Why CRs Are Your Business Problem
Congress hasn't passed all 12 annual appropriations bills on time since 1996. That's not a typo — the last time the federal government entered a new fiscal year with fully enacted spending authority for every agency was 29 years ago, for FY1997. Since then, every fiscal year has begun with at least some agencies operating on borrowed time, funded by a continuing resolution rather than a real budget.
The numbers from the Peter G. Peterson Foundation are stark: since FY1998, Congress has passed an average of five continuing resolutions per fiscal year. The government has operated under a CR for an average of 117 days — roughly four months — before full-year appropriations finally get signed. In 13 of the past 15 fiscal years, Congress has passed zero appropriations bills by October 1.
This isn't dysfunction you can outrun. It's the operating environment. And if you don't understand exactly what a CR does to the contracting pipeline — what agencies can and cannot do, which contracts stall and which continue — you're building your GovCon business on a foundation you haven't inspected.
The scale of CR-driven disruption
Those are big-program statistics. The story for small businesses is sharper. You have less capital, thinner margins, and no enterprise-wide revenue base to absorb a multi-month contract freeze. A CR that makes a large prime contractor's fiscal year complicated makes a small business's fiscal year dangerous.
What a Continuing Resolution Actually Is
A continuing resolution is an appropriations law in the form of a joint resolution that provides temporary budget authority to federal agencies when Congress hasn't passed the full-year spending bills by the start of the fiscal year on October 1. The CR doesn't appropriate a specific dollar amount. It provides a formula — the "rate for operations" — calculated from what was enacted in the prior fiscal year.
Think of it as the government's equivalent of rolling over an expired contract rather than signing a new one. The agency keeps running at roughly the prior year's pace. It doesn't get new money for new programs. It doesn't get certainty about the future. It just gets permission to continue what it was already doing, for as long as the CR lasts.
CR vs. Shutdown: An Important Distinction
Continuing Resolution
Congress passes a temporary funding bill. Agencies stay open, existing programs continue, new starts are blocked. Contracting officers can award contracts for previously-funded activities. The government functions — slowly and with restrictions.
Government Shutdown
All temporary funding expires. Most non-essential agency operations halt. New contract awards stop. Invoices aren't processed. Essential services (military, emergency response) continue; everything else pauses until Congress acts.
Both situations hurt contractors, but in different ways. A CR is a slow drag; a shutdown is an acute shock. Most fiscal years feature both.
CRs can also include anomalies — targeted exceptions written directly into the CR legislation that allow specific programs to spend at rates higher or lower than the formula. A new ship class, a defense modernization program, a specific agency initiative: if Congress wants to protect it from the CR restrictions, they add an anomaly. Without one, every program gets the same formula treatment.
Is your pipeline built to survive a CR?
CapturePilot's Intelligence tools show you which of your target agencies have enacted appropriations, which are running on CR authority, and where your pipeline has the most exposure to budget uncertainty.
Start your 30-day free trialWhat Agencies Can and Cannot Do Under a CR
The rules under a CR are set by the CR legislation itself, OMB Circular A-11 (Section 123), and the apportionment bulletins OMB issues at the start of each CR period. Contracting officers aren't making judgment calls — they're constrained by explicit legal authority.
What agencies CAN do
- •Fund existing programs and activities at the pro-rata prior-year rate
- •Award contracts for activities conducted and funded in the prior year
- •Exercise options on existing contracts (with funding constraints)
- •Issue OMB-approved apportionments for existing programs
- •Protect staff from furlough via personnel compensation exceptions
- •Act on programs explicitly covered by CR anomalies
What agencies CANNOT do
- •Start new programs that received no funding in the prior year
- •Increase production quantities beyond prior-year rates (DoD)
- •Award new contracts that exceed the apportioned funding ceiling
- •Obligate funds at a rate higher than the prior-year enacted level
- •Issue new solicitations during a full lapse (shutdown, not CR)
- •Finalize pending awards when appropriations have fully lapsed
The phrase "new start" is key. Under a CR, if a program didn't exist — or wasn't funded — in the prior year, it cannot begin. That's a hard stop, not a suggestion. It kills procurement timelines on new initiatives regardless of how well-funded they would be in a full-year appropriation.
