October 2, 2025

Background

Officially, starting at 12:01 a.m. ET on October 1, 2025, the U.S. government has shut down. Roughly 750,000 federal employees will be placed on furlough, with only “essential employees” continuing to work.  

During a shutdown, federal employees who work for agencies and programs not funded by the annual appropriations process are exempt from shutdown furloughs. These include programs like Social Security and Medicare, and other programs funded by user fees and mandatory money. Employees whose agency is funded by an appropriations bill will be designated as “non-essential” or “essential”. Those deemed “essential” are generally those who do work related to life safety, property protection, health, emergency response, and other work deemed essential by their agencies. 

Every time Congress fails to pass appropriations bills on time there is a shutdown threat, triggering agencies to develop contingency plans within a certain period before the end of the fiscal year. Typically, these plans carry over from year to year with tweaks, but it is important to note individual administrations have significant latitude in determining the details of a shutdown, so the guidance can vary from one administration to the next. Based on guidance released for this shutdown, the Torrey Advisory Group (TAG) has prepared memos outlining key details. Note, the guidance is subject to change depending on the length of the shutdown. 

TAG Memos

• United States Department of Agriculture (USDA)
• Food and Drug Administration (FDA)
• Other Agencies (EPA, DOI, DHS, DOL, DOS, DOT, USTR) 

Direct Links to Contingency Plans

Below you can find agency contingency plans:

• Department of Agriculture
• Environmental Protection Agency 
• Department of Interior 
• DHS/U.S. Customs and Border Protection
• DHS/U.S. Citizenship & Immigration Services 
• Department of Labor 
• Department of State 
• Department of Transportation  
• U.S. Trade Representative  

Contact the Team

Feel free to contact Michael Torrey, Tara Smith, Cassandra Kuball, Barbara Patterson, Katie Naessens, Julie McClure, Nona McCoy, Danielle Nelson, Ashley Smith, Olivia Lucanie, Caroline Sowinski, Eden Lambert, Tracy Boyle, or Grace Walker with any questions or comments.

Food and agricultural organizations that need the right results in Washington, D.C. can trust Torrey Advisory Group to put its relationships, reputation, and expertise to work on your issue. Since 2005, the firm has successfully provided legislative and regulatory guidance, issues management, and association management services to a wide variety of clients. Learn more about us at torreydc.com.