The Operational Case for Cross-Program Redeployment During Peak Season

Cross-program redeployment helps federal contractors manage peak staffing demand. Explore the costs, compliance risks and workforce planning requirements.

A prime contractor supporting several federal contact center programs may already have part of the capacity it needs for the next surge.

The problem is that the capacity may be sitting on another contract.

One program is moving into its busiest month while another is returning to baseline volume. One team needs temporary reinforcement while experienced agents elsewhere in the portfolio have room in their schedules. Recruiting a new seasonal workforce may solve the gap, but it also introduces sourcing, onboarding, training, and early-performance risk.

Cross-program redeployment gives primes another option.

When the contracts, credentials, workforce model, and labor requirements support it, experienced employees can move temporarily between programs to help absorb peak demand without rebuilding every seat from zero.

The opportunity is real, so are the constraints.

What Is Cross-Program Redeployment in a Federal Contact Center?

Cross-program redeployment is the temporary movement of employees from one federal contract or task order to another to meet a workforce requirement.

For a multi-contract prime, that could mean moving trained contact center agents into a seasonal peak, shifting supervisors to support a rapid ramp, or temporarily using quality, training, or workforce management personnel where additional capacity is needed.

The model works best when demand patterns across the portfolio do not peak at exactly the same time.

A healthcare program may need additional capacity around Open Enrollment. Another customer-service program may experience its heaviest workload earlier in the year. A disaster-response program may require sudden surge capacity rather than a predictable seasonal ramp.

Viewed independently, each contract needs its own staffing plan.

Viewed as a portfolio, those programs may create opportunities to use existing workforce capacity more efficiently.

That does not make employees interchangeable between contracts.

The operational question is whether the prime has built enough portability into the workforce for people to move when demand changes.

Can Federal Contractors Move Staff Between Programs?

Federal contractors can move employees between contracts when the move remains consistent with the requirements of each contract.

That qualification matters.

An employee working on Contract A cannot simply begin performing on Contract B because both programs belong to the same prime.

The receiving contract may have different:

labor categories
staffing commitments
wage determinations
work locations
background investigation requirements
security requirements
system permissions
training standards
schedules
key-personnel restrictions
customer-specific experience requirements

Cost charging also has to follow the work.

FAR 31.201-4 provides that a cost is allocable to a government contract when it is incurred specifically for that contract, benefits the contract and other work in a proportion that can be reasonably distributed, or meets another recognized allocability basis.¹

For cross-program staffing, that makes accurate timekeeping and cost allocation fundamental.

An employee may remain part of the same company and even the same business unit, but the hours spent supporting a different contract have to be treated according to the cost, accounting, and contract requirements that apply to that work.

For primes, redeployment should therefore be designed as a workforce model, not handled as an informal schedule swap between program managers.

What Credentialing Is Needed to Move Agents Between Federal Contracts?

Credentialing is one of the biggest practical limits on cross-program staffing.

An experienced federal contact center agent may already have a favorable background investigation, a PIV credential, or security eligibility. That can reduce some of the friction associated with moving the employee.

It does not automatically provide access to another program.

HSPD-12 requires federal employees and contractor personnel who need routine access to federal facilities or information systems to undergo appropriate identity verification and credentialing. GSA guidance also makes clear that contractor credentials operate through agency sponsorship and access-management processes.²

Security eligibility creates a related but separate issue.

The federal personnel-vetting system increasingly supports reciprocity rather than unnecessary reinvestigation. Trusted Workforce 2.0 is designed in part to allow trust determinations to move more efficiently across organizations, and DCSA systems support transfer and reciprocity processes for eligible personnel.³

But reciprocity does not mean an employee can immediately log into any federal system or begin supporting any contract.

The receiving program still has to determine what access the position requires, establish the appropriate relationship, provision systems and facilities, and complete any program-specific onboarding.

That distinction determines whether redeployment can solve a surge next week or only a surge next quarter.

A mature prime already knows which employees across its portfolio have credentials, investigations, suitability determinations, or security eligibility that could shorten the path to another program.

When Is Redeployment Cheaper Than Seasonal Hiring?

Redeployment becomes attractive when the cost of making an existing employee ready for the receiving program is lower than the cost and risk of recruiting a new seasonal employee.

