Many federal contractors have heard about the revamping of the Federal Acquisition Regulation. Variously called FAR 2.0, the Revolutionary FAR Overhaul, or simply RFO, this project has been undertaken by the Office of Federal Procurement Policy (OFPP) and the Federal Acquisition Regulatory Council (FAR Council). An executive order got the ball rolling, setting forth the mandate to create FAR 2.0 by October 12, 2025. We wrote about it in our earlier post, and described it as two parallel tracks. Track 1 involves a rewrite into “plain language” and removing non-statutory and unnecessary content. Track 2 involves the development of the non-mandatory guidelines to guide procurement officials.
Our earlier posts regarding the RFO can be found here: Executive Order, Overview of FAR 2.0, FAR Part 6.
The revision of the FAR sections has continued over the past few months, with additional proposed revisions being released in September 2025. In this post, we’ll review one proposed revision that seems to make some significant changes to the language: Part 8 – Required Sources of Supplies and Services.
Part 8 – Required Sources of Supplies and Services
Part 8 describes “prioritizing sources of supplies and services for use by the Government.” The language was issued on August 14, 2025 and updated on August 29. Six agencies have adopted the deviation. The Practitioner Album notes that the “model deviation language simplifies mandatory source guidance, makes clear that Governmentwide ‘required use’ contracts are mandatory, and retains focus on the importance of the AbilityOne Program.”
Numerous sections will be retained, including
- Use of Procedures Other than Competitive Procedures (10 U.S.C. § 3204)
- Products of Federal Prison Industries (10 U.S.C. § 3905)
- Architectural and Engineering Services (40 U.S.C. § 1103 Note)
- Competitive Procedures (41 U.S.C. § 152(3))
- Requirements for Purchase of Property and Services Pursuant to Multiple Award Contracts (41 U.S.C. § 3302)
- Use of Noncompetitive Procedures, (41 U.S.C. § 3304)
- Committee for Purchase from People Who are Blind or Severely Disabled (41 U.S.C. §§ 8501 et seq)
The guide states that Section 8.104 Use of Existing Contracts, will replace section 8.004 Use of Other Sources. In particular: “Governmentwide “required use” contracts or BPAs are now required to be used when a commercial product or commercial service meets an agency’s need, unless approved by the Head of the Contracting Activity (HCA). If a Governmentwide “required use” contract or BPA is not suitable, agencies should consider use of other existing governmentwide contracts, BPAs, or shared services.”
That section states that an agency
(1) must use the existing government-wide contract or blanket purchase agreement to buy the supply or service if the contract has been designated by the Office of Federal Procurement Policy a “required use” contract, unless the head of the contracting activity provides an exception (e.g., because the contract’s terms and conditions, scope, or performance period do not meet the agency’s needs); and
(2) should consider use of other existing government-wide contracts or blanket purchase agreements if there is not a suitable “required use” contract to meet the agency’s needs.
This language strongly requires the use of “required use” contracts and encourages the use of best in class procurement vehicles. That site suggests the two types (required and BIC) are separate, although some BIC vehicles willy likely be required use contracts. But the particular required use contracts are not defined on the site as of yet. Some BIC include Alliant II, VETS II, STARS III, CIO-SP4, and NASA SEWP, among many others.
Federal Supply Schedule Subpart 538.71
Ordering procedures will be moved to General Services Acquisition Manual part 538. This action results in the removal of basically all of current FAR part 8.4, which currently deals with Federal Supply Schedules, AKA GSA schedules.
This will be a new section for GSA Schedule ordering procedures, In particular, an agency is “not required to have evaluation plans, score quotations, or establish a competitive range before communicating with quoters or soliciting revised quotations.” In addition, GSA schedule ordering includes the following characteristics:
- Brief explanation only (no debriefing)
- No responsibility determination needed
- No price reasonableness determination needed
While these features have been present in the past for GSA schedules, the guidance highlights them for procurement officials. This seems to indicate an increased emphasis on use of GSA Schedules. So, contractors, if not already, may consider getting on the GSA schedules since many contracts appear to be moving to that vehicle.
Conclusion
This updated Part 8 represents some key changes for federal contractors to both the structure and substance of the FAR. We will stay tuned to the RFO revisions as they are rolled out and summarize them on SmallGovCon. Check back here for updates.
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