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Federal Contracting

FAR Revisions – making it simple

FAR Reform: What Contractors Need to Know About the Latest Proposed Changes

The FAR Council continues to update the Federal Acquisition Regulation (FAR) in response to the executive order “Restoring Common Sense to Federal Procurement.” These proposed changes aim to simplify and streamline federal buying. So far, updates target FAR Parts 1, 10, 11, 18, 34, 39, 43, and 52.

Although these changes are still in the review stage, many agencies have already started applying them. Here’s what federal contractors should know:

New Proposed FAR Revisions – In Plain Terms

Part 10: Market Research

  • Agencies now have more flexibility in how they conduct market research at any dollar level.
  • They must still research larger buys (above the simplified acquisition threshold).
  • They no longer have to research smaller buys if good pricing info is available.
  • The FAR removes suggested research steps.
  • New clause FAR 52.210-1 (Market Research) will appear in solicitations and contracts for noncommercial buys over $6 million.

Part 11: Describing Agency Needs

  • Agencies no longer need to prioritize green products listed in the Green Procurement Compilation.
  • Agencies can rely on commercial market acceptance to decide if an item fits their needs.
  • Removes measures controlling the identification and availability of specifications.
  • The FAR drops specific rules for specs and delivery schedules.
  • It keeps rules under DPAS for contracts tied to national defense and emergency programs.

Part 18: Emergency Acquisitions

  • Agencies no longer need to prioritize sustainable options during emergency buys.
  • Emergency flexibilities remain in place for disasters, security events, and contingency operations.

Part 39: Buying IT and Communications Tech

  • Contracting officers do not need to evaluate every stage of modular IT contracts for the best contract vehicle.
  • Agencies will no longer need IT vendors to list minimum education or experience for proposed staff.

Part 43: Contract Modifications

  • The FAR clarifies how agencies should document and define change orders.
  • Contracting officers won’t have to list every major event when reviewing requests for pricing adjustments.

What This Means for Contractors

These changes mark a shift toward faster, more practical procurement. Even though the FAR updates are not finalized, agencies are already putting many into action. Contractors should track these changes closely to stay ahead, and stay compliant, to stay competitive.

Questions regarding the latest proposed revisions to the FAR? Give us a call.

This Refresh is MASsive

GSA recently announced the upcoming release of MAS Solicitation 47QSMD20R0001 – Refresh #27 via the GSA Interact community. GSA’s Federal Acquisition Service plans to issue the refresh in June 2025, with contractors required to accept the mass modification within 90 days of issuance. (BUY.GSA.GOV June 9, 2025)

Key changes in Refresh #27 include:

General Solicitation Updates:

  • Added sections for revoked Executive Orders and the EO on Ending Radical and Wasteful Government DEI Programs
  • Revised the “General Out of Scope Items” section
  • Updated instructions in SCP-FSS-001 for all offerors
  • Retired 10 SINs (see Significant Changes document)
  • Expanded the Transactional Data Reporting (TDR) pilot to 62 more SINs and make TDR mandatory for all Product SINs and Cloud SIN 518210C
  • Incorporate updated Service Contract Labor Standards (SCLS) Wage Determinations
  • Limited requirement for resellers to provide a Letter of Supply to items proposed under IT (Category F) and Printing/Photographic Equipment (A10, Category A)
  • Clarified base/accessory item proposal rules
  • Apply minor updates to the Price Proposal Template for Products
  • Incorporate clause/provision updates through FAC 2025-04 and GSAR Change 199 (excluding Change 187) (ibid)

Category-Specific Revisions:

  • Office Management (A): Updated SIN 511120 and removed Media Products Subcategory (A06)
  • Facilities (B): Revised SINs under Maintenance (B01), revisions to SIN 561210FAC and Supplies (B04): Revisions to SIN 322291 Restroom products
  • Furniture (C): Revised SINs in Packaged Furniture (C07): SIN 33721P and Fitness (C09): SIN 339920S
  • Miscellaneous (G): Revised SINs for Flags, Banners, Pennants and Related Products 33999F, Subcategory (G02):, Apparel Subcategory (G05): SIN 3152, Clothing and SIN 339113PA Protective Apparel, and 4PL Services (G06)
  • Travel (L): Updated SIN 531 under Employee Relocation (L01) (ibid)

⚠️ The Mass Mods Portal will be offline the weekend of June 28th for maintenance. (ibid)

Have questions about the refresh or acceptance instructions? Give us a call.