That calculation goes beyond hourly pay.

Seasonal hiring may involve sourcing, screening, recruiter time, background processing, onboarding, equipment, training, nesting, supervisor support, and the productivity gap while a new agent reaches proficiency.

Redeployment may avoid some of those costs because the employee already understands contact center operations, the employer’s performance expectations, attendance standards, quality processes, and internal systems.

But redeployment also has costs.

The employee may need new program training. Different credentials or systems access may be required. The applicable wage rate may change. The home contract may need replacement coverage. Productivity may fall temporarily while the employee learns the new program.

The useful comparison is therefore not:

existing employee versus new hire.

It is:

cost to make an existing employee productive on the receiving contract versus cost to recruit, prepare, and retain a new employee for the same period.

For a six-week peak, that difference can materially change the economics.

For a longer requirement or highly specialized program, recruiting dedicated staff may still be the better choice.

Cross-program redeployment earns its value when the workforce can move with relatively little reinvestment.

Service Contract Labor Standards Still Follow the Work

Moving an employee does not allow the prime to carry the labor conditions of the original contract into the new assignment without checking the receiving contract.

The Service Contract Labor Standards may apply to federal service contracts performed by service employees in the United States. Covered contracts include wage determinations establishing minimum monetary wages and fringe benefits for relevant classifications and locations.⁴

That matters in a multi-contract workforce.

An employee could move into work subject to a different labor classification, wage determination, locality, or collective bargaining requirement.

The Department of Labor also requires appropriate compensation when an employee performs work in different covered classifications, with specific rules around segregating hours and applying the relevant wage rates.⁴

For primes using cross-program staffing, HR, payroll, contracts, and operations therefore need the same redeployment plan.

A scheduling decision that makes sense operationally can create a compliance problem if the receiving contract’s wage and fringe requirements have not been checked first.

Training Determines Whether Agents Are Actually Redeployment-Ready

Cross-training is where the long-term value of redeployment is created.

Trying to cross-train employees after the surge starts defeats much of the advantage.

A prime that expects to move people between programs should identify likely pathways in advance.

Which programs use similar customer-service skills?

Which require similar systems or security profiles?

Where do demand cycles complement each other?

Which roles can reasonably be cross-trained without creating excessive learning requirements?

From there, training can be layered.

The employee may already understand call handling, quality expectations, escalation discipline, security practices, and the prime’s operating model. Cross-program training can then focus more narrowly on the receiving program’s policies, systems, knowledge base, terminology, customer population, and procedures.

That is very different from building a new agent from the beginning.

Primes can also maintain redeployment readiness through refresher training before known peak periods rather than waiting until the receiving program is short of staff.

The goal is to reduce the distance between available employee and productive employee.

That distance determines whether internal mobility is a meaningful capacity strategy or simply an idea on a workforce planning slide.

How Cross-Program Redeployment Can Support Retention

Redeployment can solve another problem that seasonal programs create: what happens to good employees when the peak ends.

A contractor may spend heavily to recruit, train, and develop an agent for a surge, then release that employee when volumes return to baseline.

If another program inside the portfolio needs capacity, the prime has an alternative.

Employees can move from a declining workload into another contract where their skills remain useful.

That can preserve federal contact center experience that would otherwise leave the company.

For employees, internal movement can also create a clearer path to continued hours, new program knowledge, and broader experience across the portfolio.

The retention value matters because every experienced person retained reduces the amount of capability the contractor has to rebuild before the next surge.

Over time, a prime can develop a pool of employees who have performed across more than one federal program and require less lead time when future demand shifts.

That is when redeployment stops being an emergency response and becomes part of workforce infrastructure.

How Should Primes Coordinate Subcontractors in Cross-Program Staffing?

A multi-contract workforce rarely sits entirely inside the prime.

Staffing subcontractors may own important parts of the candidate pipeline or employ agents already supporting one of the programs being considered for redeployment.

That makes cross-program planning a prime-subcontractor coordination issue too.

The prime needs to know:

which subcontractor employees may be available
whether their employment terms allow the proposed assignment
whether the receiving contract permits the staffing arrangement
which labor requirements apply
whether new onboarding or credentials are required
how hours and costs will be assigned
who manages training and performance
when the employee is expected to return to the original program

The subcontractor also needs enough visibility to plan its own workforce.

