RFO-2025-31
June 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 31
On this page:
- Purpose
- Background
- Summary of changes
- Instructions
- Applicability
- Authority
- Effective date
- Point of contact
1. Purpose
This memorandum approves a class deviation to Federal Acquisition Regulation (FAR) part 31 for purposes of implementing the FAR Council’s model deviation to FAR part 31.
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 FAR.
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.
3. Summary of changes
FAR part 31, Contract Cost Principles and Procedures, anchored in federal appropriations law, has been streamlined to provide only the essential requirements for the pricing of contracts, subcontracts, and modifications whenever cost analysis is performed.
Statutory requirements and principles retained in the RFO FAR part 31 model deviation include, but are not limited to, the following:
- Armed Services Procurement Act of 1947, Public Law 413
- 41 U.S.C. Chapter 43 and 10 U.S.C. Chapter 273, Allowable Costs
- 31 U.S.C. Chapter 37, Subchapter III, Claims Against the United States Government
- 18 U.S.C. § 1031, Major Fraud Against the United States
- OMB Circular A-122, Cost Principles for Nonprofit Organizations
- OMB Circular A-21, Cost Principles for Educational Institutions
- OMB Circular A-87, Cost Principles for State, Local, and Indian Tribal Governments
| Change | Description |
|---|
| Retained | - The majority of the content is retained as it implements appropriations law.
- Most definitions and procedures are retained to maintain uniformity across Government.
|
|---|
| Removed | - Plain language edits were made throughout to enhance readability and remove redundant, unclear, or non-essential language, decreasing the word count by more than 1,300 words.
|
|---|
This table is not an exhaustive list.
4. Instructions
- The GSA acquisition workforce shall follow the RFO part 31 model deviation text instead of FAR part 31 as codified at 48 CFR Chapter 1. The Council’s RFO part 31 model deviation text is available at Acquisition.gov, under the “FAR Overhaul” link, and is incorporated into this class deviation.
- Review templates and related standard operating procedures to align with this 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 immediately and remains in effect until rescinded or incorporated into the FAR.
8. Point of contact
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.