By Elizabeth Evans
This winter, the United States endured its longest period of government “shutdown” to date. Lasting ## days (December 22, 2018 until DATE, 2019), this most recent shutdown well outlasted the previous record of 21 days[1]. While popular news media has featured ample coverage related to how the shutdown impacted our national parks, paychecks for government employees, as well as TSA airport security screenings (to name a few), little attention has been paid to how government shutdowns can affect government grant funding. Following we’ll review the influence of shutdowns on both the pre- and post-award process in effort to shed light on an often-neglected subject.
Note: Only six of the federal grantmaking agencies have a current FY19 appropriation: Department of Defense, Department of Education, Department of Energy, Department of Health & Human Services (which includes the National Institutes of Health among others), Department of Labor, and Department of Veterans Affairs.
Note: Curious which agencies fall under the partial shutdown? The list includes: Department of Agriculture, Department of Commerce, Department of Homeland Security, Department of Housing & Urban Development, Department of Interior, Department of Justice, Department of State, Department of Transportation, Department of Treasury, Environmental Protection Agency, National Aeronautics & Space Administration, National Endowment for the Arts, National Endowment for that Humanities, National science Foundation, US Agency for International Development.
PRE-AWARD IMPACT
There are three areas of pre-award impact from a shutdown. The first two pertain to the application process itself, when funding opportunities are announced, and the application process. The final item is related to what happens to those who have already submitted grant proposals.
Notice of new funding opportunities usually goes one of two ways: either they are postponed until the agency’s operations resume, or they continue to be posted with request for proposals (RFP) frequently featuring a caveat along the lines of, “The terms and conditions of the RFP are subject to change, pending Congressional action on the FY 2019 appropriation and authorization bills.” Neither instance is particularly ideal of grantseekers. In the case of the former, those who have been anxiously anticipating an RFP may have to reshuffle their timeline of proposal development tasks. If their organization has a carefully curated grants calendar to ensure that the organization is never over their capacity for grants pursuit/reporting, this change could throw that balance into disarray. Perhaps the only silver lining for a delayed RFP release is that it does provide proposal development teams more time to get their planning ducks in a row using the previous cycle’s solicitation (and hope the programs requirements are not drastically different within the next RFP). Most grant professionals will tell you that the later case is much less preferable. Should any agency choose to forge ahead with release of an RFP despite a lack of appropriation and/or shutdown, there is no guarantee that the work put into the application submission will be worthwhile. Obviously grant pursuit is always a risk, however, applicants can generally feel confident that when they apply to a given program what has been stated within an RFP will be held constant for the duration of their project, if awarded. When RFPs are published prior to agency appropriation, however, the “rules of the game” could be subject to change midway through. Meaning, there may be unexpected stipulations added to the appropriation legislation which forces the grantmaking agency to change how funds are awarded and/or used. By extension, these changes could nullify any proposals which are not in adherence or require the agency to re-release the RFP (thereby requiring applicants to retool previous efforts and reapply).
If a grant solicitation has already been posted prior to the shutdown, the original deadline for that grant program is typically either maintained or extended. This decision will vary based on the agency and grant program. During this most recent shutdown, for instance, the National Science Foundation (NSF) as well as the Nation Institutes of Health continued to accept proposal submissions in accordance with their existing deadlines. The Department of Education, however, decided to push back the eligibility waiver process for colleges and universities interested in the Higher Education Act’s Title III and V funding programs[2]. Although, when deadlines are extended due to a shutdown, most grantseekers are likely to appreciate the extra preparation time.
Most federal agencies utilize the Grants.gov Workspace submission portal for accepting applications. In years past, should a shutdown occur this portal would be unavailable. This recent shutdown was different. For the first time, Grants.gov remained open and in operational status. The Grants.gov support center also remained available for technical assistance only (note program related questions were to still be directed to the relevant grant funding agency). Some funders have their own submission gateways (e.g. NSF’s FastLane or Federal Emergency Management Agency’s Grants Portal), however, during a shutdown there is no guarantee that these sites will function.