Pulling ten people from one program may solve the receiving contract’s peak and create a gap somewhere else.

The best cross-program moves therefore start with portfolio capacity data rather than isolated staffing requests.

The question is not simply, “Who can we move?”

It is, “Where can capacity move without creating a second performance problem?”

What Should CORs Know About Workforce Redeployment?

A COR does not need the prime’s entire internal workforce strategy.

The government does need confidence that the contractor will continue meeting the requirements of the contract.

That makes communication particularly important when redeployment changes something the government can see: staffing levels, key personnel, schedules, service levels, training status, quality performance, or transition risk.

FAR 1.602-2 makes an important distinction here. A COR’s authority is defined in writing, and a COR cannot make commitments or changes affecting price, quality, quantity, delivery, or other contract terms.⁵ Only a Contracting Officer acting within their authority can execute contract modifications on behalf of the Government.⁶

For contractors, that means communication should match the nature of the change.

If redeployment is fully within the contractor’s existing staffing discretion and does not alter a contractual commitment, the COR may primarily need operational visibility.

If the move affects contract requirements, identified key personnel, staffing commitments, delivery, price, or another term, the contractor needs to follow the contractual approval path rather than treating an operational conversation as authorization.

Some agency contracts also contain key-personnel clauses that expressly require Contracting Officer notice or approval before identified personnel are removed, replaced, or diverted.⁷

A mature redeployment plan accounts for those boundaries before anyone is moved.

The government should see controlled capacity management, not a contractor shifting people between programs after a shortage has already affected performance.

Building a Multi-Contract Workforce for Peak Capacity

Cross-program staffing works best when the portfolio has been designed for it.

That means primes need visibility beyond individual contract headcount.

They need to know which employees have transferable skills, which investigations and credentials are already in place, which programs share training requirements, which labor conditions differ, and when seasonal demand rises and falls across the portfolio.

A useful redeployment map can identify employees by:

program experience
role and labor category
language capability
credential and investigation status
security eligibility where applicable
system access
completed training
geographic restrictions
peak availability
likely time required to become productive elsewhere

That turns workforce planning into a portfolio capability.

Single-program staffing asks how to fill the next vacancy.

Multi-contract workforce planning asks where existing capacity can create the most value without compromising performance anywhere else.

For primes managing several federal contact center programs, that is a much more useful question.

How Salem Solutions Supports Cross-Program Federal Contact Center Staffing

Salem Solutions helps federal contractors build workforce capacity around the needs of the wider portfolio, including surge recruiting, backfill, redeployment support, credential-aware sourcing, and pipeline planning across multiple programs.

That gives primes another option when demand shifts. Instead of treating every peak as a completely new hiring event, the workforce strategy can combine redeployment-ready employees with external recruiting where additional capacity is still required.

For contractors managing several federal contact center programs, the goal is to know where capacity can move before a surge turns that question into an emergency.

Looking to build more flexibility across your federal contact center portfolio? Talk to Salem about a workforce strategy that supports surge, redeployment, and backfill across programs: bit.ly/HireSalem

References

Federal Acquisition Regulation, “31.201-4 Determining Allocability,” Acquisition.gov, accessed September 2026.
https://www.acquisition.gov/far/31.201-4
U.S. General Services Administration, “Homeland Security Presidential Directive-12, Personal Identity Verification and Credentialing, and Background Investigations for Contractors,” GSA Order 2181.1A ADM, March 27, 2024.
https://www.gsa.gov/directives-library/homeland-security-presidential-directive12-personal-identity-verification-and-credentialing-and-background-investigations-for-contractors
Defense Counterintelligence and Security Agency, “DCSA Announces Adjudication and Vetting Services,” April 15, 2024.
https://www.dcsa.mil/About-Us/News/Article/Article/3741584/dcsa-announces-adjudication-and-vetting-services/
Defense Counterintelligence and Security Agency, “FAQs: Defense Information System for Security (DISS),” accessed September 2026.
https://www.dcsa.mil/Systems-Applications/Defense-Information-System-for-Security-DISS/FAQs-DISS/
U.S. Department of Labor, Wage and Hour Division, “Frequently Asked Questions Pertaining to the Issuance of Wage Determinations Under the McNamara-O’Hara Service Contract Act,” accessed September 2026.
https://www.dol.gov/agencies/whd/government-contracts/service-contracts/faq
Federal Acquisition Regulation, “1.602-2 Responsibilities,” Acquisition.gov, accessed September 2026.
https://www.acquisition.gov/far/1.602-2
Federal Acquisition Regulation, “43.102 Policy,” Acquisition.gov, accessed September 2026.
https://www.acquisition.gov/far/43.102

