DoD, GSA, NASA Extend Change Order Data Collection
Published Date: 4/11/2025
Notice
Summary
The Department of Defense, GSA, and NASA want to keep collecting info about change orders in government contracts for three more years. This helps them track and manage contract changes better, making sure everything runs smoothly. If you’re involved in federal contracts, you might need to keep providing this info, and they’re asking for your feedback by June 10, 2025.
Analyzed Economic Effects
5 provisions identified: 0 benefits, 4 costs, 1 mixed.
Separate accounting when changes exceed $100,000
Under FAR 52.243-6, a contracting officer may require change order accounting when the estimated cost of a change or related changes exceeds $100,000. When required, the contractor must maintain separate accounts of incurred segregable direct costs allocable to the change until the parties agree to an equitable adjustment or the dispute is resolved.
Notification clause and $1,000,000 threshold
FAR 52.243-7 (Notification of Changes) is intended mainly for negotiated R&D or major weapon systems/supply contracts and shall not be used if the contract amount is expected to be less than $1,000,000, unless the contracting officer anticipates situations that may lead to alleged changes. When used, the contractor must notify the Administrative Contracting Officer in writing and provide detailed facts (date, nature, people involved, documents, effects on line items, labor/materials, delays, estimated adjustments, and response time needed).
Information collection extension proposed
DoD, GSA, and NASA say OMB has approved the information collection (OMB Control No. 9000-0026) for use through August 31, 2025 and propose to extend that approval for three additional years beyond the current expiration date. The agencies are accepting public comments on this proposal through June 10, 2025.
30-day deadline to assert change claims
If you are a federal contractor using FAR clauses 52.243-1, -2, or -3, you must assert your right to an adjustment within 30 days after receipt of a written change order. For certain construction/demolition contracts under FAR 52.243-4, you likewise must assert within 30 days after receipt of a written change order or written notice (unless extended by the Government).
Estimated annual respondent burden
The agencies estimate 4,774 respondents, 11,532 total annual responses, and 11,532 total annual burden hours (9,656 reporting hours + 1,876 recordkeeping hours) associated with this collection (OMB Control No. 9000-0026).
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Key Dates
Department and Agencies
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