RFO FAR - Understanding the FAR Overhaul

There is a current 'overhaul' for FAR regulations that you can visit on Acquisition.gov (the FAR government website). This is great for new businesses who may not have the long-running expertise in compliance of incumbents.

For decades, FAR grew into a dense web of prescriptive steps, checklists, and clauses, with a confusing mix of statutory and non-statutory rules. These rules often slowed down acquisitions and created unnecessary compliance burdens for contractors. Revolutionary FAR Overhaul (RFO) changes that by stripping away redundant language and focusing on statutory essentials.

Below are five key deviations that illustrate this transformation, followed by why fewer non-statutory rules matter for businesses.

1. Market Research (FAR Part 10)

Old FAR rules required contracting officers to follow a rigid formula: search SAM.gov, review FPDS, analyze sustainability, and document bundling impacts. These steps were repetitive and often irrelevant for smaller buys. RFO replaces this with a principle-based approach: conduct market research that makes sense for the acquisition. Agencies can now choose methods like reverse industry days or expert panels without being locked into a checklist. For businesses, this means earlier engagement and less wasted effort on compliance paperwork.

2. Required Sources of Supply (FAR Part 8)

Previously, ordering from Federal Supply Schedules involved pages of prescriptive steps and cross-references. RFO condensed these rules into a clear statutory requirement: use Best-in-Class contracts and follow simplified ordering principles. Detailed procedures moved to the GSAR, leaving FAR leaner. Contractors now have a clearer roadmap without navigating layers of redundant instructions.

3. Use of Government Sources by Contractors (FAR Part 51)

This part contained non-statutory language about subcontractors accessing government supply sources. RFO eliminated the entire part and folded essential statutory provisions into Part 8. Contractors no longer need to interpret a separate section for something that rarely applies, reducing compliance complexity.

4. Acquisition Planning (FAR Part 7)

Old rules mandated detailed acquisition plans with checklists and consolidation analyses, even for small procurements. RFO shifted the focus to results: meet statutory requirements like small business participation, but without rigid templates. Agencies can now scale planning to the size and risk of the buy. For businesses, this means fewer delays caused by bureaucratic planning and more opportunities for innovative solutions.

5. Simplified Noncommercial Acquisitions (FAR Part 13)

Ironically, simplified acquisitions were anything but simple. Multiple overlapping clauses created confusion for contracting officers and vendors. RFO consolidated these into plain-language rules and streamlined clause requirements. This makes it easier for small businesses to understand what’s required and compete effectively without hiring compliance specialists for small buys.

Why Fewer Non-Statutory Rules Help Businesses

Non-statutory rules often add layers of complexity without legal necessity. By removing them, RFO offers several benefits:

• Faster Contracting Cycles: Less paperwork and fewer procedural delays mean businesses can respond to opportunities quickly.
• Lower Administrative Costs: Companies spend less on compliance staff and systems when rules are clear and concise.
• Greater Flexibility: Contractors can propose innovative solutions without being constrained by outdated processes.
• Improved Competition: Simplified rules lower barriers for small businesses and new entrants.
• Reduced Risk: Clear statutory alignment minimizes the chance of technical non-compliance and bid protests.