Preparing for the Open Enrollment Surge: HealthCare.gov, FEHB, and the November Peak

Prepare for the Open Enrollment surge with strategies for federal contact center staffing, bilingual coverage, workforce readiness and peak demand.

The Open Enrollment surge begins November 1 with HealthCare.gov, followed days later by Federal Benefits Open Season. These overlapping enrollment periods bring millions of people into the process of reviewing coverage, comparing options, completing enrollment actions, and seeking assistance.

The workforce problem starts well before the first spike in calls. By November, agents need to be trained, systems-ready, scheduled, and supported. A staffing plan that is still trying to build capacity once demand arrives is already behind.

For prime contractors, the question is therefore not how many seasonal agents can be hired. It is how much productive capacity will actually be available when Open Enrollment reaches its peak.

Why November Creates a Federal Contact Center Capacity Problem

HealthCare.gov and Federal Benefits Open Season serve different populations, but their enrollment calendars overlap.

HealthCare.gov’s Open Enrollment Period for 2027 coverage begins November 1, 2026. The standard Marketplace window runs through January 15.¹

Federal Benefits Open Season operates on a shorter schedule. OPM sets the annual period from the Monday of the second full workweek in November through the Monday of the second full workweek in December. In 2026, that places the window from November 9 through December 14.²

For contact center operations, those dates matter because the demand is concentrated.

Marketplace consumers may be starting applications, comparing plans, updating household information, checking financial assistance, submitting documents, or trying to resolve an enrollment issue before an effective-date deadline.

Federal employees and eligible participants may simultaneously be reviewing FEHB options and making benefits decisions during their own annual enrollment window.

The programs do not share one contact center or one operating model, but they do create overlapping demand for similar workforce capabilities: healthcare customer service experience, process accuracy, strong communication, familiarity with sensitive information, and the ability to work through complex questions without creating additional confusion.

That can tighten the labor market precisely when contractors need the largest number of trained people available.

How Many Agents Does HealthCare.gov Use During Open Enrollment?

There is no current public CMS figure showing the exact number of agents supporting the Marketplace Call Center for the 2027 enrollment season.

There is, however, useful historical context.

CMS reported that Marketplace Call Center staffing peaked at approximately 10,000 people during the Open Enrollment period preceding the 2019 plan year and that it intended to maintain that staffing level for the following enrollment season.³

The figure should be treated as historical rather than as today’s staffing level, but it shows the scale federal enrollment support has required before.

The customer population remains substantial. During the 2026 Marketplace Open Enrollment Period, nearly 23 million consumers selected or were automatically re-enrolled in coverage through the federal and state Marketplaces. Approximately 15.8 million of those plan selections were through HealthCare.gov.⁴

CMS has also previously described its call center as a front line for consumers applying for coverage and comparing plans, and has documented the use of extensive pre-Open Enrollment training and refresher training during the enrollment period.³

That is the part workforce planners should pay attention to.

Ten thousand names on a staffing roster would mean very little if the operation could not turn them into productive capacity.

The same principle applies at any scale.

A surge plan has to account for every step between identifying a candidate and having an agent independently handling live contacts. Recruiting, screening, onboarding, systems access, training, nesting, and early QA all consume time and capacity before the workforce can absorb volume.

How Far in Advance Should Open Enrollment Contact Center Hiring Begin?

There is no federal rule that says Open Enrollment recruiting must begin a specific number of weeks before November.

The more useful calculation works backward from the date agents need to be productive.

If a program requires several weeks of training, system access, background screening, nesting, or healthcare-specific learning, those steps need to be completed before peak demand arrives. Recruiting has to begin early enough to absorb those lead times as well as the candidates who accept an offer but never reach production.

That makes the final four weeks before Open Enrollment a poor time to begin building the primary workforce.

