While the turkey was getting its glow I spent some time wondering and researching . This simple view came to mind but all the same it makes me wonder. A view of the RFO effort that I have not seen discussed or a discussion that I missed.

At Acquisition.gov at the tab "Regulations" there are 32 codified supplements to the FAR noted. At the tab "FAR Overhaul" at "Quick Access to Key RFO Resources" the click on for "Parts and Deviations" brings up the list of of overhauled FAR Parts. Each FAR Part listed notes how many deviations have been issued for each Part and the click on for the deviations notes the Federal entity that issued the deviation.

What caught my eye is that the number of deviations issued for each Part varies from 6 to 31. In some cases the deviations issued do not match, so to speak, with the Federal entities that are listed as the 32 that have codified the FAR. And most intriguing is the fact that RFO FAR Part 2 listed in the "Parts and Deviations" shows zero deviations have been issued.

From my view the following quick questions occurred to me -

Are the listed deviations accurate? By example the corollary of deviations for RFO FAR Part 1 to other Part deviations is confusing. Making of road map of the deviations would appear to be quite challenging.

The RFO effort is a simple one? Imagine a contractor thinking about participating in procurements today across several Federal entities some of whom have not deviated, some have deviated but for not all Parts.

RFO FAR Part 15 has only 8 deviations issued? Makes one wonder if the concerns that have been expressed in various thread discussions in WIFCON Forum have caught the eye of some Federal entities?

The Millennium Challenge Corporation? An entity that became a rabbit hole for me. Interesting!

Happy Thanksgiving to All!

Hope your Thanksgiving was nice, @C Culham. I think a lot of what you're observing when you note the disparities in adoption rates is a result of the piecemeal issuance schedule. Those parts that were issued in May tend to have higher adoption rates than those issued later. Those issued on the final date of Sep. 30 (parts 15, 16, 22, 23, 25, 32, 42, and 53) each are adopted by fewer than 10 agencies.

Regarding part 2, the Practitioner Guide states the following:

Agencies are not required to issue a separate deviation for FAR part 2 because these changes to definitions were made as part of the already issued model deviations.

Regarding the underlying sentiment of your post, I wholeheartedly agree: How on earth can anyone--from CS to CO to reviewer to contractor--track which regulation applies to which acquisition? I even spoke to one Department-level procurement analyst who told me her Department is allowing each CO to follow whichever regulation (FAR or RFO) they choose!! No doubt that many mistakes are being made regularly due to confusion over which regulation applies.

But what is the impact? I suspect there's a greater impact to efficiency than compliance. Those who are in the trenches and trying to get it right have a tall order in trying to fit the pieces together while jumping from regulation to regulation and recalling which apply to which acquisitions. And then there's the questions from industry they'll get in response to solicitations. It's got to be a headache for everyone.

The reason I don't think compliance is as big a concern is because the RFO primarily stripped rules from (vice added rules to) the FAR, A CO who erroneously follows the FAR over the RFO might be applying a stricter-than-necessary standard, but conceptually would seem to be at low risk of violating many rules. (Those who are more familiar with the RFO will undoubtedly be able to point out some interesting exceptions to this statement.)

My small agency hasn't adopted any of the RFO yet. We plan to do it all at once so there's a clean break. I think this is optimal, as it will enable us to prepare for the biggest changes and mitigate confusion once we flip the switch.

1 hour ago, FrankJon said:

Hope your Thanksgiving was nice,

It was, thank you.

1 hour ago, FrankJon said:

But what is the impact?

The impact I wonder about is with regard to claim litigation, especially post contract completion when the contract was written in the mish mash. I have vague memory of such instances where extra effort was needed to determine what rule applied when with regard to changes to the FAR. So minimal but all the same a confusion.

1 hour ago, FrankJon said:

Regarding part 2, the Practitioner Guide states the following:

As you note jumping from regulation to regulation and I will add practitioner guides! In many of Mr. Edwards writings page count is noted about the FARs growth. So is page count now FAR, RFO, practioner guide and when all said and done RFO and practioner guide? I do appreciate pointing out the guide.

