A shutdown is defined as the government's orderly suspension of agency work that is not legally excepted, typically accompanied by furloughing the employees who perform that work, when funding is unavailable.

Shutdown status is recorded at 10:00 AM ET each day. Partial shutdowns are included. A shutdown lasting "at least X days" requires the shutdown to be in effect at 10:00 AM ET on X+1 consecutive days. For example, if a shutdown is first in effect at 10:00 AM ET on October 1, 2026, and remains in effect at 10:00 AM ET on October 2, 2026, the shutdown has lasted at least 1 day.

Examples that would count toward the shutdown day count:

• OMB releases a formal directive that orders heads of the affected agencies to "execute plans for an orderly shutdown," which is in effect as of 10:00 AM ET on the relevant date
• OPM posts a current operating status that indicates that "due to a partial lapse in appropriations, Federal Government operations vary by agency"
• During an ongoing shutdown, OPM posts a status referencing an Executive Order excusing employees for a holiday, but does not indicate the government has resumed normal operations

Examples that would NOT count toward the shutdown day count:

• A technical lapse in appropriations occurs, but OMB directs agencies to continue standard operations
• Government closures or operating status changes resulting exclusively from Federal holidays, inclement weather, or other emergencies, unless such closures coincide with a shutdown due to a lapse in appropriations

Clarification (3/24/26): For purposes of determining when a shutdown has ended, a shutdown shall be deemed to have ended on the first day on which, at 10:00 AM ET, the Primary Source Agencies (OMB and OPM) indicate that the shutdown has ended. Where the Primary Source Agencies have not published timely guidance, or there exists conflict between them, Secondary Source Agencies as defined in the contract rules may also be used to determine shutdown status.

If the OMB rescinds or supersedes its directive to execute plans for an orderly shutdown of the Department of Homeland Security, or issues a memorandum indicating that Department functions should resume, the shutdown will be deemed to have ended for purposes of this Contract. If, following such a directive, a limited number of employees within a specific agency or component remain unfunded and furloughed because that component's appropriation was deliberately excluded from the enacted funding legislation — while the component's core operations continue using alternative funding sources (such as mandatory spending enacted through reconciliation) — the continued furlough of those employees does not, by itself, constitute a continuing shutdown for purposes of this Contract. For the avoidance of doubt, an agency or component of DHS that operates using funding sources other than the annual DHS appropriations bill is not considered to be shut down for purposes of this Contract.