The FAR will be amended effective October 1, 2025 to:

• Require a J&A at $30M to sole-source an 8(a) contract, instead of $25M (https://www.federalregister.gov/d/2025-16412/p-17)

• Require CCoPD at $2.5M instead of $2M (https://www.federalregister.gov/d/2025-16412/p-20)

• Make a lot more changes too, starting here: https://www.federalregister.gov/d/2025-16412/p-69, e.g., the threshold for needing agency head approval to award a single-award task order contract will go up by 50%, from $100M to $150M.

I have two things to say:

1. I suspect this means the single-award IDIQ contract should be used more often. We haven't had 50% inflation the past five years, so there is no doubt in my mind this is a policy change - not a change following the Consumer Price Index, as the statute requires every five years.

2. Even though the Revolutionary FAR Overhaul (RFO) class deviations are happening in parallel to these FAR changes in the Federal Register, these FAR changes are to the statutory acquisition-related thresholds, which the RFO can’t delete from FAR, if I understand its charter right. But there is one minor technicality: Many agency's class deviations have been mostly restating the RFO drafts that were in place prior to this FAR change, without adjustment for inflation. So, I think technically those lower thresholds found in the deviations' attachments would control for now, unless new ones come out.  This would at least apply to Part 6’s new sole-source 8(a) threshold.  The $30M will, however, be plain and clear at FAR 19.808-1 for all to see, so I would just document the file if I were stuck waiting for a new Part 6 class deviation.

We can only hope new class deviations come out in time by the October 1^st effective date of the FAR change, to catch up with the FAR Council (never thought I'd say THAT)!

On 8/29/2025 at 11:41 AM, WifWaf said:

The FAR will be amended effective October 1, 2025 to:

• Make a lot more changes too, starting here: https://www.federalregister.gov/d/2025-16412/p-69, e.g., the threshold for needing agency head approval to award a single-award task order contract will go up by 50%, from $100M to $150M.

I have two things to say:

1. I suspect this means the single-award IDIQ contract should be used more often. We haven't had 50% inflation the past five years, so there is no doubt in my mind this is a policy change - not a change following the Consumer Price Index, as the statute requires every five years.

Wise move. It’s ridiculous when companies have to compete for contract awards and then, in turn, have to compete again for orders. Having a single award will encourage companies to submit their most favorable offers upfront for the initial award.

As a side note, all the multiple award IDIQ contracts is a crazy situation. The large number of companies in the pool, often over 100 and in at least one case more than 500, certainly doesn’t provide for efficient placement of orders. They are brought about for a couple of reasons - the sponsoring agency makes revenue off orders and wants to make choices as attractive as possible and agencies award additional contracts to avoid potential protests.

On 8/29/2025 at 11:41 AM, WifWaf said:

the single-award IDIQ contract should be used more often

Good point.

Counter-point: The single-award IDIQ contracts should be used less often - if there is a GWAC or GSA contract.

OMB: The FAR Council will issue new text for FAR 8.004, requiring “that if a commercial product or service meeting the agency’s requirements is available on an existing contract awarded for government-wide use by GSA or another agency, the agency must use the existing contract vehicle instead of awarding a separate new contract, unless the head of the agency provides an exception.

9 minutes ago, General.Zhukov said:

Good point.

Counter-point: The single-award IDIQ contracts should be used less often - if there is a GWAC or GSA contract.

OMB: The FAR Council will issue new text for FAR 8.004, requiring “that if a commercial product or service meeting the agency’s requirements is available on an existing contract awarded for government-wide use by GSA or another agency, the agency must use the existing contract vehicle instead of awarding a separate new contract, unless the head of the agency provides an exception.

I’m glad to see the GSA FFS ordering provisions removed the preference for multiple award BPAs. My same comment above applies to GSA on multiple vs single awards.

20 hours ago, formerfed said:

I’m glad to see the GSA FFS ordering provisions removed the preference for multiple award BPAs.

Is this, at FAR 8.405-3(a)(3), the prohibition to which you are referring, and are you saying that the RFO has in its place allowed single-award BPAs under Federal Supply Schedules without a requirement for any approvals?

32 minutes ago, WifWaf said:

Is this, at FAR 8.405-3(a)(3), the prohibition to which you are referring, and are you saying that the RFO has in its place allowed single-award BPAs under Federal Supply Schedules without a requirement for any approvals?

Ordering procedures got moved to the GSA Acquisition Regulation. I don’t see the previous FAR prohibition there

https://www.acquisition.gov/fss-ordering-procedures