FAR Part 52 Lineout Highlights Push Toward Transparency, Performance Oversight, and Industrial Base Integration

The May 2, 2025 lineout of FAR Part 52 reveals a targeted set of proposed updates focused on implementing and reinforcing acquisition policies through specific clauses and provisions. Though these revisions are not yet finalized, they complement broader regulatory reform efforts under the Trump Administration and merit close attention from federal contractors. These updates, if adopted, will directly impact solicitation language and contract execution requirements, particularly for contractors involved in major systems development, earned value reporting, and feedback mechanisms related to acquisition performance.

Among the most notable additions is the introduction of FAR 52.201-1, “Acquisition 360: Voluntary Survey.” This new solicitation provision operationalizes the push for greater contractor engagement and feedback by encouraging offerors to submit input on the preaward and debriefing processes. The feedback, which must be submitted within 45 days of award and is voluntary and anonymous unless self-disclosed, is explicitly stated to have no bearing on the award decision. While it provides no legal rights or protest grounds, the provision formalizes an avenue for contractors to influence acquisition process improvements by offering candid, retrospective evaluations of agency behavior. Contractors should take this seriously, as aggregated feedback could inform future changes to procurement practices or even result in increased scrutiny of specific contracting offices.

Further, the revised FAR 52.234 clauses—particularly 52.234-1 through 52.234-4—underscore the increasing prominence of Earned Value Management Systems (EVMS) in major federal acquisition efforts. These clauses expand the application of EIA-748-compliant EVMS requirements to both prime and subcontractors, and formalize detailed expectations around plan submission, government reviews, and baseline control. Importantly, 52.234-2 and 52.234-3 outline the preaward and postaward Integrated Baseline Review (IBR) provisions, signaling that IBRs will be a routine part of the contract lifecycle where EVMS is applied.

Under the proposed 52.234-2 clause, offerors must either certify that their system has been found compliant by the Cognizant Federal Agency (CFA) or submit a detailed compliance plan. The clause mandates that the compliance plan differentiate between existing systems and proposed changes, describe application to subcontractors, and provide third-party or internal assessments. Additionally, it calls for specific milestone forecasts, ensuring agencies can monitor the timeline for achieving full compliance with EIA-748. This degree of detail will necessitate that offerors—especially those new to government work—invest time and resources in developing robust systems and documentation prior to award.

The companion clause at 52.234-3 mirrors these requirements for postaward IBRs, reinforcing that EVMS planning and compliance do not stop at award but must be maintained throughout execution. Both clauses emphasize collaborative risk identification and mitigation through the IBR process, with government and contractor teams jointly evaluating the realism of scope, schedule, budget, and available resources.

Clause 52.234-4 then solidifies post-award EVMS compliance as a continuing obligation of the contractor. If a compliant system is not already in place at award, the contractor must apply their current system and follow their submitted compliance plan, subject to Contracting Officer approval. The government is granted wide latitude to monitor system performance, demand access to pertinent records, and require Integrated Baseline Reviews at option exercise or major contract modification milestones. The clause also introduces a requirement for contractors to obtain approval from the CFA for any proposed changes to their EVMS and stipulates a 30-day response window for CFA review. These new expectations reflect a government-wide emphasis on transparency, cost control, and early identification of performance risks.

Finally, the reassertion of 52.234-1, the clause implementing Title III of the Defense Production Act, illustrates an ongoing alignment between acquisition and industrial policy. This clause mandates that contractors refer requests for testing and qualification of Title III-supported resources to the Contracting Officer, and, if directed, perform such tests. The government will furnish the materials and adjust contract pricing accordingly. Contractors are also obligated to flow this clause down to all subcontractors. The intent is to ensure that industrial resources developed with federal investment under Title III are properly validated and integrated into the broader defense industrial base, thus reinforcing domestic supply chain resilience and preparedness.

Overall, this FAR Part 52 lineout—though limited in volume—reveals a significant and evolving regulatory architecture underpinning today’s acquisition landscape. It promotes greater feedback from the private sector, tightens performance management through EVMS and IBR processes, and more tightly links industrial policy with contracting execution. While these provisions remain in draft form and are subject to change, contractors would be wise to begin internal readiness planning, particularly around EVMS capability and acquisition lifecycle compliance.

Disclaimer: This blog post is based on a proposed draft of FAR Part 52 and reflects a preliminary analysis of changes that have not yet been formally adopted. This summary is intended for informational purposes only and does not constitute legal advice or official guidance. Contractors should consult legal counsel or regulatory experts before acting on any information contained herein.