There's a counterintuitive flip side: agencies also generally cannot terminate existing contracts during a CR period, even inefficient ones. The law that prevents them from starting new things also locks in much of what they're already doing. Your existing contracts are protected by inertia.
How CRs Kill New Contract Awards
The new-starts prohibition is the single biggest pipeline killer. When agencies enter a CR, every solicitation for a program that doesn't have prior-year funding either gets delayed or killed. That includes new task orders under existing IDIQs for novel requirements, fresh indefinite-delivery vehicles covering expanded scope, and any capability the agency is trying to add for the first time this year.
But the impact doesn't stop at new starts. Even for programs that ARE eligible to proceed under a CR, contracting officers slow down. When they don't know how long the CR will last, they're hesitant to obligate funds they might need to return later if the final appropriation comes in lower than the prior-year rate. The result is a voluntary slowdown on top of the mandatory restrictions.
What a CR did to DoD acquisition in FY2018
For small businesses pursuing new work, the practical effect is that the award cycle extends unpredictably. A solicitation that was scheduled for release in October might not go out until March. An award that was expected in November might slip to April. You can't bill for delays. You can't staff up for work that hasn't been awarded. The pipeline you tracked in September looks nothing like the pipeline you see in January.
SBIR and STTR programs face an additional complication: their statutory authorities are subject to separate reauthorization. During the October 2025 government shutdown, both SBIR and STTR authorities lapsed entirely, making new SBIR/STTR awards impossible regardless of an agency's CR status — a layered impact that hit small R&D firms especially hard.
The year-end rush that follows every CR
Impact on Existing Contracts and Options
If you already have a contract in place, a CR doesn't terminate it. But it does complicate it in ways that create real operational risk.
Incremental funding modifications
Contracting officers fund only the portion of your contract that corresponds to the CR period. A task order that should be funded for a full year gets funded for 46 days, then extended when the CR extends. You may see three or four funding modifications in a single fiscal year covering work you expected to be funded once.
Option year timing risk
An option generally cannot be exercised if the period of performance extends beyond the current CR without further appropriation authority. Worse, many options expire if not exercised by a specific date. CR delays can compress or eliminate the window the CO has to act — and a missed option exercise date is a contract loss you can't recover.
Performance holds without stop-work orders
COs sometimes ask contractors to slow down or informally hold performance while funding is sorted out — without issuing a formal stop-work order. Informal holds create enormous risk: you may not be entitled to time extensions or cost recovery without a documented government direction to stop.
Payment processing delays
Even contracts that are funded and active face slower invoicing cycles during CR periods as agency finance offices manage multiple simultaneous apportionment periods. DFAS and agency payment systems run at reduced capacity when appropriations are uncertain.
The apportionment math also creates a hidden risk when final appropriations come in lower than the prior-year rate. If an agency was spending at the prior-year rate during a CR — say $10 million per month — and the final appropriation comes in at $90 million for the year rather than $120 million, the agency has over-obligated by $30 million against what it's actually authorized. The scramble to reconcile that gap means halting further obligations, often abruptly, late in the fiscal year.
The pro-rata formula: how CR money actually flows
Under OMB Circular A-11, Section 123, the amount available to an agency during a CR period is calculated as:
A 46-day CR releases 12.6% of the prior-year appropriation. A 30-day CR releases 8.2% — close to but not exactly one-twelfth. The ceiling is further constrained to the lesser ofthe prior-year enacted amount, the President's budget request for the current year, or the lowest Congressional mark. This means an agency facing a proposed budget cut can't even spend at the full prior-year rate during a CR.
