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As you are most likely aware, the government fiscal year ends at midnight on September 30, and an Appropriation Act for FY 2024 has not been passed. Also, as of this writing, it is currently expected that a continuing resolution will not be passed that would extend government programs for a defined short term, as a stop-gap measure. Accordingly, the Antideficiency Act, 31 U.S.C. 1341 et seq will be enacted and federal “non-essential” operations will be halted until passage of a funding measure or continuing resolution. Therefore, prudent management requires that we are prepared for contingencies that may arise.
Given the timing for the potential shutdown this year, the Office of the Vice President for Research is providing additional details now that address the impact resulting from a shutdown. In case a funding lapse occurs on September 30, we want researchers and administrators to know how they will be affected.
1. The impact tends to be minimal if the shutdown is brief.
2. During a shutdown, federal funds already approved for grants or student aid programs continue to flow. Current grants are not affected, to the extent that budgeted funds remain and the time period for their expenditure remains in effect. Researchers should not experience problems paying project personnel, ordering supplies, and conducting normal operations. However, Federally funded contracts could receive stop-work orders, given the nature of the activities funded thereunder.
3. Reimbursements or requests for payments only occur for those sponsors utilizing the electronic payment systems that process payments without human intervention and which do not require specific approvals. Payment requests requiring prior review, specific approvals, or that are presented for payment outside of an automated payment system will not be processed by the federal government during a shutdown. For short-term shutdowns, this does not present a substantial issue for K-State. Longer-term shutdowns require proactive monitoring to assess cash balances and to monitor and evaluate large cash outlays. It should be noted that K-State, as is the case with all Grantees, will be proceeding at our own risk and will necessarily be required to monitor cash-flow issues in the sponsored project range of accounts to ensure that K-State has adequate funds available to continue federally funded project activity. The federal government has advised its grantee community to be frugal in our spending on these current projects to ensure that the Institution can keep these projects open as long as possible in the event the government shutdown continues for an extended period.
4. New awards, continuations, or award add-amounts will not be issued by federal agencies during a shutdown. This could affect ongoing projects and will require close interaction with departmental and college business officers, and the Office of Sponsored Programs.
5. Some agencies, including the Centers for Disease Control, maintain some essential staff and operations, but most proposal peer review processes will cease during a shutdown, thus delaying scheduled review panels and subsequently slowing down the process of awarding new grants after the shutdown ends.
6. Funding agencies generally do not maintain websites, including some proposal submission portals and social media during a shutdown. More specific guidance will be issued as it is announced.
7. Data download from federal agencies could be affected during a shutdown.
Specific effects at K-State may include the receipt of stop-work orders from federal agencies, which require K-State to cease activities associated with a particular contract until further notice, or determinations regarding employees that are currently on assignment at government installations that result in furloughs or stop-work orders. In the case of cooperative agreements, a curtailment of project activities may be required if substantial involvement of government sponsor employees or access to government installations, IT systems, or the like is required.
In the event of a shutdown, the Office of the Vice President for Research will continue to work to develop and prepare proposal packages for submission, and these will be submitted as possible, or held in a queue until submission portals reopen and revised submission dates are received from the federal government. We will look to the funding agencies to provide guidance that is more specific. The sponsored programs accounting staff within the Office of Sponsored Programs will ensure that all eligible requests for payments are submitted to the federal government in advance of anticipated shutdowns.
Many resources will be made available by federal agencies and the Office of Management and Budget, or OMB, that detail agency-specific standard operating procedures in the event of a government shutdown, along with pertinent FAQs.
A resource titled Q&A: Everything You Should Know About Government Shutdowns provides some general information, but lacks any specific agency guidance.
In addition to the above, federal agencies will distribute agency-specific guidance to their existing grantees on a “just-in-time” basis regarding program/project-specific guidance and determinations. This information is passed on to appropriate K-State researchers and support units as it is received. Also, federal agencies are required to post Agency Contingency Plans and FAQs, as they are developed.
If you have specific questions regarding the effect that a shutdown will have on your project, you may email the Office of Sponsored Programs at research@k-state.edu for proposal and/or award questions and at spaaccts@k-state.edu to reach out to the sponsored programs accounting team for payment related questions.
As previously mentioned, the Office of the Vice President for Research will continue to monitor this situation. Additional updates for the K-State community will be posted on the OVPR website.
David Rosowsky, PhD
Vice President for Research
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