Idle But Not Ignored: How to Document Shutdown Delays for a Stronger REA
If the ongoing government shutdown has sidelined your contract work, now’s the time to protect your business. Stop-work orders, closed facilities, delayed access, idle teams, if you don’t document it properly, you may never recover the cost. But that doesn’t mean you need to go overboard either.
The good news: You can build a solid, FAR-compliant record for a future Request for Equitable Adjustment (REA) without overwhelming your staff or overengineering your paperwork.
Here’s how small and mid-sized government contractors (especially 8a, SDVOSB, and WOSB firms) can document idle labor and access issues the right way, clearly, efficiently, and with a paper trail that actually holds up.
What This Means in Plain English
If the government suspends or delays your work, for example, due to a stop-work order, shutdown, or lack of access, you may be entitled to more time or money through an REA. But that relief doesn’t come automatically.
To qualify, you have to show exactly how you were affected. That means documenting what your team couldn’t do, when, why, and how much it cost you. This isn’t about gold-plated reports or micromanaging staff timesheets. It’s about keeping real-time, credible records that tie your delays directly to the contract.
Several FAR clauses back you up here:
FAR 52.242-14: Covers suspensions, including “constructive suspensions” where government inaction halts performance.
FAR 52.242-15: Authorizes formal stop-work orders and allows for adjustments if the government tells you to pause.
FAR 52.243-1: Covers changes that affect contract cost or schedule.
FAR 31.201-2 and 31.205-17: Set the rules for what’s allowable (idle labor, idle capacity, idle facilities) and how to justify it.
These clauses give you a foundation. Your job is to build the evidence.
Why This Matters for Small Contractors
If you're an 8a firm, a women owned small business, or hold disabled veteran small business certification, a shutdown can hit especially hard. Smaller GovCons often don’t have deep reserves or standby contracts to shift labor to. Every day of idle time burns cash.
But here’s what many miss: without clean documentation, even valid costs get denied.
And don’t assume the government will remember what happened during the shutdown. If you don’t have annotated timesheets, email logs, or access records to support your REA, you risk losing out on cost recovery altogether.
That’s why this isn’t just a compliance exercise, it’s a survival strategy.
How to Document Without Overkill
Here’s how to keep your REA file lean but defensible:
Annotated Timesheets: Instruct staff to log idle hours clearly. Add notes like “8:00–12:00 idle due to site locked” or “pending GFE delivery.” Link it to the affected contract or CLIN.
Simple Daily Logs: One bullet-point log per day from your PM or site lead is often enough. What happened, who was on-site, and what got delayed.
CO/COR Email Logs: Keep a running file of all shutdown-related messages, missed responses, and instructions (or lack thereof).
Sub/Vendor Statements: Ask subs to confirm their own idle time or missed deliveries. This supports your claim and prevents double-counting.
Access Denial Proof: Take photos of locked gates, save screenshots of system errors, or capture badge logs to show lack of facility or system access.
Segregated Cost Codes: Idle labor costs should be tracked separately in your accounting software, don’t bury them in overhead or direct labor pools. DCAA likes clean lines.
Milestone Impacts: Note every delayed deliverable and when it slipped. Link it directly to the suspension window.
Bottom line: you don’t need elaborate reports. You need consistent, real-time notes that connect delays to contract performance.
Your REA Checklist Starts Now
If you're thinking “we’ll clean this up later,” don’t. REAs that rely on reconstructed logs or vague estimates often get rejected. According to GAO rulings, what counts is contemporaneous evidence, not guesswork.
Here’s a quick REA-readiness checklist:
Mark idle time on payroll/timesheets (with notes)
Log each day’s work status and issues
Save all CO/COR emails and notices
Track access logs or denials
Annotate schedule delays with dates
Code idle costs separately in accounting
Document decisions (e.g., to retain staff or lease space)
Keep a summary of added costs (labor, rent, remobilization)
Preserve all formal notices sent to the government
If you’re still catching up on your federal contracting certifications or working with a consultant for sba 8a certification services, this checklist also helps you build better internal processes, and avoids scrambling next time funding pauses.
Final Word: Protect the Record Before You Need It
Government contracting comes with risk, and right now, a lot of that risk is tied to payment delays, stalled work, and reduced access. But whether you’re pursuing 8a contracts services, women business certification, or already managing government procurement task orders, one thing is clear:
A credible REA is built before the claim, not after.
Even if you never file one, tracking idle labor and shutdown impacts protects your cash flow, compliance position, and audit readiness. And if you do file, it gives your CO everything they need to say “yes.”
For small firms trying to grow in the federal space, that’s worth the effort.
Want to turn documentation into dollars? Pair this post with our breakdown on how to keep your business solvent during a shutdown: Shutdown-Proof Your GovCon Business: Financial Contingency Planning That Actually Works
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