General Expectations
During a shutdown, the administration, distribution, and funding of federal contracts and grants will be disrupted. Based on past shutdowns, faculty and staff with awarded grants or contracts in active performance periods have typically been able to continue incurring many project-related expenditures during short-term interruptions.
During a shutdown, faculty and staff should be aware that they likely will not be able to:
Receive new grant or contract funding.
Communicate with program managers or other federal officials not designated as “essential”.
Host federal site visits.
Obtain required approvals or technical assistance from federal agencies.
Although things may work differently this year, we anticipate a similar pattern for this shutdown, and we are closely monitoring for any new directives. Please note that longer shutdowns introduce greater complications and uncertainties.
While some agencies may announce emergency contact procedures, in general, federal personnel will not be available during a government shutdown. Once the shutdown ends, operations may resume gradually, and delays should be expected. Please do not anticipate an immediate return to normal operations.
Proposals & Application Systems
In the past, proposal preparation systems have remained online during shutdowns. However:
Agency Help Desks will likely be unavailable.
Proposals are not expected to be reviewed or processed until normal operations resume.
Awards (Including Just-in-Time Requests)
Federal agencies are not expected to issue new notices, awards, or other actions during the shutdown. This includes:
New or renewal awards
Continuation awards
Supplements and incremental funding
Agencies are also unlikely to request pre-award or mid-award documents (e.g., revised budgets, just-in-time requests) during this period.
Spending on Active Awards
Unless we receive different direction, existing federally funded grants and cooperative agreements may continue spending until obligated funding is exhausted.
Similarly, contracts and other transaction agreements may continue spending until obligated funding is exhausted unless a stop-work order has been issued by the funding agency (which may occur under a shutdown).
If a stop-work order is received, please contact the CGA Awards Group .
Technical and Financial Reports
Electronic reporting systems are expected to remain available, and reports must still be submitted by their original deadlines.
If a technical report submission fails, investigators should generate a Help Ticket to document the attempt to file the report on time. Tickets will likely still be available online even if the Help Desks are not staffed.
Reports submitted via email should be sent on time, although agency acceptance may be delayed until after the shutdown.
Prior Approvals
Agency systems for submitting prior approval requests historically have remained functional, and CGA may continue submitting requests.
Responses from federal agencies will likely not occur until operations resume.
No-cost extension requests requiring agency approval may be delayed.
Payments
CGA worked to submit invoices and drawdowns before October 1 where possible in anticipation of the shutdown.
Payments are not expected during the shutdown. However, currently, expenses legitimately incurred during the shutdown are expected to be reimbursed once normal operations resume.
Additional Resources:
Department of the Army
Contractors may continue work under fully obligated contracts, regardless of whether activities are excepted.
U.S. Department of Education Department of Energy
Lapse Plan Summary Overview - September 2025 No new grants or contracts except to protect life or property or for reasons essential to national security.
After the exhaustion of available balances, those activities not related to the preservation of life and property, unnecessary to the discharge of the President’s constitutional power, not funded by other than annual appropriations, or not otherwise expressly authorized by law will cease.
Department of Health and Human Services (DHHS) National Institute of Health (NIH) Food and Drug Administration (FDA) Department of Homeland Security (DHS)
Lapse in Funding for DHS Financial operations and financial system operations will stop, including processing payments, receipts or performing funds control, except for exempt/excepted activities.
No new grants or extensions unless necessary for life/property protection; fully funded existing awards may continue.
Oversight gaps may force some grantees to pause work if approvals or coordination are required.
Department of State
Guidance on Operations During a Lapse in Appropriations No new grants or contracts except to protect life or property or for reasons essential to national security.
Previously awarded contracts and grants that continue in performance during a lapse in appropriations and have adequate funding previously obligated should generally be permitted to continue unless the post/contracting activity cannot provide adequate oversight of contract performance.
Environmental Protection Agency (EPA)
Agency Contingency Plans in the Event of a Lapse in Appropriations No new grants, contracts, or cooperative agreements, including modifications to add incremental funding, unless tied to excepted activities.
Funded grantees may continue to work on their projects, as long as interaction with federal employees is not required.
Grant recipients currently approved to utilize the Automated Standard Application Payment (ASAP) system may make drawdowns of authorized obligated levels during a shutdown.
National Aeronautics and Space Administration (NASA)
NASA Guidance: Shutdown Furlough Guidance Issued by NASA For research activities (i.e., grants), the agency will only incur obligations that are aligned with presidential priorities.
No new contracts, grants, or cooperative agreements except those required for excepted activities.
Contractors may continue funded work unless it requires the use of shutdown NASA facilities or furloughed staff.
National Science Foundation (NSF)
The National Science Foundation Plan For Operations During a Lapse in Appropriations (PDF) Assistance and Contract-Related Policy and Systems Issues During a Lapse in Appropriations Recipients may continue performance under their NSF awards during a lapse in appropriations, to the extent funds are available, and the period of performance of the grant or cooperative agreement has not expired.
No new grants, continuing grant increments, cooperative agreements, or contracts will be awarded, and no new funding opportunities (program descriptions, announcements, solicitations or Dear Colleague Letters) will be issued.
Electronic systems for proposal preparation and submission (i.e., Research.gov and Grants.gov) will remain available for use; the Awards Cash Management Service (ACM$) and the Invoice Processing Platform (IPP) will remain available for the submission and processing of valid payments for recipients and contractors.
