Federal Shutdown Guidance

https://media.defense.gov/2025/Sep/27/2003809363/-1/-1/1/CONTINGENCY-PLAN-GUIDANCE-FOR-CONTINUATION-OF-OPERATIONS-IN-THE-ABSENCE-OF-APPROPRIATIONS.PDFA

A contractor performing under a contract (or contract option) that was awarded prior to the expiration of appropriations may continue to provide contract services, whether in support of excepted activities or not, up to the limit of the funds obligated on the contract prior to the lapse in appropriations if they do not require 1) access to Government facilities; 2) active administration by Government personnel; or 3) the use of government resources in a manner that would cause the government to incur additional obligations during the lapse in appropriation. However, new contracts (including contract renewals or extensions, issuance of task orders, exercise of options) may not be executed, nor may increments of funding be placed on incrementally funded contracts or to cover cost overruns, unless the contractor is supporting an excepted activity. No funds will be available to pay such new contract or place additional increments of funding on contracts until Congress appropriates additional funds.

The expiration of an appropriation does not require the termination of contracts (or issuance of stop work orders) funded by that appropriation unless a new obligation of funds is required under the contract and the contract is not required to support an excepted activity. In cases where additional funding is required and/or oversight, engagement, or inspection by Federal employees who have been furloughed is critical to successful performance under the contract and the contract is not required to support an excepted activity, the issuance of a stop work order, or the termination of the contract may be required.

https://www.ed.gov/media/document/us-department-of-education-contingency-plan-lapse-fiscal-year-fy-2026-appropriations-112431.pdf

The Department would cease any new grantmaking activities. However, the majority of the Department’s grant programs typically make awards over the summer and therefore there would be limited impact on the Department’s grantmaking. Grantees will continue to be able to draw down funds from these awards, and therefore, the impacts on schools and students should be minimal.

The Department will continue to disburse student aid such as Pell Grants and Federal Direct Student loans, and student loan borrowers will still be required to make payments on their outstanding student debt. The Department will also make Title I and IDEA grant funding available as usual

https://www.hhs.gov/about/budget/fy-2026-hhs-contingency-staffing-plan/index.html

HHS will continue any exempt or excepted activities in the event of a lapse in appropriation. Each of the operating divisions will continue, as necessary, to support exempt activities with advance appropriations, carryover balances, emergency supplemental balances, third party funding, or user fees. The information below provides specific detail regarding which activities will continue or not continue during a lapse in appropriation, by HHS Operating Division.

HHS will cease all non-exempt and non-excepted activities in the event of a lapse in appropriation. This includes, but is not limited to, oversight of extramural research contracts and grants, being able to process FOIA requests or public inquiries, data collection, validation, and analysis. More specifically, CDC communication to the American public about health-related information will be hampered, CMS will be unable to provide oversight to major contractors, and NIH will not have the ability to admit new patients to the Clinical Center, except for whom it is medically necessary.

The information below provides specific detail regarding which activities will continue or not continue during a lapse in appropriation, by HHS Operating Division.

• FY 2026 Lapse Plan Administration for Children and Families (ACF)
• FY 2026 Lapse Plan Administration for Community Living (ACL)
• FY 2026 Lapse Plan Agency for Healthcare Research and Quality (AHRQ)
• FY 2026 Lapse Plan Advanced Research Projects Agency for Health (ARPA-H)
• FY 2026 Lapse Plan Administration for Strategic Preparedness and Response (ASPR)
• FY 2026 Lapse Plan Center for Disease Control and Prevention (CDC)
• FY 2026 Lapse Plan Center for Medicare and Medicaid Services (CMS)
• FY 2026 Lapse Plan Food and Drug Administration (FDA)
• FY 2026 Lapse Plan Health Resources and Services Administration (HRSA)
• FY 2026 Lapse Plan Indian Health Services (IHS)
• FY 2026 Lapse Plan National Institutes of Health (NIH)
• FY 2026 Lapse Plan Office of the Secretary (OS)
• FY 2026 Lapse Plan Substance Abuse and Mental Health Services Administration (SAMHSA)

https://www.dhs.gov/sites/default/files/2025-09/2025_0930_dhs_procedures_related_to_a_lapse_in_appropriations.pdf

During a lapse in appropriations, also referred to a federal funding hiatus, the Department of Homeland Security (DHS) must be able to cease its government operations in an orderly fashion. Only those functions and activities that are exempt or excepted from the work restrictions specified in the Anti-Deficiency Act (ADA) may continue during a lapse in appropriations.