By then, program leaders should be validating readiness.

How many agents have accepted?
How many have actually started?
How many are through training?
How many are in nesting?
How many can independently take contacts?
Where are the remaining gaps?
What does the replacement pipeline look like?

The difference between hired headcount and productive headcount becomes critical during a fixed enrollment window.

Bilingual Open Enrollment Staffing Needs Its Own Capacity Plan

Language support adds another layer to Open Enrollment workforce planning.

HealthCare.gov provides Spanish-language services and makes language assistance available through the Marketplace Call Center. Consumers who need help in languages other than English can also request interpreter assistance at no cost.

For staffing purposes, bilingual capacity should not disappear inside the overall headcount number.

A program can reach its total staffing target and still enter Open Enrollment short of the language capability required by its customer population.

Spanish-language demand can place particular pressure on a smaller pool of bilingual employees. If that pool is too thin, those agents have less room for schedule changes, coaching, absence coverage, or unexpected increases in contact volume.

Recruiting bilingual agents also requires more than confirming that someone speaks Spanish conversationally.

Healthcare support requires agents to communicate accurately while discussing coverage, applications, eligibility information, documentation, and next steps. Language proficiency needs to hold up inside the actual context of the role.

That makes bilingual staffing part of the initial workforce forecast.

It should have its own sourcing targets, readiness numbers, schedule coverage, replacement pipeline, and quality monitoring.

Four Surge Staffing Models for Open Enrollment Contact Centers

Open Enrollment programs do not all need the same workforce structure.

The right model depends on the size and length of the volume increase, training complexity, existing workforce capacity, bilingual requirements, and what happens to additional employees when demand falls.

Four models are particularly useful for federal contact center planning.

1. Core Workforce With a Seasonal Overlay

A permanent workforce continues to manage baseline demand while additional agents are hired for the enrollment period.

This gives the program an experienced operational core while allowing headcount to expand around a predictable peak.

The pressure point is support capacity.

A large seasonal class creates additional work for trainers, supervisors, QA teams, schedulers, and escalation resources. Programs that expand frontline headcount without expanding those functions can create a bottleneck behind the agents.

2. Staged Training and Deployment

Instead of trying to recruit and train the entire surge population at once, the workforce enters in planned cohorts.

One group may be nesting while the next is in training and another is completing onboarding.

This gives the program more control over throughput and allows early lessons to improve later classes. It also spreads demand across trainers and supervisors rather than placing the entire ramp on one start date.

For a long enrollment window, staged deployment can also position additional capacity closer to later deadlines rather than requiring every surge agent to be production-ready on November 1.

3. Cross-Trained Workforce Redeployment

Some contractors may have employees elsewhere in the organization who can temporarily support enrollment work, provided the contract, training requirements, systems access, and employee qualifications allow it.

The advantage is access to workers who already understand the contractor’s operating environment.

The limitation is readiness.

Moving an experienced contact center agent from another program does not automatically make that person ready for federal healthcare enrollment work. Program knowledge, systems training, security requirements, and customer-specific processes still need to be addressed.

Redeployment works best when it has been planned in advance rather than used as an emergency response to missed staffing targets.

4. Core, Seasonal, and Backfill Capacity

This model builds three layers into the workforce plan.

The core team provides stability. A planned seasonal cohort expands capacity for expected demand. A separate backfill pipeline remains active to replace early attrition, failed starts, unexpected absences, or higher-than-forecast volume.

That third layer matters because surge recruiting rarely ends when the target headcount is reached.

If the entire pipeline closes once training begins, every early loss reduces the program’s available capacity.

A backfill strategy keeps the workforce plan moving while the surge is already underway.

What Separates Open Enrollment Programs That Hold Service Levels?

The programs that enter November in the strongest position have usually solved more than recruiting.

They know their productive headcount, rather than relying on offers accepted.

They have enough training capacity to move candidates through the program without creating a queue before the real queue even begins.

Supervisor ratios account for the fact that a large proportion of the workforce may be newly trained.

QA capacity expands alongside frontline staffing so that speed does not come at the expense of accuracy.

Bilingual coverage has been forecast independently.

The recruiting pipeline remains active after the first classes start.

Most importantly, the workforce plan has been tested against something other than the expected forecast.

