independent
Contractors must now verify which FAR version governs each contract
A year into rolling model deviations, agency implementation is uneven enough that clause applicability is a contract-by-contract question, not an assumption.
The FAR Council has released model deviation text for all FAR parts under the RFO initiative, launched via EO 14275 and OMB M-25-26 (May 2, 2025). Agencies had 30 days to implement each tranche via class or individual deviations, and they are doing so at different speeds. The result: which clauses govern a given contract now depends on the agency, bureau, and buying activity. Covington flags a compounding problem: procurement systems often lag the policy, meaning contract documents may not yet reflect adopted deviations. Contractors cannot treat the codified FAR as a reliable proxy for what is actually in their contracts.