Navigating the government shutdown

• Essential agency functions continue as determined by each agency.

• Federal employees who are considered “excepted” or "essential" will be required to work without pay until the shutdown ends, while others will be furloughed.

• Most regulatory activity will be paused, and consideration of formally issued comments will be placed on hold throughout the shutdown.

After the initial five-day contingency period, the IRS has shuttered most operations and furloughed nearly half its workforce.

• Only “excepted and exempt” employees will continue working.

• Tax filing deadlines remain unchanged.

• Guidance for H.R. 1, P.L. 119-21, commonly known as OBBBA, could be delayed.

• Potential delays in:

  • Refund processing

  • Audit, examination, and appeals activities

  • Customer service response times

  • Online account access and electronic payments

  • Resolution for automated collection notices that continue during this period

• View the IRS lapsed appropriations contingency plan for additional information.

• The FASAB has suspended operations. As a result, FASAB will not release guidance.

• The GAO has suspended operations. As a result, GAO will not publish reports or update its website until operations resume.

• Most GAO personnel are furloughed and unavailable, so calls and emails may not be returned during this period.

• Entities pursuing tax-exempt status may need to wait additional months for Forms 1023-EZ and 1023 to process.

• Federal grant applications and approval processes are paused until the agency responsible for the grant has the authority and funding to return to regular operations.

• Federal grants and contract reimbursements will be delayed or frozen.

• The PCAOB is not funded through the appropriations process and is operational during the shutdown.

• However, as all PCAOB rules must be approved by the SEC, formal action is likely to be paused during the shutdown.

• SEC functions that will remain operational include:

  • Certain services funded through government contracts, such as the EDGAR, IARD, and CRD systems.

  • Public comments will continue to be accepted but will not be reviewed until funding is restored.

  • A limited number of staff will be on duty to handle emergency enforcement, litigation, examination, and market monitoring functions.

• View the SEC lapsed appropriations contingency plan for additional information.

• Social Security, Medicare, and Medicaid will continue to make payments, because the funds for these programs do not require annual appropriations.

• Applications are currently still being processed, but other services, such as benefit verifications, are paused and customer service delays are expected.

• The collection, processing, and publication of key economic data will be halted making it more challenging for the Federal Reserve and other policymakers to assess the health of the U.S. economy.

• Supplemental Nutrition Assistance Program (SNAP) provides food-purchasing assistance to low-income individuals and families.

  • Insufficient funding for November can result in potential disruptions in issuing benefits.

  • Delays in benefit verification, application processing and EBT data transmission

• Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) provides food, formula, nutrition education and support for pregnant and new mothers and young children.

  • Temporary funding allows WIC to operate until November.

  • New applications may be paused, and some WIC agencies may close once funding runs out.

• The Department of Commerce has designated employees working on tariff-related issues (e.g., trade negotiations, implementation of existing tariffs) as essential. These employees will continue to work during a shutdown.

• During a shutdown, U.S. Customs and Border Protection continues to collect tariffs.

• View Department of Commerce lapsed appropriations contingency plan for additional information.

• Programs like Pell Grants, Federal Direct Loans, and FAFSA processing are continuing, because they are funded through mandatory appropriations or carryover funds.

• Borrowers must continue making payments, but an extended shutdown could cause delays in processing and support activities, and schools located on federal land, such as Indian reservations or military bases, could temporarily lose funding.

• View the Department of Education lapsed appropriations contingency plan.

• Grant processing and new awards will not be processed.

• Key HUD operations that support FHA-insured mortgages and Ginnie Mae’s work in the secondary mortgage market will continue.

• Monthly assistance programs, including Section 8 Housing Choice vouchers, public housing, and multi-family assistance contracts, will continue to operate for as long as funding is available.

• Most fair housing activities will pause.

• Emergency shelters and transitional housing programs may remain active.

• The release of the Consumer Price Index (CPI) may be directly impacted causing a delay in the official announcement of 2026 Medicare premiums, Social Security cost of living adjustments (COLA), retirement contribution limits, and other key benchmarks.

• Compensation and benefits programs for which funding has not lapsed will continue.

• DOL will continue to support states and other federal agencies in the administration and payment of unemployment insurance benefits.

• View DOL lapsed appropriations contingency plan for additional information.

• AICPA Experts Offer Advice to Help during Times of Financial Hardship and Job Loss, Oct. 20, 2025

• AICPA Town Hall: Special Edition — Navigating the Government Shutdown, Oct. 16, 2025

• Shutdown concerns, the quest for tax guidance, the future of IRS service, Oct. 8, 2025

• AICPA Comment Letter on IRS Relief for Taxpayers Impacted by Ongoing Shutdown, Oct. 9, 2025

• AICPA Renews Call to Except All IRS Employees for Duration of Shutdown, Oct. 3, 2025

• AICPA Comment Letter Requesting IRS Contingency Plan for Possible Government Shutdown, Sept. 29, 2025

• Federal Funding Freezes Implications to NFPs and Other Entities

• The Importance of Going Concern Evaluation for Nonprofits (NFP Section member access)

• Risk Management Considerations for Nonprofits: Getting Started

• Not-for-Profit Audit Environment | NFP Section Ideacast

• NFP Hot Topics: KPIs, Liquidity, Operating Reserves, Going Concern | NFP Section webcast archive (NFP Section member access)

• Client letter and FAQ for a government shutdown during tax season (Tax Section member access)