Understanding the New FAR Part 34 Rewrite: What It Means for Government Contractors

Federal procurement is going through a major transformation—and it’s not just about streamlining paperwork. The FAR (Federal Acquisition Regulation) is being overhauled to improve clarity, empower decision-makers, and make the acquisition process more effective.

While much attention has been focused on FAR Part 1 (the guiding principles and framework), FAR Part 34 has also received a crucial rewrite—and it deserves your attention.

So, what’s new in FAR Part 34?

This section deals with Major System Acquisition, a key area for contractors working on complex, high-value projects like aerospace, defense, energy systems, infrastructure, and large-scale technology development. Whether you’re a prime or subcontractor, understanding the new rules is essential for staying compliant—and competitive.

Let’s break it all down in plain English.

What Is FAR Part 34?

FAR Part 34 governs Major System Acquisition—in other words, any large-scale procurement effort involving the design, development, and delivery of major government systems or platforms. Think missile defense systems, military aircraft, communications infrastructure, or critical cybersecurity systems.

The revised FAR Part 34 is divided into two main subparts:

• Subpart 34.1 – Focuses on post-award policies related to using industrial resources developed under the Defense Production Act (DPA), Title III
• Subpart 34.2 – Establishes requirements for using an Earned Value Management System (EVMS) to monitor performance and cost

Each of these areas brings with it new obligations—and new opportunities—for government contractors.

Subpart 34.1 – Post-Award Use of Title III Industrial Resources

Let’s start with Subpart 34.1, which is all about how the government uses industrial resources that were developed or expanded with assistance from Title III of the Defense Production Act.

What is Title III?

Title III of the Defense Production Act (DPA) allows the federal government to invest in domestic production capacity to support national defense. This means the government can fund manufacturers to expand their operations, develop new technologies, or strengthen supply chains for critical materials.

In practice, this support often leads to new or improved materials, components, or manufacturing techniques that are used in major systems.

What Does Subpart 34.1 Cover?

This section creates a structured policy for when and how these Title III-developed resources are tested and qualified for use in government contracts.

Key changes include:

1. Government Pays for Testing

If the government wants to use a resource developed under Title III in a system it’s procuring, it will generally cover the cost of testing and qualification. That’s a big win for contractors who might otherwise bear those expenses themselves.

2. Triggering the Testing Process

When a Title III contractor requests that a resource be approved for use, the contracting officer must review the request and determine:

• Is the resource relevant to a major system or supply item?
• Are there enough remaining quantities to justify the cost of testing?

If both boxes are checked, the contracting officer must modify the contract to require testing of that Title III-developed resource.

3. Clause at FAR 52.201

All contracts for major systems or supply items must now include the clause at FAR 52.201, which references the use of industrial resources developed under Title III.

Why It Matters to Contractors

If you’re involved in manufacturing parts, materials, or technologies funded through the DPA, this update formalizes your pathway into federal programs.

And if you’re a prime contractor or system integrator, this change affects you too. You may be required to test and integrate Title III-developed components into your systems, potentially altering timelines, sourcing strategies, or even cost structures.

Bottom line? It’s a more transparent, organized process that clarifies expectations—but you need to stay on top of what’s required.

Subpart 34.2 – Earned Value Management System (EVMS)

Now let’s talk about Subpart 34.2—this one’s focused on the Earned Value Management System, or EVMS.

EVMS is a project management system that helps government agencies and contractors track cost, schedule, and performance in an integrated way. It’s a powerful tool—but also one with detailed reporting requirements.

What’s New in Subpart 34.2?

The rewritten section doesn’t introduce revolutionary concepts but does clarify existing EVMS policy and standardize how it’s applied. Here’s what contractors need to know:

1. EVMS Is Required for Major Development Contracts

If you’re bidding on or managing a major acquisition for development, expect to use EVMS. This includes projects in defense, aerospace, IT infrastructure, and large-scale construction or manufacturing.

2. Monthly Reports Are Mandatory

Agencies must now require contractors to submit monthly EVMS reports. These include performance metrics that compare actual cost and schedule data against baselines.

This level of transparency is intended to ensure projects stay on track—and that any cost or schedule overruns are flagged early.

3. EVMS Applies to Subcontractors, Too

If you’re a subcontractor on a project with an EVMS requirement, the same expectations apply to you. That means you must align your reporting practices with the prime contractor’s system.

4. Agencies Must Review EVMS Plans Before Award

If a solicitation includes EVMS requirements, contractors must submit a plan as part of their proposal, and agencies are now required to review that plan’s adequacy before awarding the contract.

This creates a front-loaded vetting process—so be ready to prove you’ve got the systems and procedures in place.

5. Integrated Baseline Reviews Are Mandatory

Agencies will conduct Integrated Baseline Reviews (IBRs) for every EVMS-required contract. This is a formal review process where both the agency and the contractor align on the project’s performance baseline.

What Contractors Should Do

If you’re working on (or pursuing) major system development contracts, now is the time to:

• Ensure your EVMS is compliant and can produce monthly reports
• Train your team on baseline tracking and reporting
• Prepare a contractor EVMS plan that aligns with OMB Circular A-11 and FAR 52.234-4
• Engage with your subcontractors to ensure alignment on EVMS requirements

This is not optional—it’s now embedded in every major acquisition for development.

Why Strategic Engagement Matters More Than Ever

With both Subparts 34.1 and 34.2 emphasizing compliance, transparency, and performance, contractors must think strategically—not just about winning awards, but about maintaining strong relationships with contracting officers.

These updates underscore the importance of:

• Understanding what COs are looking for in terms of compliance and risk mitigation
• Communicating clearly about your performance and capabilities
• Aligning your proposal language with mission needs

At FedBiz Access, we provide more than just paperwork help. We offer direct-to-contracting-officer marketing through our Federal Connections Package and MatchMaker services, putting your business in front of the people who matter most.

Need help with messaging or knowing how to speak the language of contracting officers? We also offer engagement coaching, so you’re ready when the opportunity strikes.

Action Steps for Government Contractors

Here’s what you should be doing right now to align with the new FAR Part 34:

✅ Review Your Projects and Clients

Are you working on—or bidding on—major system acquisitions? Make sure your contracts comply with EVMS and Title III-related requirements.

✅ Update Your Capability Statement

If you work with Title III-developed resources or have EVMS experience, showcase that clearly. Contracting officers want to see that you’re prepared to handle the complexity.

✅ Train Your Team

Make sure your contract and project management teams understand what the new EVMS requirements mean and how to execute accordingly.

✅ Engage Early

Don’t wait until an RFP drops. Use market intel tools like FedBiz365 to identify opportunities and get in front of contracting officers ahead of time.

Final Thoughts: Part 34 Brings More Clarity—And More Accountability

The revised FAR Part 34 may not grab headlines like other policy changes, but it has real implications for how contractors deliver, report, and engage in major system acquisitions.

From integrating Title III-developed components to tracking performance with EVMS, the federal government is signaling a shift toward tighter oversight, better accountability, and more efficient spending.

Contractors who understand and embrace these updates will be the ones who stand out.

Need Help Navigating These Changes?

At FedBiz Access, we’ve helped thousands of businesses succeed in the government marketplace over the past 24 years. From registration and certification to GSA Schedule preparation, capability statement design, engagement training, and contracting officer outreach, we’ve got you covered.

? Schedule a complimentary consultation with a FedBiz Specialist today

Let’s align your strategy to meet the moment—and win.