Today marks the first day of the Fiscal Year 2026, and the first day of the government shutdown. When this happens, agencies must rely on contingency or “shutdown” plans to determine which operations continue and which must pause. Shutdowns create delays and uncertainty for government contractors, but not all agencies close their doors completely during this time. For example, the General Services Administration (GSA) is a self-funded agency and largely remains open. In this article, we’ll explore how agencies decide what remains open, which major departments continue operating, and what this means for government contractors.
GSA is not alone in remaining open during a shutdown. A surprising amount of agencies continue full or partial operations for essential or critical operations. These include:
Whether an agency stays open during a shutdown depends on a combination of legal requirements and budgetary structures. Under the Anti-Deficiency Act, agencies cannot spend money without appropriations, except in specific cases. To prepare for potential funding lapses, each agency maintains a contingency plan that lays out which employees and functions are “excepted” or “exempt.”
“Excepted” employees are those whose work is deemed necessary to protect life or property, so they will continue to operate under normal emergency operating procedures. For example, law enforcement officers, air traffic controllers, and military personnel typically fall into this category. “Exempt” employees, on the other hand, work in areas funded by sources outside annual appropriations.
Their work can continue regardless of a shutdown. Everyone else, those whose work is neither excepted nor exempt, are generally furloughed until appropriations are restored. Some of this is also influenced by the current administration as well, so actions may change depending on who is in charge.
Since GSA is self-funded, so most of its operations—including the Multiple Award Schedule (MAS) Program—remain open. The majority of GSA personnel were not furloughed in this most recent shutdown, but auditors and employees running assessments were. This means contractors can continue submitting modifications and completing most actions on their Schedule, but things like Contractor Assessment Visits (CAVs) or other contract-related audits may be canceled or delayed.
GSA is a prime example of an agency that does not shut down with the rest of the government because its funding is not dependent on the annual fiscal budget. Unlike most agencies, GSA’s Federal Acquisition Service (FAS) is financed through pathways such as the Industrial Funding Fee (IFF).
Because of this funding structure, GSA’s procurement systems are up and running, and agencies that are still operating can continue purchasing from the MAS Program.
However, other agencies may not have the funding or operations to continue certain contracts, so you may be receiving some stop-work orders or will see less opportunities in the pipeline.
Government shutdowns inevitably cause disruption, but they do not bring federal procurement to a complete halt. It’s important to understand which agencies remain open, and to focus your efforts temporarily on those agencies. In terms of GSA Schedule contract preparation, it’s important to know what to expect. Check out our recent blog to learn more about how you can mitigate the effects of this shutdown. If you have questions about your contract, or need help with your GSA Schedule, please do not hesitate to reach out to one of our consultants.