Federal Contract Reviews Will Ask Six Questions, None on Results

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Most of what gets written about buying covers the part before the money moves: the requirement, the competition, the award. Then people go back to work.

One way to tell whether a set of buying rules has any hold on what happens later is to look for a review that comes back on a clock, in writing, whether or not anybody asks for it. Federal buying has one of those, in the rules for ordering off the General Services Administration’s schedules, one of the standard channels for routine federal purchasing. At least once a year the buyer has to make a written determination about any blanket purchase agreement it holds, the standing arrangement an agency sets up with a schedule supplier for repeat needs.

Those rules are in the middle of an overhaul. The review has survived every step of it and has grown. Put side by side, the codified regulation, the deviation text GSA put in place last November, and the proposal published this September show the review going from three items to six. Nothing that was added along the way asks what the purchase produced.

Twenty Provisions Become One

Executive Order 14275 set off a rewrite of the Federal Acquisition Regulation, the rulebook federal agencies buy under. The first phase did not wait for rulemaking. In August 2025 GSA issued a class deviation that set up the schedule ordering procedures in its own regulation instead of the FAR. It took effect that November and was written for every ordering activity that uses the schedules. Agencies adopted the matching change to the FAR on their own dates. The Defense Department’s deviation is dated March 6, 2026.

Formal rulemaking is the second phase, and it reached Part 8 this September. The FAR Council published its proposal on September 18. In the regulation as codified, the subpart on schedule ordering runs twenty numbered sections and subsections. Under the proposal it runs one, and that one tells agencies to follow the ordering procedures GSA establishes at 48 CFR 538.71.

GSA published its own half on September 22. The proposal says what the move costs in text: the ordering procedures go “from over 10,000 words to approximately 2,600.”

The One Review That Comes Back

The codified rule requires the contracting officer to review a blanket purchase agreement and determine in writing, at least once a year, whether the schedule contract is still in effect, whether the agreement “still represents the best value,” and whether estimated quantities have been exceeded and additional price reductions can be obtained. Three items.

The deviation text lists five. Best value and the quantity check stay, and the schedule contract still has to be in effect. The price question becomes its own item and widens to “price discounts or other concessions.” One item is new: whether the “BPA ordering procedures are being followed.”

The proposal published in September keeps that list, rewords the quantity item to refer to total estimated value, and adds a sixth item for order-level materials, the products and services bought in support of an order that are not on the supplier’s schedule contract. Where an agreement includes them, the review asks whether their pricing is still fair and reasonable, whether they are still necessary, and whether they should be added to the schedule contract.

So the list is set to double, and what was added is a procedure check, a wider price question, and a question about order-level materials.

Best Value Is A Judgment Made At Award

The term carrying the weight in that review is best value, and the FAR defines it. “Best value means the expected outcome of an acquisition that, in the Government’s estimation, provides the greatest overall benefit in response to the requirement.” That is the codified definition, and the Part 2 rewrite proposed in June carries it across word for word.

An expected outcome, in the government’s estimation, is a forecast. The codified ordering rule treats it as settled once the steps are followed: by placing an order using the schedule procedures, “the ordering activity has concluded that the order represents the best value.” The codified review item points back to that sentence. The deviation and the proposal drop it and tell the buyer to award to the contractor “that represents the best value (as defined by FAR 2.101).” In every version the best value the buyer is told to find is a judgment made at award, before anything has been delivered.

Read that way, the first item on the yearly list asks whether a forecast made at award still looks right. Contracting offices can put more into the review. The list itself does not ask for a performance rating or customer feedback, and it can be answered in full without anyone recording what the purchase has produced.

What The Rewrite Says It Is For

GSA’s proposal repeats the stated purpose of the overhaul, which “is designed to streamline compliance for contracting professionals, improve acquisition speed and agility, and reinforce mission outcomes over process formalities.”

The stated aim is to put outcomes ahead of process. Everything added to the one recurring written review in these procedures concerns process, price or order-level materials. The word outcome appears nowhere in the proposed procedures, only in the preamble explaining what the rewrite is for. Value appears four times, twice as best value and twice as total estimated value. Benefit, return on investment and business case do not appear at all, and neither does any form of the word measure.

This is a narrow claim. Other parts of the FAR cover contract administration and quality assurance, and the codified FAR separately requires a past performance evaluation at least once a year on schedule orders above the simplified acquisition threshold. Those evaluations rate how the contractor performed under the contract. None of that is in this proposal, and none of it is part of this review.

What Goes In The File

Nothing stops a buyer from putting more in that determination. The list is a floor.

On the vendor side we built the business cases buyers were handed, and nobody ever asked us to come back afterward and add up what happened. Most Companies Set Goals for Purchases and Never Check Them describes the step that was missing: going back, on a planned date, to what the purchase was defined to produce and comparing it with what happened. The federal review already has the planned date.

A buyer can supply the rest before the agreement is signed, by writing down what the purchase has to produce, how it will be measured, what has to stay true for the measurement to hold, what evidence the supplier will supply, and how competing offers get compared on that basis, and then putting it in the agreement. The proposed procedures already require an agreement to carry sufficient “detail about the need, such as scope of work or objectives,” so the place for it exists. The yearly determination then has something to check against besides a price list. That written statement is a Request for Value.

A supplier that delivered has a lot to gain from this. A completed determination says the price and the paperwork are in order, and a performance evaluation rates the supplier against the contract. Neither has to say whether the purchase produced what it was bought for. A determination that records what the purchase produced gives the supplier that delivered something to point to at renewal that a competitor’s promise cannot match.

The comment periods were set to close on October 19 for the FAR case and October 22 for the GSA rule. When the final rules appear, the review is the part worth reading closely.

References: Federal Register 2026-19162 (FAR Case 2026-003, Parts 8, 12, 13, 15, 38, 44 and 51, published September 18, 2026, comment period to October 19, 2026); Federal Register 2026-19331 (GSAR Case 2026-G501, Federal Supply Schedule Ordering Procedures, published September 22, 2026, comment period to October 22, 2026); GSA Class Deviation RFO-2025-FSS-GSAR 538 (issued August 13, 2025, effective November 3, 2025); Department of Defense Class Deviation 2026-O0049 (dated March 6, 2026); Federal Register 2026-12559 (FAR Part 2 rewrite, published June 23, 2026); 48 CFR 2.101, 8.404, 8.405-3 and 42.1502 as codified.

Keep reading: ACT II · Chapter 9: The Value Control Loop