The quiet rewrite of FAR Part 15 — what changed and why it matters

The latest FAR Part 15 update did not get the trade-press attention it deserved, but it materially changes how contracting officers document source selection rationale and how protests get adjudicated.

Three changes stand out. First, the documentation standard for tradeoff decisions has been tightened — narrative justifications must now address each significant strength and weakness identified in the consensus report.

Second, the threshold for clarifications versus discussions has been clarified, which closes a loophole that had allowed some agencies to gather what amounted to discussions while calling them clarifications.

Third, debriefing requirements have expanded for awards above the simplified acquisition threshold, giving offerors more substantive feedback and — implicitly — more grounds for protest.

For contractors, the practical implication is that proposal hygiene matters more than ever. Every claim should be evidenced, every staffing assertion verifiable, and every past performance reference recent and relevant.