What happens if volume arrives earlier?
What happens if the first training class loses more people than expected?
What happens if absenteeism increases during the busiest week?
What happens if Spanish-language demand exceeds the original model?
What happens if additional capacity is needed seven days from now?

A surge plan becomes useful when it can answer those questions before the program needs the answers.

What Primes Should Ask a Workforce Partner Four Weeks Before Open Enrollment

Four weeks before Open Enrollment, a staffing partner should be able to talk about readiness in operational terms.

A prime should know:

How many production-ready agents will we have by the required date?

Candidate pipeline numbers are useful, but they should be separated into sourced, interviewed, offered, accepted, started, training, nesting, and production-ready populations.

Where are we losing people before production?

Fallout should be visible early enough to trigger additional recruiting rather than becoming a surprise at the end of training.

What does bilingual readiness look like?

Total agent capacity and Spanish-language capacity should be reported separately where bilingual support is required.

How quickly can we replace a lost agent?

The answer reveals whether the staffing provider still has pipeline depth after the initial ramp.

What happens if the forecast is wrong?

The staffing model should identify how additional capacity can be sourced, trained, and deployed if demand exceeds expectations.

What workforce support does the surge require?

More agents can mean more trainers, supervisors, quality analysts, schedulers, and escalation support. The prime needs visibility into the operating model around the new hires, not only the hiring number.

What is the ramp-down plan?

The surge does not end operationally the moment volume falls. Workforce decisions after the peak can affect retention, morale, final service levels, and the contractor’s ability to respond to late enrollment activity.

These are the questions that reveal whether a workforce partner is supplying seasonal labor or managing surge capacity.

How Open Enrollment Surge Performance Can Affect CPARS

Open Enrollment may be seasonal, but the contractor’s performance during the surge still becomes part of the wider contract record.

FAR 42.1501 identifies past performance information as including a contractor’s record of conforming to requirements, controlling costs, adhering to schedules, behaving reasonably and cooperatively, and demonstrating concern for the customer’s interests.5

FAR 42.1503 requires evaluations to address factors including technical or service quality, schedule or timeliness, management or business relations, and other applicable performance areas. Evaluations should reflect objective facts supported by contract and program performance data.6

For a contact center contractor, the Open Enrollment period can generate plenty of that data.

Staffing shortages may show up in service levels.

A rushed ramp may affect quality.

High early attrition may create schedule or coverage problems.

Weak workforce forecasting may require repeated recovery actions.

A well-managed surge can demonstrate the opposite: the contractor forecasted demand, brought capacity online when required, responded to workforce changes, and protected service during the program’s most demanding period.

That is why Open Enrollment staffing belongs in the performance strategy for the contract.

The hiring plan is only one part of it.

How Salem Solutions Supports Open Enrollment Contact Center Staffing

Salem Solutions approaches Open Enrollment as a workforce capacity challenge that starts before seasonal hiring begins.

That means building pipeline depth around the required production date, sourcing for healthcare contact center and bilingual needs, planning staged deployment, maintaining backfill capacity, and helping federal contractors respond when actual workforce requirements move beyond the original forecast.

For primes supporting federal healthcare programs, the objective is straightforward: enter November with enough trained capacity to absorb the peak without sacrificing the people, supervision, and service quality needed to perform through the full enrollment window.

Preparing for the Open Enrollment surge? Talk to us about building the workforce capacity behind your federal healthcare contact center.

References

HealthCare.gov, “Get or Change Coverage Outside of Open Enrollment,” Centers for Medicare & Medicaid Services, accessed September 2026, https://www.healthcare.gov/coverage-outside-open-enrollment/.
U.S. Office of Personnel Management, “What Is Open Season?” accessed September 2026, https://www.opm.gov/frequently-asked-questions/insure-faq/health/what-is-open-season/.
Centers for Medicare & Medicaid Services, “Federal Health Insurance Exchange 2019 Open Enrollment,” October 11, 2018, https://www.cms.gov/newsroom/fact-sheets/federal-health-insurance-exchange-2019-open-enrollment.
Centers for Medicare & Medicaid Services, “Marketplace 2026 Open Enrollment Period Report: National Snapshot,” January 28, 2026, https://www.cms.gov/newsroom/fact-sheets/marketplace-2026-open-enrollment-period-report-national-snapshot-2.
Federal Acquisition Regulation, “42.1501 General,” Acquisition.gov, effective March 13, 2026, https://www.acquisition.gov/far/42.1501.
Federal Acquisition Regulation, “42.1503 Procedures,” Acquisition.gov, effective March 13, 2026, https://www.acquisition.gov/far/42.1503.

