Class Deviation RFO-2025-35: FAR Class Deviation for FAR Part 35 in Support of Executive Order 14275, Restoring Common Sense to Federal Procurement

Class Deviation RFO-2025-35
July 24, 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 35 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 35 for purposes of implementing the FAR Council’s model deviation to FAR part 35.

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

FAR Part 35, Research and Development Contracting, moves away from a prescriptive, specialized regulatory framework for research and development (R&D) contracting toward a streamlined structure that empowers acquisition professionals and makes the federal R&D environment more attractive for innovative commercial firms.

The part is streamlined from 25 to 20 components (subparts, sections, subsections) that are reorganized in a more logical flow of the procurement lifecycle. This significant update greatly improves the usability of the content.

Statutory requirements retained in the RFO FAR part 35 model deviation include, but are not limited to, the following:

31 U.S.C. § 6303, Using Procurement Contracts
10 U.S.C. § 4126, Use of Federally Funded Research and Development Centers

Change	Description
Retained	The definitions of “Applied Research” and “Development” are retained at 35.001. The section titled “Policy” (moved from 35.003 to 35.002) is retained and has been streamlined to remove reference to “Recoupment.” New subparts 35.1, Presolicitation, 35.2, Evaluation and Award, and 35.3, Postaward create logical organization in alignment with the acquisition lifecycle, creating clear points of reference. ”Solicitations” (moved from 35.007 to 35.101) has been updated to include plain language improvements. “Broad agency announcements” (moved from 35.016 to 35.102) retains core substance and unique procedures and has been updated with plain language improvements. “Evaluation for award” (moved from 35.008 to 35.201) has been updated to include plain language improvements. “Scientific and technical reports” (moved from 35.010 to 35.301) has been updated to include plain language improvements. Policies and procedures for “Federally Funded Research and Development Centers” (moved from 35.017 to 35.4) are retained with plain language improvements.
Removed	The definition of “Recoupment” at section 35.001. Section 35.002, “General” provided the context for R&D contracting. Its removal streamlines the part. Section 35.004, “Publicizing Requirements” was removed as largely duplicative of FAR part 5. Section 35.005, “Work Statement” was removed to provide acquisition teams greater flexibility in crafting requirements best suited for the R&D effort. Section 35.006, “Contracting Methods and Contract Type” was removed as duplicative of FAR part 16. The sections titled “Subcontracting research and development effort” (35.009), “Data” (35.011), “Patent Rights” (35.012), “Insurance” (35.013), and “Government property and title” (35.014) are removed as they are covered elsewhere in the FAR: Part 44 for Subcontracting; Part 27 for Data and Patents; Part 28 for Insurance; and Part 45 for Government Property. Section 35.015, “Contracts for research with educational institutions with educational institutions and nonprofit organizations” is removed. However, education institutions are still highlighted as an organization-type that should be considered during evaluation for award at 35.201. Requirements for Standard Form 298, Report Documentation Page, are removed. This provides more flexibility to complete reports in the best suited manner for the R&D effort.

Change

Description

Retained

The definitions of “Applied Research” and “Development” are retained at 35.001.
The section titled “Policy” (moved from 35.003 to 35.002) is retained and has been streamlined to remove reference to “Recoupment.”
New subparts 35.1, Presolicitation, 35.2, Evaluation and Award, and 35.3, Postaward create logical organization in alignment with the acquisition lifecycle, creating clear points of reference.
- ”Solicitations” (moved from 35.007 to 35.101) has been updated to include plain language improvements.
- “Broad agency announcements” (moved from 35.016 to 35.102) retains core substance and unique procedures and has been updated with plain language improvements.
- “Evaluation for award” (moved from 35.008 to 35.201) has been updated to include plain language improvements.
- “Scientific and technical reports” (moved from 35.010 to 35.301) has been updated to include plain language improvements.
Policies and procedures for “Federally Funded Research and Development Centers” (moved from 35.017 to 35.4) are retained with plain language improvements.

Removed

The definition of “Recoupment” at section 35.001.
Section 35.002, “General” provided the context for R&D contracting. Its removal streamlines the part.
Section 35.004, “Publicizing Requirements” was removed as largely duplicative of FAR part 5.
Section 35.005, “Work Statement” was removed to provide acquisition teams greater flexibility in crafting requirements best suited for the R&D effort.
Section 35.006, “Contracting Methods and Contract Type” was removed as duplicative of FAR part 16.
The sections titled “Subcontracting research and development effort” (35.009), “Data” (35.011), “Patent Rights” (35.012), “Insurance” (35.013), and “Government property and title” (35.014) are removed as they are covered elsewhere in the FAR: Part 44 for Subcontracting; Part 27 for Data and Patents; Part 28 for Insurance; and Part 45 for Government Property.
Section 35.015, “Contracts for research with educational institutions with educational institutions and nonprofit organizations” is removed. However, education institutions are still highlighted as an organization-type that should be considered during evaluation for award at 35.201.
Requirements for Standard Form 298, Report Documentation Page, are removed. This provides more flexibility to complete reports in the best suited manner for the R&D effort.

This table is not an exhaustive list.

4. Instructions

The GSA acquisition workforce must follow the RFO part 35 and corresponding model deviation text instead of FAR part 35 as codified at 48 CFR Chapter 1. The Council’s RFO part 35 model deviation text is available at Acquisition.gov/far-overhaul, and is incorporated into this class deviation.
Review templates and related standard operating procedures to remove unnecessary process 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 immediately 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.