Fiscal year 2027 began on October 1 with no full-year federal budget in place. Congress passed a stopgap instead: the Continuing Appropriations and Extensions Act, 2027, signed on September 2, keeps the government funded through December 11, 2026. If your organization holds a federal grant, or is waiting on one, the next ten weeks run on that law's rules.
A continuing resolution, or CR, is not a budget. It is permission to keep spending at last year's rate while Congress finishes the real appropriations bills. That distinction drives everything below.
Your Current Grants Keep Paying
Start with what is handled for you. Section 101 of the CR funds agencies at a rate of operations matching fiscal year 2026, so programs that existed last year keep running and active awards keep drawing down. Reimbursement requests should process normally. A CR is not a shutdown; the payment systems stay on. The law also carries targeted exceptions, called anomalies, where Congress wanted something other than last year's defaults, on spending rates and on program starts alike. A summary from ASTHO notes carve-outs letting USDA maintain WIC participation and letting FEMA's disaster relief fund spend at the pace that response and recovery work requires.
Nothing New Starts Before December 11
Section 104 of the Act bars agencies from using CR funds to initiate or resume any project or activity that did not have funding in fiscal year 2026. Grant people call this the no-new-starts rule. A program that was funded last year can keep making awards. A brand-new program, one that exists only in an FY2027 bill that has not passed, cannot launch until Congress acts, unless the CR itself carves out a specific exception for it; several of the Act's anomalies do exactly that, overriding Section 104 for named activities. If you are waiting on a new program, check whether it drew one of those carve-outs before assuming it is on hold. For most, it is: if a funder told you to watch for a new federal opportunity this fall, this is usually why it has gone quiet.
Agencies Are Told to Hold Grant Money Back
Two quieter provisions matter most for timing. Section 110 directs agencies to take only the most limited funding action needed to keep projects going. Section 109 speaks to grants directly: programs that would normally distribute their full-year funding early in the year are told not to, and agencies are barred from awarding grants under those programs in ways that would impinge on Congress's final funding decisions. In practice, award cycles slow down well beyond those programs. The Government Accountability Office has documented the pattern across past CRs, including delayed grant cycles at agencies like the Administration for Children and Families: agencies hold announcements and obligations until they know their full-year number, then compress the work into the back half of the year.
So expect notices of funding opportunity, the NOFOs that open grant competitions, to post late or sit in draft until real appropriations pass. Posted deadlines are real. Forecasted ones are tentative until the forecast becomes a posting. That slowdown lands on a sector where federal grantmaking has already fallen sharply this year, and it will make fourth-quarter revenue planning harder for grant-dependent organizations.
The Uniform Guidance Rewrite Stays Frozen
Section 157 freezes a rulemaking nonprofits have been tracking all summer: OMB's proposed Regulation for Federal Financial Assistance, the rewrite of the Uniform Guidance that governs how federal awards are administered, cannot be issued or finalized through December 11, and the block covers any substantially similar rule. We covered the freeze when it became law with the CR's signing. The practical reading for grantees: the administrative and audit rules you operate under today are the rules through at least mid-December, and any rewrite restarts from where the rulemaking left off, not from a finished rule.
What to Do Between Now and December 11
First, invoice promptly. Submit drawdowns and reimbursement requests as the costs occur, not in batches at quarter end, so less of your money is in transit if December gets messy. Second, sort your federal pipeline by appropriations status: applications under programs funded in FY2026 are live, and anything tied to a new FY2027 program is on hold. Third, ask your program officer directly how the CR affects your award's next increment; they will usually tell you what the agency's budget office has told them. Fourth, check your cushion. Our guide to operating reserves covers how much buffer a grant-dependent budget actually needs. Fifth, keep non-federal prospecting moving; the process for finding grants does not change because Washington is late.
Then mark December 11. Congress has three options when the CR expires: full-year appropriations, another stopgap, or a lapse in funding. Each lands differently on grantees, and you want your invoices current and your reserves counted before any of them.
The takeaway
The government stayed open, current grants keep paying, and the compliance rules are frozen in place. What you lose under this CR is speed: no new programs, slower award cycles, and a NOFO pipeline that thins out until Congress passes real appropriations. Treat the next ten weeks as a cash-flow and pipeline-hygiene exercise, and reassess on December 11.