Federal Agency Contingency Plans
ORPA Guidance on a Federal Wide Shutdown
1. Spending on Active AwardsExisting federally funded grants and cooperative agreements may continue spending until such time as they run out of existing obligated funding. For contracts and other transaction agreements, spending may continue until obligated funding is exhausted unless a stop work order has been issued by the funding agency (which may occur under a shutdown). Please confer with your ORPA Research Administrator if you receive such a stop work order. General announcements from an agency that the federal government is shutting down need not be shared.
2. Proposal Submissions
In the past, federal electronic proposal submission systems have remained functional and available for submissions and that current deadlines will apply; however, Help Desks associated with those systems may be unavailable. This means that if there is a problem with a given submission, the University should be able to record a “Help Ticket” electronically (to show that an on-time submission was attempted) but may not receive a response until after the shutdown. There is a possibility that the Grants.gov Contract Center will remain available. New NOFOs (Notice of Funding Opportunities) are not expected to be released until after the shutdown is over.
With many proposals due in October, it is recommended faculty download any materials needed from the agency websites. After the shutdown, agencies may assign new deadlines for any programs where proposals were due during the shutdown period.
3. Awards (Including Just-In-Time Requests)Federal awards are not expected to be received during the shutdown. This includes new/renewal awards and continuation awards, supplements, and incremental funding. In addition, requests from agencies for pre-award or mid-award documents (e.g., revised budgets, just-in-time requests) are not expected to occur.
4. Technical and Financial Reports
If an electronic reporting system for a given agency remains available (expected at most agencies), then all reports must still be submitted by their original deadline. In the event of a failed technical report submission attempt, investigators should request a Help Ticket to showcase the attempt to file the report on time. These tickets will likely be able to be requested online even if the Help Desk itself is not being staffed. If a report is intended to be emailed, it too should be filed on time, though report “acceptance” by the agency may not occur until after the shutdown.
5. Prior Approvals
Agency systems that include the ability to submit prior approval requests are expected to remain functional, and prior approval requests may be submitted by ORPA; however, responses from federal agencies will likely not be received until after the shutdown is over. ORPA is often able to approve an initial, up-to-12-month-no-cost time extension on routine federal grants without prior approval (followed by notification to the agency in their systems). In these cases, ORPA will continue to approve such requests. Other no cost time extensions (ones requiring agency prior approval) may be requested by ORPA, but a response from a federal agency is unlikely to occur until after the shutdown.
6. Drawing Cash and Payments
This largely depends on the agency and the system that the agency uses. NIH, NSF and DOE letter of credit draws may still be operational. It is not expected that the University will receive other payments during the shutdown period, but payments for expenses legitimately incurred during the shutdown are expected to be reimbursed afterwards. In the interim, the University’s financial system will allow expenses to go through on the impacted project, creating an overall deficit until reimbursement is received from the federal agency. Payments on federally-funded outgoing subawards will continue until further notice; however, the University will be monitoring expenditures closely and may temporarily suspend these payments in the event of an extended shutdown period. In this case, PIs will be notified.
7. Agency Visits to Campus/Study Sections/Meetings Involving Federal Officials
Agency visits and meetings with federal officials are not anticipated to take place during the shutdown period, nor will virtual or on-line peer review/study section meetings. Guidance will be provided about travel tickets already purchased for such events once more information from the agencies is known.
8. Exceptions
Some agency programs have multi-year appropriations that enable them to continue work, or deal with critical activities (e.g, for human health or public safety) that cannot safely be deferred. In these cases, certain agency officials may be deemed “essential” and able to continue working. This means that certain activities (such as prior approvals) may still be forthcoming for certain projects. It is also possible that the University will be awarded some funding on subawards if the prime recipient had received its own federal funding prior to the shutdown; this is at the discretion of the prime recipient.