East schools haven't released their schedules yet, and since they need 5 OOC games I expect that number to increase. (Also, several schools play Western Kentucky, which is a transitional member and will be full DI-A in the Sun Belt next year. For my purposes, I count them as a sort of "half" DI-AA school.)
But outside of the Big East, the ACC will easily have the worst OOC schedules as a group this year. Bar-none.