Assistance and Contract-Related Policy and Systems Issues During a Lapse in Appropriations

September 30, 2025

This document addresses the various assistance and contract-related policy and systems issues that may arise during a lapse in appropriations of the Federal government, including those related to operations of review panels. The U.S. National Science Foundation (NSF) is providing this information as a service to our proposer and recipient communities in the hopes that it will address most of the questions you may have during this time period.

Unfortunately, considerable uncertainty exists surrounding a lapse in appropriations. As a result, proposers and recipients are strongly encouraged to monitor news outlets to determine if the Federal government, and therefore NSF, is open for business.

Please be aware that, except as noted below, NSF may not be available to respond to emails or phone calls during a lapse in appropriations but will respond as soon as practicable after normal operations have resumed.

Pre-award Activities for Assistance Awards (Grants and Cooperative Agreements)

Proposal Preparation & Submission

New funding opportunities (Dear Colleague Letters, Program Descriptions, Announcements, and Solicitations) may be issued until September 30, 2025. After that time, funding opportunities will not be posted to the NSF website or Grants.gov until normal operations resume.
Research.gov proposal preparation and submission will be available during a lapse. Proposals may be processed up to but not including Division Director concurrence until September 30th. After that time, proposals will not be processed until normal operations resume.
Grants.gov proposal preparation and submission will likely be available during a lapse. Proposals may be processed up to but not including Division Director concurrence until September 30th. After that time, proposals will not be processed until normal operations resume.
SciENcv will be available during a lapse for the preparation and download of the biographical sketch and current and pending (other) support documents, however, SciENcv may not be able to respond to inquiries until normal operations resume.

Impact on Existing Deadlines

During a lapse in appropriations, NSF will continue to accept proposal submissions pursuant to existing deadlines. Once normal operations resume, NSF will issue guidance regarding any funding opportunities that have a deadline or target date that occurred during a lapse in appropriations. Such information will be disseminated via the NSF website, Research.gov, and other electronic methods.

Review Process

Ad hoc reviewers will be able to submit reviews via the Proposal and Evaluation System (PES) on Research.gov.
All panels scheduled to occur through September 30th will be held as planned. Panels scheduled to occur after September 30th, including fully virtual panels, will be cancelled and will likely be rescheduled to a later date. Panelists are advised to monitor news outlets to determine if the Federal Government, and therefore NSF, is open for business.
- If the federal government closes due to a lapse in appropriations during a standard business day (Monday-Friday), panels scheduled to occur one day after the Federal Government reopens will be held unless panelists are informed by NSF staff that the panel has been postponed or cancelled. For example, if the government reopens on a Tuesday, panels scheduled for Wednesday and later will be held as planned unless panelists are informed otherwise.
- If a funding lapse occurs and is resolved over the weekend and does not disrupt a normal business day, panels would be held on Monday as scheduled.
- If you have questions about whether your panel will be held, please contact your cognizant program officer after NSF has re-opened.
Panelist Functions, including the Panel Review in the Proposal Evaluation System (PES) and the GRFP Review and Panel site, will not be accessible for use by panelists during a lapse in appropriations. Ad hoc reviewers will be able to access PES and enter reviews.
Additional information will be available for panelists on the NSF website.

Proposal Processing Time

The Foundation may not be able to meet our customer service standard of informing proposers whether their proposals have been declined or recommended for funding within six months of the deadline or target date, or receipt date, whichever is later.

Issuance of New Grants and Cooperative Agreements

No new grants or cooperative agreements will be awarded.

Issuance of Continuing Grant Increments (CGIs)

No new CGIs will be awarded.

Post-award Administration for Grants and Cooperative Agreements

Performance of Work

Recipients may continue performance under their NSF awards during a lapse in appropriations, to the extent funds are available, and the period of performance of the grant or cooperative agreement has not expired. Any expenses must be allowable and in accordance with the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (2 CFR Part 200). During a lapse in appropriations, NSF cannot authorize costs exceeding available award amounts or obligate additional funds to cover such costs.

Payments

The Award Cash Management Service (ACM$) will be available for use by recipients to drawdown funds on existing awards. In the event of a lapse in government appropriations, payments will be processed on an intermittent schedule until normal operations resume.

Project Reporting

Research.gov will be available for use by Principal Investigators (PIs) and co-PIs to submit annual and final annual project reports and Project Outcomes Reports. NSF program staff may continue to review and approve project reports through September 30th. After that time, reports will not be reviewed or approved until normal operations resume.

NSF’s Public Access Repository will be available to deposit peer-reviewed scholarly journal articles and papers in juried conference proceedings.

No-Cost Extensions

Research.gov will be available to submit both recipient-approved and NSF-approved no cost extensions (NCEs).
Recipient-approved NCEs do not require NSF approval; therefore, assuming all business rule checks have passed, the NCE would be processed automatically, and the award date would be extended.
NSF-approved NCEs may be processed through September 30th. After that date, NSF-approved NCEs will not be processed until normal operations resume. Recipients should continue to follow standard submission protocols for NCE requests, consistent with 2 CFR § 200.308(d)(2) and PAPPG Chapter VI.D.3.c.

Award Transfer Requests

Research.gov will be available to prepare and submit award transfer requests. However, these requests will not be processed until normal operations resume.

Supplemental Funding Requests

Research.gov will be available to submit supplemental funding requests. However, these requests will not be processed, and no new supplements will be awarded until normal operations resume.

Cooperative Agreements in Support of Major Facilities and Mid-scale Research Infrastructure

Recipients may continue to perform under Cooperative Agreements or Cooperative Support Agreements for work where sufficient funds were obligated prior to a lapse in appropriations, and where performance does not require Government support, such as quality assurance oversight or other actions required of NSF staff. The Award Cash Management Service (ACM$) will be available for use by recipients to draw down funds on existing awards. In the event of a lapse in government appropriations, payments will be processed on an intermittent schedule until normal operations resume. Additionally, the absence of NSF personnel to process administrative actions or provide needed authorizations during a lapse in appropriations does not constitute agency approval of any pending action.
For Major Facilities Construction or Mid-scale Research Infrastructure Implementation activities, recipients may continue work only up until the next full monthly reporting period requirement, not to exceed 30 days, even if funds are available. Recipients must not enter into any subawards, contracts, or other like arrangements, that require NSF prior approval. If the lapse in appropriations continues to the monthly reporting period, not to exceed 30 days, recipients must minimize expenditures while taking such steps to orderly suspend these activities in a manner that does not imminently threaten the safety of human life or the protection of property.
In all cases, recipients must take appropriate steps to ensure that property and equipment acquired in whole or in part with Federal funds are protected and otherwise secured from harm during a lapse in appropriations.
As necessary, NSF may issue follow-on guidance after a lapse in appropriations ends. In the event that an emergency situation arises that endangers life or property, please contact Tim Kashmer, Branch Chief, Infrastructure Support Branch by telephone at (703) 292-4818 or by e-mail at: tkashmer@nsf.gov as well as the cognizant Program Officer. Program Officers who have been designated as “excepted personnel” may also engage with recipients in emergency situations.
The Award Cash Management Service (ACM$) will be available for use by recipients to draw down funds on existing awards. In the event of a lapse in government appropriations, payments will be processed on an intermittent schedule until normal operations resume.

Contracts

In the event of a lapse of appropriations, federal contractors will receive notice from their Contracting Officer advising of their ability to continue operations under shutdown.