The FY2025 and FY2026 CR Timeline
The past two fiscal years illustrate how severe CR disruption has become. FY2025 was funded entirely by continuing resolutions — the last option year on a very long government contract. FY2026 opened with the longest government shutdown in U.S. history.
| Date | Event | Impact on Contractors |
|---|---|---|
| Oct 1, 2024 | FY2025 begins with no appropriations enacted | Agencies continue at FY2024 rates; new-starts blocked |
| Dec 20, 2024 | First CR expires; second CR enacted through March 14, 2025 | Extended freeze on new contract actions for another 85 days |
| Mar 15, 2025 | Full-year FY2025 CR signed (H.R. 1968) — $1.6T discretionary | Defense: $893B, Non-defense: $708B; agencies can now plan for the year |
| Oct 1, 2025 | FY2026 begins; no appropriations; government shuts down | All non-essential operations halt; new awards impossible; invoices frozen |
| Nov 12, 2025 | Shutdown ends at 43 days — longest in U.S. history; CR enacted through Jan 30, 2026 | Operations resume; CR covers $1.560T annualized discretionary authority |
| Feb 2026 | DHS/immigration partial shutdown begins | Affected contractors face additional payment delays and stop-work uncertainty |
The combined impact on FY2026 procurement was severe. For approximately four months — October 1 through January 30 — most agencies could not conduct normal contract award activity. The Congressional Budget Office estimated that the 43-day shutdown alone caused $11 billion in cumulative GDP loss.
FY2025: A full-year CR in practice
Small Business-Specific Vulnerabilities
Large prime contractors absorb CR disruptions. They have enterprise-wide revenue streams across multiple agencies, substantial lines of credit, and financial teams dedicated to managing apportionment cycles. They prepare for CRs the way airlines prepare for weather delays — with redundancy, reserves, and contingency protocols.
Small businesses don't have that infrastructure. Government contractors typically operate on profit margins around 8%. A two-month billing disruption doesn't compress your margin — it eliminates it and starts drawing down reserves you may not have.
Cash flow cliff
When invoices stop being processed — either during a shutdown or because CR-period funding mods haven't been issued — you still owe payroll, rent, equipment, and subcontractor payments. Hours billed during a lapse are often unbillable and unrecoverable. If the government directed the work informally, you may absorb that cost permanently.
Pipeline evaporation
During CRs, agencies can't issue new solicitations for new-start programs. If your business development pipeline was weighted toward new work at target agencies, months of BD investment — proposal preparation, capability statement updates, relationship-building — can produce zero awards during the CR period.
Workforce disruption
When contract awards freeze, small businesses can't hire the staff they planned to bring on for new work. But they also can't always keep incumbents on the payroll when billable work slows. The stop-start cycle of CRs is especially damaging for firms trying to grow headcount to match anticipated workload.
SBIR/STTR authority gaps
Small businesses that rely on SBIR and STTR programs face layered risk: these authorities must be separately reauthorized and have lapsed during recent CR and shutdown periods, making new awards impossible even when an agency has CR funding for other activities.
The structural answer to these vulnerabilities isn't to avoid government contracting — it's to understand which certifications, vehicles, and agency relationships give you the most protection during budget uncertainty. A quick eligibility check can reveal set-aside programs that keep you active even when new-start contracts freeze. An 8(a) sole-source relationship, for instance, lets you pursue work outside the competitive award cycle that CRs most severely disrupt.
Strategies to Protect Your Pipeline and Cash Flow
Surviving a CR period isn't about luck or waiting it out. The contractors who weather budget uncertainty well are the ones who planned for it before it arrived. Here's what that looks like in practice.
Size your cash reserve to your payment cycle
The rule of thumb: keep liquid reserves sufficient to cover the full length of your longest payment cycle. If your largest agency client pays in 75 days on average, you need 75 days of operating expenses in cash or a committed line of credit — not as a growth goal, but as a minimum operating floor.
Invoice immediately at every milestone
Don't batch invoices. Submit the moment performance milestones are met. Break large milestones into smaller, more frequent billable events wherever the contract permits. Every day you wait to invoice is a day you push the payment further into a period that might be frozen.
Pursue multi-year or no-year funded vehicles
Contracts funded with no-year appropriations — money with no single-year expiration — are not subject to annual CR cycles. Programs funded with research or emergency appropriations similarly provide a buffer. Ask your contracting officer about the appropriation type before you plan your pipeline around any new contract.
