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Government Contracting News: What Does “Continue Existing Operations” Mean When Your Customer Is Under a CR?

Written on December 10, 2019

What does it mean that your federal customer can maintain existing under a Continuing Resolution, but not spend appropriated dollars for anything new? That’s an important question at a time when all federal agencies are operating under a Continuing Resolution (CR) until at least December 20th. The common explanation that your federal customer cannot start a new project is frequently heard, but not always understood. Agencies can maintain, and even improve, existing telephone service. The project is providing telecommunications services. Some new features unrelated to an existing solution could be considered new, and unallowable unless other types of money were used. The fact that agencies can maintain telecommunications services is one reason why contractors in that segment are anticipating new business. An agency can continue to procure services that they currently use and even tweak the performance somewhat, so long as the service being provided stays within the scope of the original project. There may be exceptions if a GSA Schedule contract is used (see article below). Critical products and services, such as pharmaceuticals or disaster relief supplies, can be acquired as well. Any new planned project, such as implementing a new cloud solution, or removing an existing network to replace it with something entirely new, must have a different source of funding or wait until Congress passes an official appropriation. When will that happen? Not even Congress knows the answer.

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