When the federal government faces a lapse in appropriations, agencies across the Department of Health and Human Services (HHS) must implement contingency plans to sustain critical activities. Both the Advanced Research Projects Agency for Health (ARPA-H) and the Administration for Strategic Preparedness and Response (ASPR), which houses the Biomedical Advanced Research and Development Authority (BARDA), have published their contingency plans in the event of a government shutdown. These plans clarify what work continues, what is paused, and how lifesaving programs are prioritized when funding is disrupted.
ARPA-H Contingency Planning
Funding Buffer
ARPA-H has three-year appropriations for FY 2024 and FY 2025. It holds carryover balances from those appropriations large enough to support its operations through a lapse in new appropriations. Because of this, all ARPA-H activities will continue during a funding lapse.
Staffing Status
100 % of ARPA-H staff (132 employees) are designated as “exempt,” meaning they can legally continue working under the carryover funds. There is no excepted staffing needed, because ARPA-H does not plan to scale down or suspend.
What remains on track
All existing and planned ARPA-H projects, grants, contracts, and R&D efforts remain unaffected by the shutdown scenario. There is no interruption in management, awarding, oversight, or contract execution.
BARDA Contingency Planning
Funding Buffer
BARDA will utilize two-year appropriations, which give it some flexibility to keep work moving even if new appropriations are delayed. With this buffer, BARDA can maintain staff and support ongoing research, development, and procurement of medical countermeasures for up to five months into a shutdown period. BARDA staff who are exempt or excepted (because their work is tied to life-saving functions or funded with multi-year appropriations) continue working.
What Continues
- Critical contracts and R&D: BARDA will keep awarding and managing contracts for vaccines, therapeutics, diagnostics, and other countermeasures tied to biological, chemical, radiological, and nuclear threats.
- Public health emergency support: Projects connected to pandemic preparedness and supply chain resilience remain active.
- Stockpile-related activities: BARDA supports activities tied to the Strategic National Stockpile (SNS) that directly affect preparedness and response.
- Core staff functions: Staff needed to oversee critical R&D and maintain contract continuity remain in place.
What Pauses or Slows Down
- Routine oversight of cooperative agreements: Reviews of performance reports, site visits, and approval of award modifications are put on hold.
- Contract administration (non-critical items): Activities like invoice processing, monthly reporting reviews, and some contract modifications are suspended unless tied to emergency operations.
- Planning, evaluation, and reporting: Required assessments and program evaluations are delayed until appropriations resume.
- Recipient & partner engagement: Calls, newsletters, partner meetings, and conference coordination will pause, which may delay communications with partners.
Risks
If a shutdown extends beyond BARDA’s funding buffer, contract performance and procurement may stall. Service contracts tied to manufacturing or product development may be at risk if not covered by carryover funds.
Key Operational Differences
- ARPA-H: All activities will continue during the lapse
- ASPR/BARDA: Maintains staff and supports ongoing research, development, and procurement of medical countermeasures for up to five months
What This Means for You
- If you hold BARDA funding: Expect critical research and contracts to continue, but plan for delays in administrative approvals, reporting, and non-emergency contract actions.
- If you hold ARPA-H funding: Your projects are insulated from shutdown disruptions.
- Cash flow planning: Organizations relying on BARDA funds should prepare for potential delays in payments or oversight if a shutdown stretches longer than the buffer window.
- Communication: Stay in close contact with your contracting officer or program manager to confirm whether your project is categorized as critical.
Final Takeaway
Both ARPA-H and BARDA exist to advance human health but serve complementary missions: ARPA-H drives breakthrough biomedical innovation, and BARDA ensures preparedness through advanced development of countermeasures. Even in a government shutdown, their contingency plans reflect these priorities, protecting patient safety, maintaining national health security, and ensuring continuity where it matters most.
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