Federal Government Shutdown Guidance
As of 10/1/25 at 11:00 am
As you may know, Congress has failed to pass annual appropriations for FY26 or a continuing resolution, resulting in a government shutdown. Historically, shutdowns have lasted anywhere from 1 day to 35 days (2018-19). We are including information and guidance for members below regarding the effects of the shutdown and how to navigate it from an operations perspective.
This is an ongoing situation. Updates will be provided to members as additional information becomes available.
General Operations Guidance
NAA has developed guidance for housing providers regarding how to handle shutdowns, which we recommend all members review. It contains the following:
- Recommended steps for property managers
- FAQ's
- Sample communication from management companies to property managers
- Sample letter to residents impacted by federal government shutdown
Impact of Government Shutdown on Federal Housing Programs
Agencies Expected to Reduce Force: An Office of Management and Budget memo sent in late September outlines guidance for government agencies during a lapse in funding. The memo instructs agencies to "consider Reduction in Force (RIF) notices for all employees in programs, projects, or activities (PPAs) that satisfy all three of the following conditions:
- Discretionary funding lapses on October 1, 2025;
- Another source of funding, such as H.R. 1 (Public Law 199-21) is not currently available (Big Beautiful Bill); and
- The PPA is not consistent with the President's priorities.
The memo states that these RIF notices should be sent regardless of whether the employee is exempted or furloughed during the shutdown, and that agencies should use the shutdown as an opportunity to retain the fewest number of necessary employees once the FY26 appropriations are enacted.
Why this matters: Federal workers will go without pay during the shutdown, which will likely lead to difficulties for the portion of these workers who are renters to cover their rent payments. Unlike previous shutdowns, it's highly likely that a significant number of these workers will lose their jobs as agencies comply with OMB guidance.
Specific Impacts on Federal Housing Programs: Federal housing subsidies and programs are not mandatory spending and will be impacted. Depending on the length of the shutdown and the extent of RIF notices, there may be delays in payment, application, and contract approval, even after funding is appropriated.
That said, according to the National Association of Housing and Redevelopment Officials, funds for the Public Housing Operating Fund have been obligated through November 2025, and HAP and Admin Fee payments have been loaded for October and two weeks of November. Thus, housing provider payments made by Public Housing Agencies (PHAs) will not be immediately affected, and their staffing should remain stable in the short term. This could change if there is ongoing uncertainty with federal funding.
Additional impacts to the provision of rental housing include:
- U.S. Department of Housing and Urban Development (HUD): Read the agency's shutdown contingency plan.
- National Flood Insurance Program (NFIP): A lapse of NFIP authority would disrupt the purchase and renewal of flood insurance in more than 20,000 communities across the United States. Read more.
- Housing Loans: Depending on the Reduction in Force, Federal Housing Administration (FHA) and HUD Multifamily loan processing could be delayed.
Notably, lending through the Government-Sponsored Enterprises (GSEs) should not be impacted because Fannie Mae and Freddie Mac are non-governmental entities and not funded by the government. The GSEs' conservator, the FHFA, is an “independent agency” whose funding is not subject to the appropriations process. Their decision-making authority over the GSEs remains unaffected.
Regional Impacts
Washington, DC: WAMU outlines here the effects of the shutdown on the District. The DC Court’s shutdown plan, referenced in WAMU's article, can be found here.
Virginia: Code of Virginia § 44-209 requires that the court grant a 60-day continuance to any defendant in an unlawful detainer for nonpayment of rent due after the commencement of a closure of the United States government seeking a judgment for the payment of money or possession of the premises, provided that the resident:
- Appears in court on the initial court date,
- Provides written proof of being furloughed or otherwise not currently receiving wages or payments because of the federal government shutdown, and
- Is employed as:
- An employee of the United States government,
- An independent contractor for the United States government, or
- An employee of a company under contract with the United States government.
Housing providers are not prohibited from filing cases for nonpayment; the statute only mandates that they be automatically continued. Also, this law is immediately in effect following the passage of SB 1430 in the 2025 General Assembly Session. Previously, a shutdown had to last at least 14 days before this provision went into effect.
Please note that this law only applies to unlawful detainers filed for nonpayment of rent; it does not apply to filings for material noncompliance for a non-rent violation of the rental agreement or of the Code of Virginia.
Prince George’s County: The County has outlined how it will coordinate resources and share information during the shutdown.