The process for review of pending proposals also grinds to a halt. During a shutdown, review panels that were previously scheduled are canceled. Federal agencies will hold on to proposals they receive until the shutdown ends, but until then these applications are essentially gathering dust. Because new review panel dates will not set until after agency resumes operations and has a chance to coordinate schedules, the proposal processing period can be extended by as much as a month or two beyond the shutdown time plus the agency’s standard processing timeline. For instance, the NSF strives to notify applicants of the status of their proposal within 6 months of the deadline or receipt date (whichever is later[3]), but for some applicants it may be as many as 7 or 8 months before they know the outcome.
POST-AWARD IMPACT
Shutdowns are different for those with already awarded grants. They depend on federal agency or federal-to-state-pass-through dollars to maintain operation of their grant-funded projects and programs. Some awardees also rely upon federal agencies for on-going data or other resource access which may be unavailable during a shutdown. Fortunately, many federal agencies publish contingency plans for grant awardees to reference during a shutdown, but these efforts usually serve only to minimize the collateral damage of a shutdown rather than prevent.
Call out - The Office of Management and Budget has published agency contingency plans (https://www.whitehouse.gov/omb/information-for-agencies/agency-contingency-plans/) along with FAQs (https://www.whitehouse.gov/wp-content/uploads/2018/12/Frequently-Asked-Questions-During-a-Lapse-in-Appropriations.pdf) and Special Instructions for Agencies Affected (https://www.whitehouse.gov/wp-content/uploads/2018/12/Special-Instructions-for-a-Possible-December-22-Lapse.pdf).
Depending on how the grant award payments are structured, even during a full or partial shutdown, most current federal grant awardees should be able to persist in their efforts for a short period of time. When agency closure is extended, however, that is when awardees begin to worry because anticipated funding payments may cease. The reason for a discontinuation in award payments is varied. If agency staff is required to approve payment, it could be because no one is present to approve of the installment. In other cases, payment may not occur if the agency was depending upon federal dollars to be appropriated for continuation of awards.
Nevertheless, the consequences of these programs and projects going unfunded are felt. For example, there are a number of grant-funded social services programs which provide invaluable support and advocacy services to our nation’s most vulnerable populations. Whether it’s a senior meal delivery program run by a local foodbank or an afterschool educational enrichment program for high-need students in school, many local agencies and nonprofits rely on federal grant dollars to do the work they do in their communities. When funding isn’t available for these local initiatives, their hosting organizations have to get creative when thinking about covering costs until federal funding resumes. If not, their only other alternative is to temporarily halt operations. When government-funded research labs stop receiving payment many scientists are faced with a similar choice: work for free in effort not to waste time and resources previously invested the research or shutdown the lab and restart any on-going experiments once the funding dry spell is over[4]. The choice is easier for some than others. For scientists working in theoretical fields it is much easier to pause a simulation, shutdown the computer, turn off the lights, and walk away for an indeterminant amount of time. For those researchers who depend on time-sensitive natural environment observations or growth analysis data from living entities, however, they are unable to “walk away” without jeopardizing the integrity of their study.
WHAT IF I HAVE QUESTIONS?
Regardless of where one is in the grantseeking process, one side effect of a shutdown that impacts all is the availability of program officers. Whether you are an interested applicant looking for clarification as you draft your narrative, or a current awardee who wishes to discuss approval for changing a line item from your original budget – program officers are a pivotal resource and provide invaluable assistance. Unfortunately, for many federal agencies these program officers are considered “non-essential” and are furloughed during shutdowns. When this is the case, most federal funding agencies will publish a notice to let the public know to expect no response. For example, during the 2014 shutdown the National Institutes of Health stated plainly “Federal staff will not be available to assist grantees during the government shutdown.[5]” Sadly, inability to contact the funding agency leaves both grant-seekers and awardees to muddle through their quandaries on their own, hoping that their best guess is enough.
