Dear UAH Research Community,
I want to share an update regarding recent changes to the Federal Acquisition Regulation (FAR), including the newly released Revolutionary Federal Acquisition Regulation Overhaul.
On September 30, 2025, federal agencies issued model deviations intended to modernize and simply FAR text. While formal rulemaking is pending, this release was known as Phase I: Model Deviations and Initial Changes. Phase II Formal Rulemaking and Stakeholder input is expected to roll out this year.
I am currently participating in training on these changes and also serve on the Federal Demonstration Partnership (FDP) Contracts Subcommittee, which is reviewing and reporting on these changes as they happen. These changes are intended to simplify federal acquisition regulations, but during the transition period, they introduce agency-specific deviations, interim guidance, and evolving compliance expectations.
The goal of this training and FDP work is to understand not only what has changed on paper, but how those changes will affect sponsored research, contracts, and compliance at UAH. Key changes that may impact the University include:
* Plain-language rewrite and restructuring of the FAR. While intended to improve clarity, this has also resulted in consolidated sections, renumbering, and the use of “reserved” clauses—requiring closer review of contracts to confirm what is (and is not) actually applicable.
* Agency-specific deviations during the transition period. Many agencies are operating under interim deviations while formal rulemaking continues, creating a temporary “moving target” compliance environment.
* Sunset clauses for non-statutory FAR provisions. Certain requirements will now expire unless renewed, shifting the compliance burden from simply “following the clause” to actively tracking whether it still exists.
* Greater emphasis on discretion and judgment. Companion guides and practitioner tools support implementation but do not carry regulatory authority—meaning institutional policies, contract language, and internal controls remain critical.
* Increased coordination needs across campus. Sponsored Programs, Procurement, Technology Transfer, and Legal will need to work closely together as these changes affect prime contracts, subcontracts, purchasing, and intellectual property considerations.
What This Means for PIs Right Now
* No immediate action is required for existing awards unless notified by OSP or the sponsor.
* Expect closer review of contract terms on new awards and amendments, particularly where clauses are marked “reserved” or reflect interim agency deviations.
* Timelines may be affected as agencies and institutions navigate transitional guidance—this is normal during regulatory change.
* Continue to route all agreements, modifications, and subcontracts through OSP to ensure appropriate review and institutional protections remain in place.
* Ask early, not late. If something in an award or modification looks different from what was expected, flag it—questions now prevent issues later.
We are closely monitoring agency guidance and will continue to assess how these revisions affect proposal submissions, awards, and ongoing contracts. As more clarity emerges, we will share targeted guidance and training opportunities with the research community. A dedicated webpage is available on the Office of Sponsored Programs (OSP) website to provide timely updates on these changes as they occur, including practical information on how the revisions may impact UAH. View FAR updates and guidance.
Finally, a personal note: while the title "Revolutionary Federal Acquisition Regulation Overhaul" sounds wonderfully calming, I can assure you that, much like reorganizing a filing cabinet, the process is less about things disappearing and more about figuring out where they were moved. Progress, yes… just not always in a straight line.
If you have questions or concerns about how these changes may affect your research or contracts, please contact the Office of Sponsored Programs. More updates to come.
Best regards,
Gloria Greene
AVP, Contracts and Grants, Research Compliance
