Action Kit: FAR (Federal Acquisition Regulation) Part 27 Information Collection Extension

Event Type: FAR Update (Administrative)

Severity: INFO

Impact: Routine extension of existing intellectual property compliance requirements

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Immediate Actions (This Week)

• [ ] Review current FAR Part 27 compliance posture — Verify your existing contracts contain proper patent rights, data rights, and copyright clauses matching current FAR 52.227 series provisions
• [ ] Audit active proposals — Ensure any proposals in development or under evaluation include accurate FAR Part 27 clause representations and certifications
• [ ] Brief contracts and legal teams — Notify stakeholders that no immediate regulatory changes are expected; this is an administrative extension of existing information collection requirements
• [ ] Document current IP management practices — Confirm your organization maintains proper records for technical data rights assertions, SBIR data rights claims, and copyright registrations as required under existing FAR Part 27 provisions

Short-Term Actions (30 Days)

• [ ] Conduct IP rights training refresher — Schedule a 30-minute session for capture managers and proposal writers on FAR 52.227-14 (Rights in Data—General), FAR 52.227-11 (Patent Rights), and DFARS (Defense Federal Acquisition Regulation Supplement) 252.227-7013/7014 for DoD (Department of Defense) contracts
• [ ] Update proposal templates — Verify your standard compliance matrices and Section L response templates include current FAR Part 27 clause language, particularly for NAICS codes in software development (541511, 541512), R&D (541712, 541715), and aerospace manufacturing (336411-336419)
• [ ] Review subcontractor flow-down requirements — Ensure your standard subcontract terms properly flow down patent rights, data rights, and copyright provisions to suppliers, especially for contracts with NASA, DOE, and DoD
• ] **Assess CUI (Controlled Unclassified Information) handling procedures** — Cross-reference your FAR Part 27 data rights assertions with NIST SP 800-171 (NIST Special Publication 800-171) controls for protecting technical data marked as Controlled Unclassified Information (see [CUI-Safe CRM Guide (/insights/cui-safe-crm-guide) for operational guidance)

Long-Term Actions (90+ Days)

• [ ] Establish IP rights decision matrix — Develop a standardized framework for capture teams to evaluate when to accept standard data rights clauses versus negotiate for alternative provisions (e.g., limited rights data, restricted computer software rights)
• [ ] Implement IP portfolio tracking — Create a centralized repository linking your organization's patents, copyrights, and proprietary technical data to specific contract vehicles (OASIS+, SEWP, Alliant 2, CIO-SP4) where those assets provide competitive differentiation
• [ ] Conduct annual FAR Part 27 compliance audit — Schedule a comprehensive review of all active contracts to verify proper marking of deliverables, timely assertion of rights, and compliance with government purpose rights limitations
• [ ] Develop SBIR/STTR data rights strategy — For organizations pursuing Small Business Innovation Research contracts, establish clear policies for protecting SBIR data rights under FAR 52.227-20 while maximizing commercialization opportunities
• [ ] Integrate IP compliance into capture process — Build FAR Part 27 considerations into your 9-gate capture methodology, with specific decision points at Gate 3 (Qualify) and Gate 5 (Propose) to assess IP implications

Compliance Checklist

This administrative extension maintains existing information collection requirements. Verify your organization continues to meet these FAR Part 27 obligations:

• [ ] FAR 52.227-11 (Patent Rights—Ownership by the Contractor) — Properly disclose subject inventions to contracting officers within required timeframes; maintain invention disclosure procedures
• [ ] FAR 52.227-14 (Rights in Data—General) — Correctly mark technical data deliverables as unlimited rights, limited rights, or proprietary; maintain documentation supporting rights assertions
• [ ] FAR 52.227-16 (Additional Data Requirements) — Respond to government requests for data within contractual timelines; track data item descriptions (DIDs) for each deliverable
• [ ] DFARS 252.227-7013 (Rights in Technical Data—Noncommercial Items) — For DoD contracts, apply proper restrictive markings; maintain challenge/validation procedures for asserted rights
• [ ] DFARS 252.227-7014 (Rights in Noncommercial Computer Software and Noncommercial Computer Software Documentation) — Mark software deliverables with appropriate legends; document basis for restricted rights claims
• [ ] FAR 52.227-20 (Rights in Data—SBIR Program) — For SBIR contracts, protect data rights for minimum 20-year period; mark SBIR data appropriately
• [ ] Copyright registration and notice requirements — Maintain records of copyright registrations for deliverable works; include proper copyright notices on documentation
• [ ] Subcontractor IP flow-down — Ensure subcontracts include appropriate FAR 52.227 clauses; obtain necessary IP rights from suppliers to satisfy prime contract obligations
• ] **CUI marking and safeguarding** — Apply NIST SP 800-171 controls to technical data containing CUI; coordinate FAR Part 27 data rights with DFARS 252.204-7012 cybersecurity requirements (reference [CMMC (Cybersecurity Maturity Model Certification) Compliance Guide (/insights/cmmc-compliance-guide) for defense contractors)

