Federal Government Shutdown Update: Contingency Plans Released
September 30, 2025
Funding for the federal government expires today, Sept. 30. If Congress does not approve a continuing resolution by midnight, a government shutdown will occur.
Over the weekend, the administration released contingency staffing and operational plans for various agencies. We encourage state and territorial health officials to review the documents in full. Overall, according to the contingency plan document, HHS will retain approximately 47,257 (approximately 59%) of its staff and furlough approximately 32,460 (approximately 41%) of its staff.
Last week, Politico reported that the Office of Management and Budget sent out a memo to federal agencies with directives related to a potential shutdown. The memo requested that agencies submit RIF notices in addition to any furlough notices, which are traditionally issued as part of a shutdown. Additionally, there is a request that agencies revise their RIF plans when a resolution on continued appropriations is reached to retain the minimum number of employees necessary to carry out statutory functions. It is unclear how this memo intersects with the HHS contingency plans delineated below.
ASTHO staff will closely monitor developments. We will share all relevant information as it becomes available.
Below are public health provisions included in contingency plans:
HHS
HHS “will cease all non-exempt and non-excepted activities” in the event of a lapse in appropriation. This includes, but is not limited to, oversight of extramural research contracts and grants, processing FOIA requests and public inquiries, data collection, validation, and analysis.
HHS’s Program Support Center (PSC), Financial Management Portfolio (FMP), Payment Management Services (PMS), and Division of Payment Management (DPM) will be operational and retain the necessary staffing in an excepted status to ensure delivery of grant payments for excepted programs. The PMS and DPM will follow specific processes to ensure payment of permissible disbursements. In addition, HHS will maintain the Grants.gov system in an operational status, but with reduced federal support staff presence. The Grants.gov Contact Center will remain available and assist callers. HHS will provide the federal grantor community with guidance and updates in the event of a government shutdown.
CDC
CDC will continue to respond to urgent disease outbreaks and continue efforts to support the President's Emergency Plan for AIDS Relief (PEPFAR), World Trade Center Health Program, the Energy Employees Occupational Illness Compensation Program Act, and the Vaccines for Children program.
CDC and the Agency for Toxic Substances and Disease Registry (ATSDR) will not be available to provide guidance to state and local health departments implementing programs to protect the public’s health, nor will they provide communication to the American public about important health-related information. In addition, there would no longer be ongoing applied public health research by CDC and ATSDR scientists to improve prevention modalities, and responses to public inquiries about public health matters would be suspended. Analysis of surveillance reports would be delayed. Grant funding announcements would not be prepared, resulting in compressed timelines for applicants, such as state and local health departments and universities, to apply for funding.
CMS
CMS Medicare program will continue during a lapse in funding for the federal government. CMS will also have sufficient funding for Medicaid to fund the first quarter of FY26, based on advanced appropriation provided for in the Full-Year Continuing Appropriations and Extensions Act, 2025. CMS will maintain the staff necessary to make payments to eligible states for the Children's Health Insurance Program. CMS will continue Federal Marketplace activities, such as eligibility verification, using Federal Marketplace user fee carryover.
FDA
FDA activities funded through carryover user fee funding and other un-lapsed funding will continue. This includes certain activities related to the regulation of human and animal drugs, biosimilar biological products, and medical devices, and all FDA activities related to the regulation of tobacco products. All FDA activities related to imminent threats to the safety of human life or protection of property would continue. This includes detecting and responding to public health emergencies and continuing to address existing critical public health challenges by managing recalls, mitigating drug shortages, and responding to outbreaks related to foodborne illness and infectious diseases.
The FDA will also reduce food safety efforts within the FDA’s Human Foods Program. Longer-term food safety initiatives, including policy work aimed at preventing foodborne illnesses and diet-related diseases, would be halted, jeopardizing public health.
HRSA
HRSA will continue to oversee activities funded through mandatory funding, advance appropriations, prior year carry-over funds, and user fees. For a limited amount of time, HRSA will continue to oversee certain direct health services and other activities with carryover balances, such as:
- Health Centers
- Ryan White HIV/AIDS program — Parts A and B
- Ending the HIV Epidemic
- Teaching Health Center Graduate Medical Education
- Family to Family Health Information Systems
- National Health Service Corps
Indian Health Service (IHS)
IHS received advance appropriations for FY26. Therefore, the majority of IHS-funded programs will remain funded and operational in the event of a lapse of funding. Advance appropriations, third-party collections, and carryover balances will continue to fund the provision of care by the Indian Health Service, Tribal Health Programs, and Urban Indian Organizations. Facilities construction projects supported with previously appropriated funds will also continue.
SAMHSA
SAMHSA will continue substance use and mental health programs vital to the safety and protection of Americans. This includes programs that provide critical behavioral health resources in the event of a natural or human-caused disaster, such as Disaster Behavioral Health response teams, the 24/7 365-day-a-year Disaster Distress Helpline that provides crisis counseling to people experiencing emotional distress after a disaster, and the 988/Suicide Lifeline to connect people in crisis with life-saving resources.
SAMHSA will continue previously funded operations and utilize available balances to provide essential resources to those seeking help for behavioral health concerns through the Treatment Services Locator program, the Treatment Referral Line, and the Suicide and Crisis Line.
Most SAMHSA grants awarded in the prior year will have funds that remain available to be spent by the grantee, including, for example, the 988 and Behavioral Health Crisis Services program, the State Opioid Response Grant program, and the Mental Health and Substance Use Block Grants.
USDA
As of publication, USDA has not released an updated FY26 contingency plan. Therefore, we do not have official information about the WIC program.