Director of Office of Management and Budget (OMB) Russell Vought participates in a Cabinet Meeting in the Cabinet Room of the White House in Washington, DC, USA, 26 August 2025. Image: AARON SCHWARTZ/POOL/EPA/Shutterstock
OMB has told agencies to prepare to use the potential shutdown beginning next Wednesday (October 1) as a justification to issue widespread RIF notices in functions whose funding lapses.
In a memo first reported by Politico.com, OMB said that “such programs are no longer statutorily required to be carried out. Therefore, consistent with applicable law, including the requirements of 5 C.F.R. part 351, agencies are directed to use this opportunity to consider Reduction in Force (RIF) notices for all employees in programs, projects, or activities (PPAs) that satisfy all three of the following conditions: (1) discretionary funding lapses on October 1, 2025; (2) another source of funding, such as H.R. 1 (Public Law 119-21) is not currently available; and (3) the PPA is not consistent with the President’s priorities.”
(Note: HR-1 was the vehicle for the wide-ranging tax and spending law enacted in the summer that provided advance funding for certain administration priorities, such as immigration enforcement.)
The memo adds: “RIF notices will be in addition to any furlough notices provided due to the lapse in appropriation. RIF notices should be issued to all employees working on the relevant PPA, regardless of whether the employee is excepted or furloughed during the lapse in appropriations.”
“Once fiscal year 2026 appropriations are enacted, agencies should revise their RIFs as needed to retain the minimal number of employees necessary to carry out statutory functions. Any proposed RIF plan must be submitted to OMB,” it says.
The memo comes as a funding lapse appears increasingly likely, with the two parties blaming the other for that eventuality. Competing versions of a temporary extension bill each failed to garner the needed 60 votes in the Senate late last week, and there have been no public negotiations since then. The House further is not set to return from this week’s congressional recess until October 1, after the deadline.
OMB in its memo also prodded agencies to provide updated shutdown contingency plans—describing which categories of employees would be furloughed and which would continue working unpaid due to the nature of their jobs—saying it has not received such plans from some of them. OMB has stopped posting those plans on its site.
OMB further said that such plans “should not ‘repurpose’ balances or assume use of transfer authorities. Any exceptions must be requested of OMB, and will be considered on a case-by-case basis.” That is a departure from the strategy the first Trump administration used in the most recent shutdown, over December 2018-January 2019, when it had agencies use such maneuvers to keep as many functions operational as possible in order to mitigate the publicly discernable impact. The GAO later held that several of those actions violated appropriations law.
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