Class Deviation RFO-2025-38
August 12, 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 38 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 38 for purposes of implementing the FAR Council’s model deviation to FAR part 38.
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 38, Federal Supply Schedule Contracting, is removed in its entirety. Guidance and procedures for the Schedule program will be moved from FAR part 38 and subpart 8.4 to GSAR part 538.
4. Instructions
- The GSA acquisition workforce must follow the RFO part 38 model deviation text instead of FAR part 38 as codified at 48 CFR Chapter 1. The Council’s RFO part 38 model deviation text is available at Acquisition.gov/far-overhaul, and is incorporated into this class deviation.
- 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This class deviation is effective November 3, 2025 and remains in effect until rescinded or incorporated into the FAR.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.