The ADA essentially codifies the Constitutional requirement that “No Money shall be drawn from the Treasury, but in consequence of appropriations made by Law.” Federal officials are prohibited from incurring obligations, to include entering into contracts or grants, or performing activities in the absence of a currently available appropriation, unless authorized by law. The Act further restricts acceptance of voluntary services or personal services beyond authorized levels “except for emergencies involving the safety of human life or the protection of property.” As a result, only activities that are exempt or qualify as excepted may continue to operate during a lapse in appropriations.

Summary of significant agency activities that will cease during a lapse:

• Planning (such as strategic, business, or budgetary activities)
• Research and development activities
• Most policy functions, administrative, as well as programmatic, unless those functions are justified by an exception
• Auditing
• Most regulatory, legislative, public affairs, and intergovernmental affairs unless those functions are justified by an exception
• Training and development not deemed an excepted activity

https://www.nasa.gov/wp-content/uploads/2025/09/nasa-continuity-of-appropriations-plan-final-9-29-2025.pdf?emrc=cd4554

The following are prudent steps taken by NASA to minimize the incurrence of costs by contractors (including Jet Propulsion Laboratory (JPL) and its subcontractors), grantees, and partners in cooperative agreements performing excepted activities:

• New contracts, grants, cooperative agreements, task orders, change orders, and other actions would not be issued during a funding hiatus, except those critical to meeting the requirements for excepted activities under this policy-and then only to the extent and amount necessary to meet those requirements.
• Contract personnel may perform excepted activities, provided all the requirements governing excepted activities are met. For example, NASA contracts for most emergency services support and installation security services. Contractors may perform these excepted services, but only to the extent necessary.
• Contractors may continue to perform under contracts for work for which funds were properly obligated prior to the lapse in appropriations, provided performance does not require the use of shutdown NASA facilities or other Government support which would be funded by a lapsed appropriation, including administrative, oversight, or other actions required of civil servants. For example, work on certain missions in development may continue if performance does not require the use of NASA civil servant or technical resources or other Government support. Contractors continuing to work under these circumstances will be instructed to preserve resources and limit contractual expenditures. When contract work on these projects reaches a point at which civil servant participation becomes necessary (e.g., inspections or funding actions), or past which continuation without civil servant participation would be imprudent (e.g., milestones or decision points), contractors will be instructed to suspend performance.
• Contractors continuing to work under the provisions above will be instructed to preserve resources and limit contractual expenditures. Supplies that are not immediately needed to carry out the essential operations under this policy, overtime not critical to meeting the tasks still permitted under this policy, and similar costs should not be incurred.

https://www.nsf.gov/pubs/2022/shutdown22001/shutdown22001.pdf

Proposal Preparation & Submission

• New funding opportunities (Dear Colleague Letters, Program Descriptions, Announcements, Solicitations) may be issued until September 29th. After that time, new funding opportunities will not be posted to the NSF website until normal operations resume.
• gov and Grants.gov proposal preparation and submission will likely be available; however, proposals will not be processed until normal operations resume.
• SciENcv will be available for the preparation and download of the biographical sketch and current and pending (other) support documents, however, SciENcv may not be able to respond to inquiries until normal operations resume.

Impact on Existing Deadlines

During a lapse in appropriations, NSF will continue to accept proposal submissions pursuant to existing deadlines. Once normal operations resume, NSF will issue guidance regarding any funding opportunities that have a deadline or target date that occurred during a lapse in appropriations. Such information will be disseminated via the NSF website Research.gov, and other electronic methods.

Issuance of New Grants and Cooperative Agreements:

No new grants or cooperative agreements will be awarded.

Issuance of Continuing Grant Increments (CGIs): No new CGIs will be awarded.

Performance of Work

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. Any expenses must be allowable and in accordance with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR § 200). During a lapse in appropriations, NSF cannot authorize costs exceeding available award amounts or obligate additional funds to cover such costs.

