Class Deviation RFO-2025-15: FAR Class Deviation for FAR Part 15 in Support of Executive Order 14275, Restoring Common Sense to Federal Procurement

Class Deviation RFO-2025-15
September 29, 2025
MEMORANDUM FOR GSA CONTRACTING ACTIVITIES
FROM AND DIGITALLY SIGNED BY: Jeffrey A. Koses, Senior Procurement Executive, Office of Acquisition Policy (MV)
SUBJECT: FAR Class Deviation for FAR Part 15 in Support of Executive Order 14275, Restoring Common Sense to Federal Procurement

On this page:

Purpose
Background
Summary of changes
Instructions
Applicability
Authority
Effective date
Have a question?

1. Purpose

This memorandum approves a class deviation to Federal Acquisition Regulation (FAR) part 15 for purposes of implementing the FAR Council’s model deviation to FAR part 15.

2. Background

Executive Order (E.O.) 14275, Restoring Common Sense to Federal Procurement, signed April 15, 2025, mandates a comprehensive review and simplification of the Federal Acquisition Regulation.

The FAR is being updated to:

Eliminate non-statutory language.
Remove redundant or obsolete language.
Enhance clarity through plain language.
Align with the new FAR framework.
Preserve essential governmentwide acquisition standards.

This project is referred to as the Revolutionary FAR Overhaul (RFO) initiative. This initiative will make the FAR more concise, understandable, and focused on core procurement requirements.

3. Summary of changes

Besides a major restructuring, there have been significant changes to FAR 15, Contracting by Negotiation, to address long-term pain points for Government and Industry.

Key new improvements and flexibilities to part 15 include:

Logical Flow: The new framework replaces a topic-based structure with a more intuitive flow based on the acquisition life-cycle.
Consolidation: Concepts that were previously fragmented are now unified creating a more cohesive framework.
Core Vocabulary Changes: Key terms are defined and standardized.
- The term “discussions” is replaced with “negotiations.” The term “communications,” in the context of competitive range establishment, has been eliminated. The term “deficiency” is redefined.
- The use of “clarifications” now includes robust guidelines for its application. Clarifications permit minor corrections but do not allow for proposal revision and cannot be used to cure proposal deficiencies or material omissions. The scope of permissible clarifications was expanded to include coverage that was previously limited to “communications” before establishing the competitive range. Clarifications may be conducted at any time after receipt of proposals through contract award irrespective of whether a competitive range has been established.
Updated Rules of Engagement: Contracting officers must negotiate with each responsible offeror within the competitive range and may further negotiate with the offerors as needed. Having further negotiations with one offeror does not require the contracting officer to have further negotiations with other offerors. The deviation text provides guidance on industry communication through early exchanges and debriefing.
Redefined Competitive Range: The competitive range is now clearly defined as “the group of evaluated proposals that the contracting officer determines are best suited for further negotiation” instead of “all of the most highly rated proposals”.
Enhanced Clarity: The text has been revised for greater clarity. It employs more direct language and introduces explicit subheadings for complex topics.

Statutory requirements retained in the RFO FAR part 15 model deviation include, but may not be limited to, the following:

6 U.S.C. § 394, Unsolicited Proposals
10 U.S.C. § 3206 and 41 U.S.C. § 3306(c), Evaluation Factors
10 U.S.C. §§ 3301 et seq and 41 U.S.C. §§ 3701 et seq, Awarding of Contracts
10 U.S.C. §§ 3701 et seq and 41 U.S.C. §§ 3501 et seq, Truth in Negotiations Act
41 U.S.C. § 2102, Prohibitions on Disclosing and Obtaining Procurement Information