A New and Improved FAR coming your way

GSA Hosts Webinar on Transformative Federal Procurement Changes

The General Services Administration (GSA) hosted a live webinar last week to discuss major reforms reshaping the future of federal acquisition. The session focused on two recent Executive Orders EO 14240, which consolidates federal procurement under GSA, and EO 14275, which launches a sweeping overhaul of the Federal Acquisition Regulation (FAR). Together, these changes aim to streamline buying, cut waste, and open government contracting to more innovation and efficiency. (GSA webinar to discuss executive orders) May 28, 2025)

Consolidating Federal Procurement: EO 14240

Jeff Koses, GSA’s Senior Procurement Executive, explained how EO 14240 shifts common goods and services procurement under GSA’s leadership. This move will eliminate redundancy, reduce cost, and enable agencies to concentrate on mission delivery. GSA will now act as the Executive Agent for all Governmentwide Acquisition Contracts (GWACs), aligning those currently managed by NASA and NIH into GSA’s centralized procurement strategy. (ibid)

GSA will collaborate with OMB, NASA, and NIH to assess current GWACs, resources, and commitments, building a cohesive transition plan. The 10 key spending categories, Information Technology, Professional Services, Security & Protection, Facilities & Construction, Industrial Products & Services, Office Management, Transportation & Logistics, Travel, Medical, and
Human Capital will fall under GSA’s streamlined acquisition umbrella. (ibid)

FAR Overhaul: EO 14275

The second half of the webinar focused on EO 14275, which calls for a modernized, intuitive, and mission-focused FAR. Koses highlighted that the current FAR is too complex and deters many businesses, especially small and innovative firms, from entering the federal marketplace. (ibid)

The FAR rewrite dubbed the Revolutionary FAR Overhaul (RFO), is being implemented through a series of deviations and will remove low-value administrative burdens while maintaining key protections against waste and fraud. New resources, including a FAR Companion Guide, Practitioner Albums, and Buying Guides, will support acquisition professionals and contractors as the rewrite rolls out. (ibid)

Parts of the revised FAR are already available on Acquisition.gov, and the public can comment directly on proposed changes. GSA also announced new training efforts in partnership with FAI and DAU to support the acquisition workforce in adopting the changes. (ibid)

What This Means for Industry

These changes signal a major shift for contractors:

  • Greater opportunity for innovative and small businesses to compete.
  • Streamlined acquisition timelines and reduced barriers to entry.
  • Increased emphasis on commercial buying and mission-first contracting. (ibid)

What’s Next

GSA will continue collecting agency implementation plans and begin analyzing them with OMB. The agency stressed the importance of collaboration with stakeholders and the acquisition workforce during this transitional period. (ibid)

To stay informed, stakeholders can sign up for RFO updates, download new FAR parts and guides, and share feedback directly on Acquisition.gov. (ibid)

This marks a new chapter in federal acquisition—one aimed at making government buying faster, smarter, and more accessible.

Questions concerning the FAR and the overhaul? Give us a call.

Trump Administration Moves to Overhaul Federal Procurement Rules

On April 15, 2025, President Trump signed two executive orders (EOs) aimed at transforming federal procurement. These actions directly impact contractors by pushing the system toward commercial solutions and simplified regulations. Insidegovernmentcontracts.com April 16, 2025

EO #1: “Restoring Common Sense to Federal Procurement” (FAR Reform EO)

This EO directs the Office of Federal Procurement Policy and the FAR Council to revise the Federal Acquisition Regulation (FAR) to include only what statutes require or what’s essential to sound procurement. Agencies must:

  • Appoint senior officials by April 30 to align their procurement rules.
  • Follow interim deviations and guidance ahead of final FAR amendments.
  • Prepare for potential “sunset” of non-statutory FAR clauses after four years unless renewed. (ibid)

OMB will issue implementation guidance by May 5 and enforce a “ten-for-one” rule—repealing 10 regulations for every new one added.