2 hours ago, FrankJon said:

We plan to do it all at once

An approach that makes sense to me. Of note and again I may have missed it but what of applicable FAR supplements? One would think that "all at once" the applicable supplement would have to go through rewrite as well?

But then again I might be overthinking. Then I am back to wondering if the powers to be are thinking at all?

If anything, I find the conduct of the overhaul process, and its products, to be confusing. The overhauled parts, the model deviations, the FAR Companion, and the Practitioner Albums strike me as a confusing hassle. All in all, the process and its output reflect design and project management confusion.

It didn't have to be this way. But maybe it will get sorted out in 2026. Maybe.

It's been quite a rides since Covid, hasn't it? The world turned upside down. Especially this year: sudden chaotic change, uncertainty, anxiety, fear, disappointment, and anger. Sometimes all at once.

Take a break over the holidays:

• Read something funny, like The Inimitable Jeeves, by P.G. Wodehouse.

• If you want something soulful, read Train Dreams, by Denis Johnson. (Read it before you watch the movie!)

• If you want something encouraging, read Another Sort of Learning, or The Life of the Mind: On the Joys and Travails of Thinking, or On The Unseriousness Of Human Affairs, all by Fr. James V. Schall.

• If you want something challenging, read Another Sort of Mathematics: Selected Proofs Necessary to Acquire A True Education in Mathematics, by J. Jacob Tawney. I'm borderline illiterate in math, and even I understood and enjoyed it.

Or if you want something mystical and monumental, read Moby Dick:

"By reason of these things, then, the whaling voyage was welcome; the great floodgates of the wonder-world swung open, and in the wild conceits that swayed me to my purpose, two and two there floated into my inmost soul, endless processions of the whale, and, midmost of them all, one grand hooded phantom, like a snow hill in the air."

If any of you want to recommend a good book (or books) to take our minds off of our pains, please do so.

1 hour ago, Vern Edwards said:

If anything,

Thank you Vern...

1 hour ago, Vern Edwards said:

Read something

But does this not stray from the topic....

Yet I actually got to witness the mystical through the eyes of my grand children in a ride on the Polar Express after a read of the book, a view of the film and on a train of the same name! Not so monumental in the eyes of some but oh the joy!

It helped me keep my mind in the world of "I believe!" in all kinds of ways. May we all!

3 hours ago, C Culham said:

But does this not stray from the topic....

Yes. Sorry.

On 11/28/2025 at 5:00 AM, FrankJon said:

But what is the impact? I suspect there's a greater impact to efficiency than compliance. Those who are in the trenches and trying to get it right have a tall order in trying to fit the pieces together while jumping from regulation to regulation and recalling which apply to which acquisitions. And then there's the questions from industry they'll get in response to solicitations. It's got to be a headache for everyone.

It seems that DoD foresaw this and didn't issue a single deviation.

1 hour ago, Don Mansfield said:

It seems that DoD foresaw this and didn't issue a single deviation.

Instead, they decided to drop a 102-page DoDM 5010.12 rewrite the week before Thanksgiving: https://www.esd.whs.mil/Portals/54/Documents/DD/issuances/dodm/501012p.pdf?ver=_mt5ZD56t8d7Ft21HK3bPQ%3d%3d. 😅

How officials can talk about "speed," "common sense," and "innovation" in acquisition on the one hand, and then turn around and release a 102-page process document on a single topic on the other hand, I have no idea. I suppose it doesn't matter because few people will actually read it. Policy offices and VAO will distill it down into a few bullets that COs will be expected to follow. DAU/WAU will create an online training that people will race through. The impact will be negligible. Sure hope it was worth the years of development....

3 hours ago, Don Mansfield said:

It seems that DoD foresaw this and didn't issue a single deviation.

That's fascinating, I hadn't realized. I'm with DOI and they have been slow-walking deviations, but they have still issued a few. The Executive Order was dated April 15 and called for results within 180 days, which would have been October 15. RFO model deviations were done by September 30, with Part 2 and 52 done October 28 and version 2 of the Companion Guide dated October 30. I wonder what's going on behind closed doors with DoD/DoW having issued zero deviations? DFARS obviously complicates their compliance, but still.

