Government Shutdown FAQs

Federal Antideficiency Act

Enacted in 1870 after the Civil War
 31 U.S.C. § 1341

No Expenditures without an Authorized Appropriation

FOLLOW SPONSOR POSTED SUBMISSION DEADLINES

Federal Submission Systems

• Federal submission systems are typically in service, and proposals can typically be submitted
• Proposals will not be reviewed, no peer review meetings
• Unknown if help desks will be available
• Expect agency staff will be unavailable to answer questions

If Submission systems are affected, OCG will provide details as they become known.

If a Submission system shuts down, applications will be submitted by OCG once the system is back online.

Awards

• Federal awards from affected agencies will not be issued during the federal shutdown.
• Awards that have already reached OCG will be processed and sent to CCO Project Set Up.
• Awards that have an issued SpeedType can begin or continue work unless OCG notifies PIs otherwise. Spending on awards should be minimized.

Cooperative Agreements could be affected if federal participation is required but not available.

Unless directed otherwise by the awarding agency, continue research.

If the research is not accessing federal locations, federal resources, unavailable federal data, or federal personnel, the work should continue as long as you have available award funding.

Performance beyond the period of performance (PoP) or awarded budget amount  are not technically allowed by Sponsors.

If an award’s PoP ends, contact OCG for guidance.

If funding is exhausted and a future increment is expected, see CCO’s At-Risk Extension Request Process.

Spend prudently: Exceeding allotted award amounts is not recommended as costs may not be reimbursed by the Sponsor following a federal government shutdown.

Pre-approvals – On Hold

Agency employees will be unavailable to review and approve actions needing preapproval. Contact your OCG Grant or Contract Officer for pre-approvals, such as:

• Travel that is essential and immediate
• Government Equipment: Purchases, repairs, dispositions
• Budget changes that require approval
• Statement of work changes
• Key personnel changes
• Subaward changes

No Cost Extension (NCE) Requests

• NSF 1st Time NCE = OCG can typically submit and approve
• Other NCE Requests
  • Contact your Grant or Contract Officer for information
  • If an NCE cannot be approved, see CCO’s At-Risk Extension Request Process.

Protect Research Subjects 

In no event should the university’s animal or human research subjects be negatively impacted by the government shutdown. Continue work that protects animal and human subjects.

Reports

Continue to submit reports according to sponsor guidelines and a systems are available. If a system is not available for report submission, submit reports as soon as possible after the federal shutdown ends.

OCG sends a letter to all subs encouraging them to continue working through the current Period of Performance given by CU.

Authorized Funds: Expend funds committed by CU to the Sub.

The sub is encouraged to Work at Risk, if necessary, as CU does.

Process invoices and send reminders to subrecipients, where applicable.

Drawing Cash

Whether payment draws can be done l varies by agency. RFS will continue to draw as systems are available. 

Pay attention to awards that have already closed or are close to the 120 day closeout deadlines. Final closeout procedures will not be processed until the shutdown is resolved.