Change	Description
Retained	Part 15 continues to be the part primarily used for establishing negotiated contracts when using a request for proposal (RFP). The following provision and clauses are retained (or remain reserved) with no changes: 52.215-4 remains reserved 52.215-7 remains reserved 52.215-9 (Clause), Changes or Additions to Make-or-Buy Program 52.215-10 (Clause), Price Reduction for Defective Certified Cost or Pricing Data 52.215-14 (Clause), Integrity of Unit Prices 52.215-16 (Provision), Facilities Capital Cost of Money 52.215-17 (Clause), Waiver of Facilities Capital Cost of Money 52.215-24 thru 52.215-42 remain reserved
Moved/updated	The part structure is revised from six subparts to five: Subpart 15.1 - Presolicitation and Solicitation Subpart 15.2 - Evaluation and Award Subpart 15.3 - Postaward Subpart 15.4 - Contract Pricing Subpart 15.5 - Unsolicited Proposals 15.000, “Scope”, is updated to emphasize that the procedures in the part provide an opportunity for back-and-forth negotiation between the Government and an offeror(s) upon receipt of a proposal submitted in response to an RFP. 15.001, “Definitions”, updates two of the four definitions: “Deficiency” is updated to remove reference to “unacceptable risk” and clearly define a “material requirement”. “Proposal revision” is updated to include the phrase “material elements of a proposal”. This revision clarifies that not every change made during negotiations constitutes a proposal revision, focusing the definition on changes that are substantive in nature. 15.002, “Types of Negotiated Acquisitions”, is updated to modernize the language throughout. The two paragraphs in this section are now titled “Noncompetitive Acquisitions” and “Competitive Acquisitions”. 15.101, “Early Exchanges with Industry”, revises and consolidates content previously located in multiple sections of the part. The new section is structured with clear subheadings for “Draft RFPs”, “Requests for Information”, “Mission Needs and Requirements”, and “Advisory Multistep Process”, making the content more accessible. 15.102, “Structuring a request for proposals”, more clearly outlines the required format and content for RFPs. 15.103, “Developing a Competitive Source Selection Approach”, relocates the existing source selection approaches (“Tradeoff” and “Lowest Price Technically Acceptable”) and adds two approaches - “Highest Technically Rated with a Fair and Reasonable Price” (15.103-3) and “Phased Acquisitions” (15.103-4). 15.105, “Other Considerations”, relocates, consolidates, and updates topics previously located throughout the part into a single section. This consolidation enhances the usability of the regulation by grouping these specific solicitation-related considerations together for easy reference during RFP preparation: 15.105-1 Oral presentations. Relocated from 15.102. 15.105-2 Negotiations disclosure. Relocated from 15.209(a). 15.105-3 Limitation on tiered evaluations for multiple award contracts. Relocated from 15.101-3. 15.105-4 Request for cost or pricing data. Relocated from 15.403-5. 15.105-5 Make-or-buy decision. Relocated from 15.407-2. 15.105-6 Should-cost review. Relocated from 15.407-4. 15.105-7 Unit prices. Relocated from 15.404-1(f). 15.106, “Amending a Request for Proposal”, updates former section 15.206. The language and requirements are now clearer. 15.109, “Uniform Contract Format”, and its subsections, are relocated and streamlined. New subpart 15.2, “Evaluation and Award”, updates and clarifies the evaluation and award process. 15.202, “Evaluating Competitive Proposals”, relocates and substantially revises the content previously at section 15.305. 15.202(a)(2) provides a more robust, multi-part definition of “clarifications”. It states that clarifications can be used to “enhance the Government’s understanding of a proposal”, “allow reasonable interpretation”, and address “ambiguities” as well as “perceived deficiencies, weaknesses, errors, omissions, or mistakes”. The new definition allows the contracting officer to request additional information or documentation provided cost/price or other material elements of the proposal are unchanged. Clarifications are not to be used for revising proposals and curing deficiencies or material omissions. 15.204, “Competitive Award with Negotiation”, streamlines and consolidates the complex rules for post-evaluation exchanges with offerors, which were previously spread across sections 15.306 (“Exchanges with offerors after receipt of proposals”) and 15.307 (“Proposal revisions”). The phrase“communications with offerors before establishment of the competitive range” has been deleted, and where appropriate, functions have been moved to the new definition of “clarifications” under 15.202(a)(2). 15.206, “Preaward notices and debriefings”, updates guidance on preaward notices and debriefings. New 15.207-1, provides new information about completing the award document when not using OF 307, Contract Award; SF 26, Award/Contract; or SF 33, Solicitation, Offer and Award. 15.301, “Postaward Debriefing of Offerors”, relocates and updates the content on post-award debriefings, previously at 15.506. Subpart 15.4, “Contract Pricing”, has been restructured and the internal section numbering and organization have been significantly updated. Subpart 15.5, “Unsolicited Proposals”, is moved from former subpart 15.6 and the content is reorganized and streamlined. The following provision and clauses are updated for clarity, to mirror updates made throughout the part, and/or to update cross- references or remove outdated content: 52.215-1 (Provision), Instructions to Offerors— Competitive Acquisition 52.215-2 (Clause), Audit and Records—Negotiation Alternate I is removed because it implemented the American Recovery and Reinvestment Act which is no longer active. 52.215-6 (Provision), Place of Performance 52.215-8 (Clause), Order of Precedence—Uniform Contract Format 52.215-11 (Clause), Price Reduction for Defective Certified Cost or Pricing Data—Modifications 52.215-12 (Clause), Subcontractor Certified Cost or Pricing Data 52.215-13 (Clause), Subcontractor Certified Cost or Pricing Data—Modifications 52.215-15 (Clause), Pension adjustments and asset reversions 52.215-18 (Clause), Reversion or Adjustment of Plans for Postretirement Benefits (PRB) Other Than Pensions 52.215-19 (Clause), Notification of Ownership Changes 52.215-20 (Provision), Requirements for Certified Cost or Pricing Data and Data Other Than Certified Cost or Pricing Data 52.215-21 (Clause), Requirements for Certified Cost or Pricing Data and Data Other Than Certified Cost or Pricing Data—Modifications 52.215-22 (Provision), Limitations on Pass-Through Charges—Identification of Subcontract Effort 52.215-23 (Clause), Limitations on Pass-Through Charges The FAR Companion is expected to include best practice information not required in the FAR on the following content: Guidance on the best value continuum and using various source selection approaches Procedures pertaining to oral presentations Amendments based on alternate solutions
Removed	Former section 15.205, “Issuing Solicitations”, is removed because it is repetitive of information found in other FAR parts. The following provisions are deleted: 52.215-3 (Provision), Request for Information or Solicitation for Planning Purposes, is now reserved. The information is covered by the new 15.101(c). 52.215-5 (Provision), Facsimile Proposals, is now reserved. The revised regulation takes a more technology-neutral approach. This allows agencies the flexibility to authorize a range of modern electronic submission methods without needing a specific, and now largely outdated, provision.

