Federal Government Shutdown - Impact on Contract and Grant Administration

UPDATE:
On Wednesday, October 16th Congress passed a measure to avert a threatened US default and reopen the federal government, and the bill was signed by President Obama.  We have identified that some of the federal agencies websites are up and running and some are not. 

Please be aware that it may take a day or two for the agencies to resume their “normal operations”.  Our recommendation to campuses is to continue to check the federal agency web site you need to connect/do business with.



Please refer to the following resources
to understand the impact of the Federal government shutdown on contract and grant administration. If you have questions, please contact Kim Adikes at (518) 434-7014.

Department of Labor
Federal Shutdown Has Immediate Impact at DOL, E-Verify

E-Verify
Information on impact and policies implemented to minimize the burden

NIH

Interim Guidance on Resumption of NIH Extramural Activities (NOT-OD-14-002)

Guidance on Resumption of NIH Extramural Activities Following the Recent Lapse in Appropriations (NOT-OD-14-003)

Update on the NIH RPPR Phase II Pilot Training Webinar for Demonstration Partnership Members (NOT-OD-14-004)

Information for the NIH Extramural Grantee Community During the Lapse of the Federal Government Funding

NSF
Resumption of Operations at the National Science Foundation

Assistance and Contract-Related Policy and Systems Issues During the Government Shutdown

Office of Justice Programs
Communication from OJB Director

OMB
Official Guidance from the Office of Management and Budget (OMB) 

OMB Contingency Plans

 

Operating During a Federal Government Shutdown
The following is a summary from the Council on Government Relations (COGR) about operating during a federal government shutdown:

1) Per page three of the OMB memo - Normal, routine, ongoing operational and administrative activities relating to contract or grant administration (including payment processing) cannot continue when there is a gap in funding.

Therefore, agency employees who are paid with annual appropriations and who perform an activity associated with contract or grant administration (including oversight, inspection, payment, or accounting) should generally not continue work during a funding hiatus.
 

2) In general, active grant and contract activity funded with FY2013 (or prior year) appropriations can continue. However, agency personnel most likely will not be available for approvals, supervisory support, and other administrative functions.

In addition, it is not certain what will be the functionality of automated payment systems. Consequently, institutions should recognize that there is some risk that requests for reimbursement will not be processed.

Other electronic administrative systems may or may not be available, depending on each agencies internal approach. For certain, no new awards will be issued. And most likely, new grant applications will not be accepted, though this also may depend on each agencies internal approach.
 

3) Agency specific guidance should be made available on a case-by-case basis. Agencies are required by OMB to implement agency plans for operation during a shutdown. Most likely, each agency plan will not be identical. In addition, certain programs may have special operating instructions.