Diversify across agencies with different budget profiles
Not all agencies are funded by the same appropriations bill, and CRs affect them differently. Defense appropriations and civilian agency appropriations move on separate legislative tracks. An agency that has enacted appropriations while others are on CR can continue awarding contracts normally. Spread your pipeline to reduce concentration risk.
Document everything a CR disrupts
Track all delays, informal holds, stop-work situations, and invoice processing delays in writing. Equitable adjustment claims and Requests for Equitable Adjustment depend on a clear contemporaneous record. If the government caused a delay — even informally — you may be entitled to time extensions and cost recovery. You won't get either without documentation.
Stay in contact with your contracting officer
COs are the first to know what has been apportioned and what awards can proceed. Early knowledge of constraints lets you adjust staffing and performance planning before costs accumulate. A weekly check-in call during a CR period pays for itself in avoided surprises.
Model CR duration scenarios before the fiscal year starts
Every September, run 30-day, 90-day, and full-year CR scenarios across your pipeline. Know at what cash-depletion point you would need to take action — before that point arrives. The contractors who come through CR periods intact are the ones who planned for them in advance, not the ones who scrambled after October 1.
The Q4 opportunity: positioning during the freeze
Check your eligibility for CR-protected contract vehicles
Some programs — 8(a) sole-source, certain IDIQ vehicles, multi-year contracts — give you a significant buffer against CR disruptions. CapturePilot's Quick Checker tells you which ones you qualify for in under two minutes.
Check your eligibility freeUsing Intelligence Data to Navigate CR Uncertainty
The contractors who navigate CR periods best aren't necessarily the ones with the most cash reserves — they're the ones with the best information. Knowing which agencies have enacted appropriations versus which are operating under CR authority changes everything about where you should focus your BD energy during a disruption.
During a period when most of the government is frozen, some agencies have money to spend and the authority to spend it. Agencies covered by enacted appropriations — often because their bills moved first through Congress or because they received anomalies — can continue awarding contracts at normal pace while others stall. Knowing which accounts are live versus frozen isn't intuitive; it requires tracking the specific legislative history of each appropriations bill.
What to track during a CR period
Agency appropriations status
Which of your target agencies have enacted full-year appropriations, which are under CR, and what anomalies were included.
Pending solicitations
Solicitations that were expected before a CR hit. Many will be released in compressed form as soon as the CR period ends — you want to be positioned before that happens.
Option expiration dates
Options on contracts you hold that are at risk of expiring while the government's ability to exercise them is constrained by CR uncertainty.
Spending velocity by agency
Track USASpending.gov data to identify agencies that are spending at normal rates even during a CR period — those are your best near-term targets.
CapturePilot's Intelligence features give you this picture across your target agencies — updated in near real-time as spending patterns shift. You can see which agencies are actively awarding contracts, which are frozen, and where spending is accelerating in advance of a fiscal year-end crunch. That intelligence turns CR uncertainty from a passive threat into something you can actually navigate.
Your pipeline management should reflect your CR exposure. Opportunities at agencies operating under CR authority carry higher timeline risk than opportunities at agencies with enacted appropriations. If your pipeline weights heavily toward CR-frozen agencies, the bid/no-bid decision calculus changes — pursuit cost is the same, but timeline certainty is far lower.
The bigger picture: the contractors who thrive across multiple CR cycles treat budget uncertainty as a permanent market condition, not an anomaly. They build agency diversification into their three-year plan, size their cash reserves against CR scenarios rather than optimistic award timelines, and use market intelligence to shift BD energy dynamically as appropriations status changes throughout the year.
Build a pipeline that survives CR cycles
CapturePilot tracks agency spending velocity, appropriations status, and pipeline risk across your target market — so you know exactly where to push and where to wait during every CR period.
Related reading
Federal Spending Trends 2026
Where the government is investing this fiscal year
Managing Your Government Contract Pipeline
From discovery to award — the full cycle
The Bid/No-Bid Decision Framework
Scoring opportunities before you commit resources
8(a) Sole-Source Contracts
The fastest path to federal revenue — including through CRs