Because there are just too many pieces to coordinate within DoD. If someone asked for the exact official time of day, it would take a couple weeks for official sign off

On 11/29/2025 at 10:44 AM, Vern Edwards said:

It's been quite a rides since Covid, hasn't it? The world turned upside down. Especially this year: sudden chaotic change, uncertainty, anxiety, fear, disappointment, and anger. Sometimes all at once.

Take a break over the holidays:

• Read something funny, like The Inimitable Jeeves, by P.G. Wodehouse.

• If you want something soulful, read Train Dreams, by Denis Johnson. (Read it before you watch the movie!)

• If you want something encouraging, read Another Sort of Learning, or The Life of the Mind: On the Joys and Travails of Thinking, or On The Unseriousness Of Human Affairs, all by Fr. James V. Schall.

• If you want something challenging, read Another Sort of Mathematics: Selected Proofs Necessary to Acquire A True Education in Mathematics, by J. Jacob Tawney. I'm borderline illiterate in math, and even I understood and enjoyed it.

Or if you want something mystical and monumental, read Moby Dick:

"By reason of these things, then, the whaling voyage was welcome; the great floodgates of the wonder-world swung open, and in the wild conceits that swayed me to my purpose, two and two there floated into my inmost soul, endless processions of the whale, and, midmost of them all, one grand hooded phantom, like a snow hill in the air."

If any of you want to recommend a good book (or books) to take our minds off of our pains, please do so.

I read this book but this one piece always makes me feel good

https://www.thesr71blackbird.com/Aircraft/Stories/sr-71-blackbird-speed-check-story

39 minutes ago, formerfed said:

Because there are just too many pieces to coordinate within DoD. If someone asked for the exact official time of day, it would take a couple weeks for official sign off

Here's the problem: In his Arsenal of Freedom speech at the National War College on November 7, the Secretary of War said: "We mean to save the bureaucracy from itself.... "

But, on the same day, in his memo to the Pentagon leadership, Transforming the Defense Acquisition System into the Warfighting Acquisition System to Accelerate Fielding of Urgently Needed Capabilities to Our Warriors, he said:

To ensure timely and effective implementation, the USW(A&S) will chair monthly Acquisition Acceleration Reviews to track the establishment of Portfolio Acquisition Executives, portfolio scorecard performance, removal of unnecessary barriers, and adoption of this directive. Reviews will focus on timelines for delivery of combat capability and revitalization of the industrial base to expand competition. We will continually adjust as we identify additional opportunities to optimize our acquisition processes for agility.

I have worked at a major HQ in DC. I wonder if the Secretary is aware of the amount of bureaucracy that will be used to prepare for those monthly meetings.

The only way to save the bureaucracy from itself is to destroy it as it now exists.

I wish that he had said he was abolishing the office of the Undersecretary of War for Acquisition and Sustainment, USW(A&S), and firing all the deputy and assistant secretaries. Then everyone would have known that this would not be just another acquisition reform project to survive until regime change.

🫡

That's when they would have known that he was serious.

😳

It looks like somebody agrees with me:

American Enterprise Institute - AEI

The Sabotage of Secretary Hegseth’s Acquisition Reform In...

Real acquisition reform doesn’t have a chance unless leadership quickly overturns the bureaucratic nonsense and backtracking.

12 hours ago, Vern Edwards said:

The only way to save the bureaucracy from itself is to destroy it as it now exists.

The RFO is neither "revolutionary" nor a thorough removal, renovation, and remake but an insistance and furtherance of that which has strangled Federal acquisition with bureaucratic regulation and policy. I dare say that the lynch pin of "common sense" as expressed in the EO has not prevailed.

Interesting that at today's cabinet meeting Russell Vought, Director of the Office of Management and Budget, spoke of the FAR update. The 30,000 foot view I guess.

See this (below) link and move ahead to 49:35 to hear Vought's comments.