RGCI - Steps to Take Now to Mitigate Federal Government Shutdown Impacts

The federal government has shut down again. It happens. With fiscal year 2025 funding lapsed and in our rearview mirror, how can government contractors mitigate the risk of potential stop-work orders and financial hardship? In this article, we discuss areas to consider not only to mitigate your risk but also to avoid significant financial hardship.

Areas to Review During a Federal Government Shutdown

Contact Your Contracting Officer

If you have not already done so, contact them for their direction on how to proceed, even if they are not in their offices. Don’t be surprised to receive a reply to your emails since many may be working even if under reduced hours. From this communication, you want to determine which work must stop, which work can be continued, reach an agreement on the funding status, and identify any restrictions on your contracts due to the shutdown.

Documentation 

Typically, documentation is crucial to any government contract, but it becomes even more important during a government shutdown. Document any communications with the contracting officer and their representatives, as well as any contract delays, stop work orders, work interruptions, and the costs incurred with these delays. Try to minimize costs wherever possible and document those actions. Additionally, consider the documentation, including separate cost accounts, required for any potential requests for equitable adjustments resulting from these disruptions or delays.

Contact Your Subcontractors

Provide direction to them consistent with what you received from your contracting officers, with a minimum of providing direction on what work must stop, what can continue, and any restrictions on their subcontracts, including funding.

Follow Federal Government Guidance

Federal government agencies have experienced government shutdowns before and may have existing guidance related to accessing government facilities, oversight, and the use of government equipment. Make a note to follow any directions, but also ensure that your subcontractors are aware of this, if applicable.

Bills Do Not Stop

Businesses, especially small businesses, may experience financial hardship due to cash flow issues during government shutdowns. Communicate with lenders, suppliers, and other interested parties to manage your cash flow as best you can during this shutdown period. Remember that interest expense may not be an allowable cost in your government cost-type contracts, even if it was caused by the government shutdown. This may be especially important as the government shutdown continues.

Stay Proactive in Managing Contract Impacts

Stay engaged. Document impacts on your contracts. Continue to communicate with your contracting officers. Provide guidance to your subcontractors. Take steps to mitigate costs wherever you can. Monitor your cash flow and take any necessary steps to maintain financial health during this shutdown period. Everyone wants to see the shutdown end, but be prepared for it to last for an extended period of time.

Remaining Prepared Through Every Phase of the Shutdown

While government shutdowns can disrupt operations, preparation and communication are key to minimizing long-term impact. Understanding your contractual obligations, maintaining documentation, and staying in contact with contracting officers are essential steps in mitigating risk. Redstone Government Consulting supports government contractors throughout every phase of the shutdown by providing staff training on government oversight, assisting with government contract oversight, and offering expert guidance on contracts and grants. Our team of experts works alongside government contractors to help manage disruptions, ensure compliance requirements, and maintain operational readiness throughout the shutdown period and beyond.

Written by David G. Fix, CPA, CFE

David G. Fix, CPA, CFE David (Dave) Fix is a Director with Redstone Government Consulting, Inc. He provides Government Contract Consulting services to our Government contractors primarily related to compliance with Federal Acquisition Regulations and Cost Accounting Standards, equitable adjustment claims, and business systems. Prior to joining Redstone Government Consulting, Dave served in a number of capacities with DCAA for over 35 years. Upon his retirement, Dave was a Regional Audit Manager with DCAA. Dave began his DCAA career in 1986 as an auditor-trainee with the General Electric Suboffice in Pittsfield, Massachusetts. He progressed from auditor to DCAA management ranks serving in DCAA offices in Upstate New York, Columbus, Ohio and Greensboro, North Carolina in audits of major and non-major contractors. Dave served DCAA in three overseas tours, all as Branch Manager, in Kuwait/Iraq (2007), Afghanistan (2010-2012) and Kuwait (2014). Dave was promoted to Regional Special Programs Manager (RSPM) in 2015 before ultimately becoming a Regional Audit Manager (RAM) in October 2019. While a RSPM, Dave worked with DCAA’s other three RSPMs with updating the Agency-wide audit planning process including assigning priorities and determining funded/unfunded audits that is currently being used by DCAA. While a RAM, Dave had overall management responsibility for audits performed by approximately 140 employees including one of DCAA’s largest shipyards. During his career, he served as guest instructor at DCAA’s Defense Contract Audit Institute (DCAI) bringing field perspective to “Advance Auditing Issues” and “Supervisors’ Course” as well as served as a DCAI adjunct instructor over DCAA auditors’ initial two-week training course prior to his retirement. Dave served 36 years in the Air Force Reserve/Air National Guard in both enlisted and officer positions retiring at the rank of Lieutenant Colonel. His last duty station was Air Force Reserve Command (AFRC) Headquarters, Robins Air Force Base, Inspector General Office serving as the Chief, Contracting Inspections leading inspections of AFRC’s 10 contracting offices as well as assisting in inspections of AFRC finance offices. Dave currently specializes in preparing clients for more complex DCAA audits, providing advice on FAR cost principles and contracts regulatory provisions and in assisting clients in anticipating and addressing audit.

About Redstone GCI

Redstone GCI is a consulting firm focused on fulfilling the needs of government contractors in all areas of compliance. With a singular mission to help contractors through the multiple layers of “red tape,” we allow contractors to focus on what they do best – support their mission with the U.S. Government. We are home to a group of consultants made up of GovCon industry professionals, CPAs, attorneys, and retired government audit and acquisition professionals.

Our focus and knowledge of audit and compliance functions administered by DCAA and DCMA will always be at the heart of what we do. However, for the past decade, we’ve strategically grown to support other areas of the government contractor back-office with that same level of focus and expertise. We’ve added expertise in contracts management, subcontract administration, proposal pricing, various software systems, HR and employment law, property administration, manufacturing, data analytics/reporting, Grant specialists, M&A, and many other areas. When we see a trend in the needs of contractors, we act to ensure we can provide the best expertise in the market to fulfill those needs.

One thing our clients can be certain of is that with the Redstone GCI Team in your corner, there is no problem too big and no issue too technical for our team to tackle.

Topics: Contracts & Subcontracts Administration, Government Regulations, REAs, Claims & Terminations