Resources

• FAR Part 27 (Patents, Data, and Copyrights) — https://www.acquisition.gov/far/part-27 (https://www.acquisition.gov/far/part-27)
• DFARS Part 227 (Patents, Data, and Copyrights) — https://www.acquisition.gov/dfars/part-227-patents-data-and-copyrights (https://www.acquisition.gov/dfars/part-227-patents-data-and-copyrights)
• OMB Information Collection Review Process — https://www.reginfo.gov/ (https://www.reginfo.gov/)
• NASA FAR Supplement 1827 (Patents, Data, and Copyrights) — https://www.hq.nasa.gov/office/procurement/regs/nfs1827.htm (https://www.hq.nasa.gov/office/procurement/regs/nfs1827.htm)
• DOE Acquisition Regulation (DEAR) Part 927 — https://www.acquisition.gov/dear/part-927-patents-data-and-copyrights (https://www.acquisition.gov/dear/part-927-patents-data-and-copyrights)
• Secure Operations Guide — Internal resource (/insights/secure-operations-guide) for integrating IP compliance with operational security

How Cabrillo Club Automates This

Cabrillo Signals War Room already detected this OMB submission within minutes of publication and delivered this briefing to your dashboard. The platform continuously monitors Federal Register notices, agency regulatory dockets, and OMB's information collection review pipeline so you never miss administrative actions that could signal future policy shifts. While this particular event is routine, War Room's pattern recognition identifies when seemingly minor extensions precede substantive regulatory changes—giving you early warning to adjust capture strategies.

Cabrillo Signals Intelligence Hub has automatically tagged this event with the 29 affected NAICS codes (spanning software development, aerospace manufacturing, R&D services, and IT) and nine primary agencies (DOD, NASA, DOE, DHS (Department of Homeland Security), HHS, DOT, DOC, VA, GSA (General Services Administration)). Use the saved search feature to monitor SAM.gov (System for Award Management) for new solicitations matching this profile—particularly opportunities on OASIS+, SEWP, Alliant 2, and CIO-SP4 where FAR Part 27 data rights negotiations significantly impact pricing and technical approaches. Set up alerts for RFPs containing FAR 52.227-14 or DFARS 252.227-7013 to ensure your capture team reviews IP implications during Gate 3 qualification.

Proposal Studio (Proposal OS) maintains your organization's IP portfolio as structured data—linking patents, copyrights, and proprietary technical data to specific past performance examples and win themes. When generating compliance matrices for new proposals, the AI automatically populates FAR Part 27 clause responses based on your standard IP positions, flags contracts where alternative data rights provisions may provide competitive advantage, and ensures subcontractor flow-down language matches prime contract requirements. The bid/no-bid decision engine factors IP ownership implications into probability of win (Pwin) scoring, particularly for R&D contracts where data rights directly affect commercialization potential.

Proposal Studio Workflow Tracker routes FAR Part 27 compliance reviews to your contracts and legal teams at Gate 5 (Propose), ensuring technical data rights assertions receive proper legal review before submission. The 9-gate workflow automatically generates audit-ready documentation packages linking each deliverable's data rights classification to supporting technical rationale—critical for surviving government challenges to asserted restrictions. For contracts requiring CUI protection, Workflow Tracker coordinates FAR Part 27 marking requirements with NIST SP 800-171 safeguarding procedures, ensuring your Secure Operations Guide (/insights/secure-operations-guide) protocols align with contractual IP obligations.

Explore these features in your Cabrillo Club dashboard to transform routine compliance monitoring into competitive intelligence. While this FAR Part 27 extension requires no immediate action, the platform's automation ensures you're positioned to respond instantly when substantive regulatory changes emerge.

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