This table is not an exhaustive list.

4. Instructions

The GSA acquisition workforce shall follow the RFO part 15 model deviation text instead of FAR part 15 as codified at 48 CFR chapter 1. The Council’s RFO part 15 model deviation text is available at Acquisition.gov/far-overhaul, and is incorporated into this class deviation.
For new solicitations or contracts, when using any provisions or clauses that have been revised, utilize the RFO model deviation language at RFO FAR part 52.
For open solicitations or awarded contracts, the contracting officer has discretion regarding the need to enforce or amend the provisions or clauses. Note that without some of the removed provisions or clauses, the contracting officer may be required to separately address certain aspects in the contract.
Contracting activities must review templates and related standard operating procedures to align with this class deviation and remove unnecessary processes and steps.

5. Applicability

This class deviation applies to all GSA procurements.

6. Authority

This class deviation is issued under the authority of EO 14275, OMB Memo M-25- 26 [PDF], 48 CFR 1.4, and RFO FAR 1.304.

7. Effective date

This class deviation is effective November 3, 2025 and remains in effect until rescinded or incorporated into the FAR.

8. Have a question?

Try asking GSAi first (upload the new RFO language and GSA’s implementing deviation, then ask your question. Please note, GSAi is accessible to GSA employees only). If you still need clarification, email the GSA Acquisition Policy Division at GSARPolicy@gsa.gov.