EO #2: “Ensuring Commercial, Cost-Effective Solutions in Federal Contracts” (Commercial Solutions EO)

This order requires agencies to prioritize commercial products and services under the Federal Acquisition Streamlining Act (FASA). Contracting officers must:

  • Justify any pending non-commercial procurements by June 14.
  • Submit their justifications for senior procurement executive (SPE) review within 30 days.
  • Obtain SPE approval for any future non-commercial contracts, with market research, price analysis, and rationale. (ibid)

Agencies must report progress to OMB within 120 days and annually thereafter, detailing compliance with FASA and progress on implementing the Order’s commerciality preference. (ibid)

What Contractors Should Do

  • Expect regulatory shifts that may change compliance obligations mid-contract.
  • Review current proposals to identify where you can frame your offering as a commercial item.
  • Engage proactively with contracting officers to support market-based solutions and pricing.

These changes aim to streamline procurement, reduce regulation, and shift focus toward cost-effective, commercially available solutions. (ibid)

Not certain how to frame your product/service as commercially available? Give us a call.

What’s Next for Federal Acquisition? David Berteau’s Parting Insights for Government Contractors

As David Berteau steps down from his role as CEO of the Professional Services Council (PSC), federal contractors would be wise to pay close attention to the lessons he leaves behind. With over four decades in federal acquisition, from the Pentagon to PSC, Berteau has seen the full arc of government contracting’s evolution and knows exactly where the industry needs to go next. (Federal News Network April 29, 2025)

From Inputs to Outcomes: A Call for Smarter Procurement

“The government used to buy results. Now it buys labor hours and storage capacity,” Berteau said in a farewell conversation with Federal News Network’s Tom Temin. His message to contractors is clear: success in the coming era will depend on shifting the conversation with agencies back to mission outcomes—not just technical specs or cost ceilings. (ibid)

For firms competing in a crowded, compliance-heavy space, being outcome-focused is more than a strategy—it’s a differentiator. “We need to help the government define what success looks like, and tailor solutions to achieve that,” he emphasized. (ibid)

Tech Innovation Has Left the Building—and That’s an Opportunity

Gone are the days when the Pentagon seeded cutting-edge technology. Today, Berteau said, commercial markets drive innovation, and contractors must be fluent in adapting those tools for government use, securely, affordably, and at scale. (ibid)

“Most new technology now comes from the global commercial space. The government’s role is still critical, especially for defense but the dynamic has flipped,” he noted. (ibid)

Contractors that understand how to integrate commercial tech into mission-specific architectures, from cloud platforms to edge computing, are already outpacing those still anchored in legacy systems. (ibid)

The Competitive Edge: Culture and Mission Alignment

For government service providers, Berteau stressed that culture is the real competitive advantage. “You can’t sustain success in this market without a commitment to the mission,” he said. “The red tape is real. If your people aren’t motivated by public service, they won’t last.” (ibid)

This alignment is especially critical in today’s talent market, where attracting and retaining cleared, capable professionals remains a top challenge. Contractors who invest in a strong mission-driven culture, Berteau argued, will win, not just the next bid, but long-term relevance. (ibid)

Politics Matter, But Execution Wins

While policy shifts and partisan changes affect contracting conditions, Berteau reminded industry leaders to stay focused on execution. “The best companies in this space don’t get distracted by politics. They stay grounded in what matters: delivering value, staying compliant, and helping agencies succeed.” (ibid)

With a new wave of acquisition reform always around the corner, staying agile and compliant remains essential. “You can’t perform if you’re not compliant. And if you don’t perform, you won’t be around for long,” he said bluntly. (ibid)

Still in the Fight—Just Not Full Time

Though Berteau is stepping back from day-to-day operations, he made it clear he’s not exiting the federal contracting world entirely. “I’ve got a lot left to say and do. I’ll keep writing, advising, and staying connected.” (ibid)

For government contractors navigating increasing complexity, Berteau’s departure marks the end of an era, but not the loss of insight. His advice to the industry: stay competitive, stay compliant, and above all, stay aligned with the mission. (ibid)

Questions concerning the changing federal acquisition landscape? Give us a call.