September 29, 2023 Update from NSF: Click here to read the document that addresses the various NSF assistance and contract-related policy and systems issues that may arise during a lapse in appropriations of the Federal Government.
Federal Government Shutdown
In recent years, there have been several threats of a federal government shutdown. These circumstances place pressures on government funded research activities at Rice University. Below is guidance and information on actions you can take to help mitigate these pressures.
General Expectations
In the event of a shutdown, the administration, distribution, and funding of federal contracts and grants will be impacted. While it is important to note that each federal agency will apply unique procedures and protocols, including issuance of their own contingency plans, Rice University can generally expect the following during a shutdown:
- Agencies will be prohibited from issuing new grants/contracts or amendments, including those for continued funding increments, supplements, or no cost time extensions requiring explicit prior Federal awarding agency approval.
- Most agencies’ staff will not be working. Inquiries about upcoming deadlines, proposal preparation and applications, or actions requiring prior approval will likely go unanswered until the shutdown is resolved.
- The proposal review process will be delayed.
- Grant payments will be stalled.
- Principal Investigators (PIs) should continue to meet all deadlines set forth in their awards and should be able to submit annual and final project reports and Project Outcomes Reports via Research.gov.
- Once the shutdown is lifted, there will still be delays as the federal government resumes its operations. Do not expect grants and contracts to be immediately issued the day or week after the shutdown ends.
- Research projects and Rice employees who will be most directly impacted are those with the closest ties to a federal agency or federal employees. For example: cooperative agreements with a federal research partner; Rice students receiving direct stipends from the federal government under training grants; Rice projects or employees who are working on-site at a federal facility.
In-progress federally-funded awards
Generally speaking, a government shutdown will have little to no immediate impact on the ability of in-place federally funded research to continue, though the University will not be able to receive reimbursement. Absent notification to the contrary by the Office of Sponsored Projects, researchers may presume that they can proceed as normal. However, it may be prudent to reduce expenses to the extent practical without significantly impacting the research.
Collaborative Projects Requiring Access to Federal Facilities/Staff: For federally funded work that requires access to federal facilities or federal staff affected by a shutdown, the Principal Investigator (PI) should evaluate whether there are portions of the work that can continue. For cooperative agreements, the PI should perform this analysis prior to the shutdown in consultation with the federal program manager and departmental leadership. If the work cannot continue without access to federal facilities/staff, the department should determine if persons working under the agreement can be redirected to other work and/or fund sources.
Stop Work Orders
Some federal contracts contain a clause that gives the federal agency sponsor the right to order Rice to stop performing work. If an agency exercises this right under a specified contract, Rice would not be reimbursed for expenses incurred between the effective date of the Stop Work Order and when the order is rescinded.
Please promptly forward any Stop Work Orders (SWOs) or other correspondence related to a shutdown to OSP.
As opposed to the scenarios above, expenses incurred during a Stop Work period are generally NOT reimbursable, even when the government resumes normal operations. Thus, if you receive a SWO from a federal agency, they must immediately implement a series of steps to stop work on the project. This may include canceling any cancelable orders, notifying subawardees and consultants (through SWOs or termination notices) that they must stop work on the project.