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A Looming Federal Shutdown: Last-Minute Moves for State & Local Grant Programs

September 30, 2025

As a federal shutdown looks more and more likely, you still have time to reduce disruption and compliance risk. Below is a 48-hour playbook focused on cash flow, reporting, program continuity, and documentation—so your team, subrecipients, and auditors aren’t left guessing.

Frame the risk (and your posture)

  • Assume delays in federal communications, reimbursements, and approvals.

  • No new starts unless you have written authorization and available funding.

  • Document everything (decisions, assumptions, calculations) in your grant files.

Cash & Drawdowns (today)

  • Reconcile and draw now: Clear reimbursable expenses in PMS/ASAP/eLOCCS/G5/GrantSolutions and other payment systems before systems slow or staff go offline.

  • Forecast 30–60 days of cash need: Include subrecipient pass-throughs, payroll for grant-funded staff, and active contracts.

  • Line up internal bridge funding: Confirm your finance office can front expenses temporarily without violating allowability or cost-sharing rules.

  • Avoid risky prepayments: Don’t prepay beyond policy/award terms; stick to incurred/allowable costs.

People & Operations

  • Identify “shutdown-proof” functions: Internal controls, payroll, AP, and documentation must continue.

  • Protect grant-funded staff: Verify which positions are on federal funds and whether local funds can backstop during a lapse.

  • Freeze non-essential starts: Pause activities that require federal approvals, waivers, or program officer guidance.

Subrecipients & Contractors

  • Push a 1-page bulletin: What continues, what pauses, how to invoice, who to contact, and how to handle cash constraints.

  • Recheck risk ratings: Elevate monitoring for high-risk subs that may face cash-flow stress.

  • Contract language scan: Confirm “availability of funds/termination for convenience” clauses; prep stop-work or de-scope letters if needed.

Procurement & Obligations

  • Finish what’s already in flight: If a solicitation is at award stage and funding is secured, finalize documents and countersignatures now—sign and return grant agreements.

  • Defer new applications or solicitations that depend on new federal approvals or FY funding not yet available.

  • Keep the paper trail tight: Written price/cost analyses, conflict-of-interest disclosures, and justification files complete and filed.

Reporting & Deadlines

  • Submit anything due now: Performance, P&E, FFRs—get them in before potential portal slowdowns.

  • Pre-draft near-term filings: Have narratives, metrics, and financials queued so you’re not starting cold post-shutdown.

  • Log unanswered Qs: If you’re waiting on a grants officer, send a final, concise email outlining the decision needed and your interim plan—then file it. Keep seeking guidance per grant terms even if not receiving responses.

Systems & Access (the “hour-one” failure point)

  • Verify logins/MFA for everyone: Treasury, PMS/ASAP, SAM.gov, GrantSolutions, G5, eLOCCS. Add backup methods and a second admin.

  • Snapshot your records: Export key reports, award terms, budgets, active approvals, and contact lists to your secure drive.

Governance, Risk & Communication

  • Activate a mini playbook: Name the incident lead, comms lead, finance lead, and legal liaison; set a daily 15-minute stand-up.

  • Update your risk register: Add “federal shutdown” with controls (cash draw timing, staffing backstops, subrecipient comms).

  • Brief leadership & council/board: Provide a one-pager: risks, mitigations, what keeps running, what may pause, and any fiscal exposures.

What not to do

  • Don’t start activities that depend on new federal funding or approvals.

  • Don’t relax internal controls or documentation standards, even temporarily.

  • Don’t prepay or advance subrecipient funds outside your established policies or agreements.

One page you can reuse with your team
Subject: Federal Shutdown Prep – 48-Hour Grant Checklist Attachments: Cash forecast, Drawdown confirmation, Staff funding map, Subrecipient bulletin, Reporting calendar, Contact sheet, Risk register excerpt.

Bottom line
A shutdown is disruptive, but it doesn’t have to create audit findings or program whiplash. Pull cash cleanly, protect staff and subs, lock down access, and document your decisions. When the government reopens, you’ll be ready to resume without a scramble.
 

Managing grants efficiently, without compromising compliance and integrity, can be a challenging task. If your organization is navigating the complexities of grant management, we can help you enhance oversight, streamline processes, ensure outcomes and reduce the risks of waste, fraud, and abuse. Reach out today to learn how our expertise in grants management can ensure your programs meet their goals, stay compliant, and make the best use of taxpayer dollars. 

Authored by: 

Matthew-Hanson_5ec4dda68b6bcab72c5edd90255be92b

Matthew Hanson, CGMS, GPC
Managing Director, Government Advisory Services

 

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