As a new calendar year begins, it’s important to review key events that occurred within the federal contracting world recently to prepare for a successful year for your GSA Multiple Award Schedule (MAS) contract. Forty years ago, the Federal Acquisition Regulation (FAR) was established as a “rulebook” featuring policies and regulations that would guide federal agencies during the procurement of supplies and services, totaling over 2,000 pages of content.
In April 2025, the Trump Administration released Executive Order (EO) 14275 (Restoring Common Sense to Federal Procurement) to update each FAR part to remove non-statutory language and increase the use of plain language for ease of understanding. The goal of this EO is to streamline purchasing processes and ensure efficient use of taxpayer dollars. In this blog, we will focus on the FAR Part 8 (Required Sources of Supplies and Services) rewrite.
What is the Revolutionary FAR Overhaul (RFO)?
Since the release of the Trump Administration’s EO, the FAR Council, consisting of the Administrator for Federal Procurement Policy and leaders from the Department of Defense (DoD), General Services Administration (GSA), and National Aeronautics and Space Administration (NASA), has been releasing rewrites on a rolling basis for each part of the FAR, which is called the Revolutionary FAR Overhaul (RFO). These rewrites are considered model deviations and agencies have the opportunity to implement each model deviation through their own class deviations.
On the FAR website, you can access each FAR part that has been overhauled and agency-specific deviations. The site also features multiple resources intended to assist in stakeholders’ understanding of key changes, including the FAR Companion which provides guidance for navigating the FAR and Practitioner Albums which track the language that was removed from each part’s original text.
Next, let’s discuss an important FAR provision for procurement rules and regulations for the MAS Program.
What is FAR Part 8?
FAR Part 8 governs the acquisition procedures for the following prioritized or mandatory sources for supplies and services: inventories of the requiring agency, excess from other agencies, Federal Prison Industries (FPI), Inc., and AbilityOne participating nonprofit agencies. This FAR part also outlines the ordering procedures for purchases through the Federal Supply Schedule (FSS) program and provides guidance on Order Level Materials (OLMs).
How Has the RFO Revised FAR Part 8?
The FAR Council released the FAR Part 8 model deviation in August 2025 with key items relating to procurement procedures removed or restructured. GSA’s Class Deviation RFO-2025-08 became effective on November 3, 2025, and will be followed until rescinded or incorporated into the FAR. We highlighted a few notable updates impacting GSA Schedule contractors below.
FAR Part 8 Has Been Restructured
The overhauled FAR Part 8 has been reorganized to align more closely with the acquisition lifecycle. For example, FAR Subpart 8.001 now includes a consolidated definitions section, rather than definitions being listed throughout each subpart. Additionally, FAR Subpart 8.1 (Presolicitation) outlines the mandatory sources for procurement that should be considered chronologically depending on the commercial product or service being acquired.
FAR Subpart 8.4 Has Moved
Prior to the RFO effort, FAR Subpart 8.4 was the governing regulation for agencies’ ordering processes when purchasing through the FSS program, including GSA MAS and VA FSS.
Now, under the FAR Part 8 overhaul, FAR Subpart 8.4 directs purchasers to follow the ordering procedures outlined in the General Services Acquisition Regulation (GSAR) Subpart 538.71 (Federal Supply Schedule Ordering Procedures). With the goal of streamlining purchasing and reducing procurement timelines, FSS ordering procedures under GSAR Subpart 538.71 were reduced to include only the requirements necessary for agencies to place orders and establish Blanket Purchase Agreements (BPAs) against FSS contracts.
Notably, the provision under the original FAR Subpart 8.405-3 that required the head of an agency to approve single-award BPAs over $150 million in value has been removed, potentially resulting in quicker timelines for this type of BPA.
Mandatory Use of “Required Use” Contracts
If you have been keeping up with the Trump Administration’s EOs and policy changes throughout 2025, you are likely familiar with EO 14240 (Eliminating Waste and Saving Taxpayer Dollars by Consolidating Procurement) directing federal procurement to be consolidated under GSA. Similarly, the FAR Part 8 overhaul attempts to also streamline federal purchasing by making the use of a certain class of “required use” BPAs or contracts intended for governmentwide use mandatory if the desired commercial product or service is available. If a “required use” contract is not sufficient, then the purchasing agency should utilize other existing governmentwide BPAs or contracts.
The Office of Federal Procurement Policy (OFPP) has not yet disclosed which contracts are considered “required use.” If the MAS Program is considered a “required use” contract, GSA Schedule contractors could experience increased interest in their offerings under the new FAR Part 8. This prioritization of “required use” and existing contract vehicles indicates a focus on the acquisition of commercial products and services via established procurement methods.
Understanding How the RFO Impacts Your GSA Schedule
FAR Part 8 is not the only section of the FAR that has been rewritten. Other FAR parts that have been overhauled include but are not limited to FAR Part 12 (Acquisition of Commercial Products and Commercial Services), FAR Part 10 (Market Research), and FAR Part 19 (Small Business). The model deviation for each FAR part is expected to be eventually incorporated into the FAR through a formal rulemaking process and could undergo additional revisions.
For GSA Schedule contractors, it is important to review each FAR part overhaul, as well as applicable agency deviations, to understand how the updated policies will impact your contract. GSA recently released MAS Solicitation Refresh #30 which involved several clauses being removed or updated within the Solicitation in order to align with the RFO initiative. Our expert consultants are here to support the growth of your GSA Schedule contract and understand the ever-changing federal marketplace.