• gov will be available to submit both grantee-approved and NSF approved no cost extensions (NCEs).
• Grantee-approved NCEs do not require NSF approval; therefore, assuming all business rule checks have passed, the NCE would be processed automatically, and the award date would be extended.
• NSF-approved NCEs may be processed through September 29th. After that date, NSF-approved NCEs will not be processed until normal operations resume. Recipients, therefore, are cautioned that Federal funds cannot be expended beyond the award end date.

NOT-OD-26-004: Information for the NIH Extramural Community During the Lapse of Federal Government Funding

Because a funding lapse has occurred, please be advised that National Institutes of Health (NIH) staff may not be available to provide normal oversight and administrative support services.

For awards received prior to the lapse in funding, you may be able to continue drawing funds from prior awards during an appropriations lapse. HHS’s Payment Management System will remain operational to continue processing those drawdown requests. The robust internal controls that currently exist will continue to ensure the integrity of grant drawdown requests and payments. Please note, if you received your notice of grant award with restrictive terms and conditions, or if your drawdown request triggers one of the Payment Management System edit checks and/or the drawdown limit controls, you may not be able to drawdown funds.

Please check our website at www.grants.nih.gov and www.HHS.gov for updates.

Submission of Grant Applications
For the duration of the funding lapse, applicants should continue to submit applications in accordance with the due dates outlined in the Notices of Funding Opportunities. Applications will be accepted and reviewed once operations resume. For any applications submitted immediately prior to or during the funding lapse, here is what will happen:

1. For electronic submissions through Grants.gov: Grants.gov will be open and can accept electronic applications. However, applications will not be processed by NIH until operations resume.
2. For electronic submission of multi-project applications through NIH’s ASSIST system: The ASSIST system will remain available and can accept applications. However, applications will not be processed by NIH until operations resume.

Awarded Grants

Currently Active Grant Awards: For the duration of the funding lapse, all work and activities performed under currently active NIH grant awards may continue. However, see below for limits on performing many of the reporting requirements associated with NIH grant funding.

Research Performance Progress Reports (RPPR): For any annual or final RPPRs due during the funding lapse, eRA Commons will be available. Users must submit reports on time, and NIH staff will review reports after operations resume.

Notices of Award (NoAs): With the exception of excepted programs, no NIH grant awards will be processed for the duration of the funding lapse. For any awards processed before the funding lapse that have an issue date during the funding lapse, the awards will not be sent to the recipient on the issue date. Once operations resume, all pending NoAs will be sent. This will not affect the start date nor the issue date of these awards; it just affects the date the award document is sent to the recipient and available for access in the eRA Commons. In the absence of receiving the NoA, institutions may use pre-award costs authority at their own risk.

No-cost Extension (NCE) Notifications: eRA Commons will remain accessible during the funding lapse; however, staff will not be available to review and approve requests. For any grants due to expire during the funding lapse, recipients should submit NCE notifications in accordance with standard requirements. Requests for second and greater NCEs, which require prior approval, the request may be submitted but will not be reviewed until operations resume.

General Access to eRA Commons and Other OER-Supported Systems: eRA Commons will be accessible during the funding lapse. Users will be able to access the Commons for viewing electronically submitted applications, accessing Internet Assisted Review, or processing such actions as Commons Registration, xTrain documents, Closeout documents, and/or FCOI notifications etc. However, limited staff support will be available.

Prior Approval Requests and Other Communications: NIH extramural employees will have no access to voice mail or e-mail during the funding lapse. All prior approval requests and other communications will not be received until operations resume. It is recommended that you delay sending such communications until after operations resume.

Access to HHS Program Support Center (PSC)/Payment Management System (PMS): For awards received prior to the lapse in funding, recipients may continue drawing funds during an appropriations lapse. PMS will remain operational to continue processing drawdown requests, so that payments can be made. The robust internal controls that currently exist will continue to ensure the integrity of grant drawdown requests and payments. Please note, recipients of grant awards with restrictive terms and conditions, or requests that trigger one of the PMS edit checks and/or the drawdown limit controls, may not be able to drawdown funds. Recipients can continue to complete and submit their Federal Financial Reports (FFR) in PMS. However, NIH staff will not be available to review and process FFRs until operations resume.