Government Shutdown Resilience for Contact Center Contractors

A government shutdown can disrupt federal contractors in different ways. Learn how contact center contractors can protect workforce and service continuity.

A government shutdown does not produce the same outcome for every federal contact center contract.

One program may continue operating because funding was already obligated. Another may receive a stop-work order. A third may continue only the portion of its work necessary to support an excepted government function.

For contractors, that uncertainty creates a different operational problem: decisions about staffing, payroll, subcontractors, and service continuity often have to be made before anyone knows how long the lapse will last.

The strongest shutdown contingency plans are therefore built before appropriations expire.

This article breaks down what happens to federal contractors during a government shutdown, how funding and excepted activities affect contact center operations, and what contractors should have in place before a lapse begins.

What Happens to Federal Contractors During a Government Shutdown?

A lapse in appropriations does not automatically cancel existing federal contracts.

The first question is whether funds have already been legally obligated to the work.

OMB guidance recognizes that activities financed by resources that remain available, including carryover balances, multi-year or no-year funding, may continue during a lapse.¹ Historical Department of Justice shutdown guidance has similarly explained that work under a contract funded before the lapse may continue when performance does not depend on furloughed federal employees or require additional funding.²

That distinction matters enormously for federal contact centers.

A contractor supporting a fully funded period of performance may have authority and funding to continue work even while other functions inside the agency shut down.

An incrementally funded contract carries a different exposure.

Under FAR 52.232-22, which applies to incrementally funded cost-reimbursement contracts, the contractor performs only up to the amount currently allotted. The Government is not obligated to reimburse costs beyond that amount unless additional funding is formally provided.³

In other words, the contract ceiling and the amount currently funded are not necessarily the same thing.

For contact center operators approaching September 30, the important number is not simply total contract value. It is how much funding is actually obligated, which work that funding covers, and how long the available amount can sustain performance.

That needs to be known before a lapse begins.

How Funding Status Affects Federal Contract Performance During a Shutdown

Funding is only one dependency.

A funded contractor may still depend on federal employees for approvals, supervision, system administration, security access, escalations, policy interpretation, or other actions required to perform the work.

That creates an important shutdown scenario.

The money may be available, but the operating environment may not be.

DOJ shutdown guidance has previously instructed that a pre-funded contract could continue when contractor performance did not require furloughed federal personnel. Where federal employee supervision or interaction was necessary and those activities could not continue, the agency could suspend contractor performance.²

For a contact center, that means contingency planning needs to map government dependencies as closely as workforce dependencies.

Which federal personnel does the program need every day?

Who approves escalated cases?

Who maintains system access?

Who can authorize policy changes?

Which government counterparts will remain available during a lapse?

What happens if a contact center agent receives a case requiring agency intervention while the responsible government team is furloughed?

These are operational questions that should be answered before the appropriations deadline, not discovered during the first morning of a shutdown.

What Are Excepted Services During a Federal Government Shutdown?

Shutdown terminology can create unnecessary confusion.

Under the Antideficiency Act framework, certain government activities may continue during a lapse because they are funded from available sources or fall within recognized exceptions. These can include activities expressly authorized by law, activities necessarily implied by other authorized functions, certain constitutional duties, and work necessary to protect human life or government property.¹

OMB requires agencies to maintain contingency plans identifying which activities will continue and which will cease during a lapse.¹

For contractors, however, the question is more specific than whether an agency performs “excepted work.”

A contact center may support an agency function that continues during the shutdown, but the contractor still needs to know:

whether its contract has available funding
whether contractor support is required for the continuing activity
whether necessary federal oversight will remain available
whether systems and facilities will remain accessible
whether the Contracting Officer has directed performance to continue

A federal contact center therefore should not make its own assumption that service is either excepted or non-excepted based solely on the mission of the agency.

The contract, available appropriations, agency contingency plan, and written direction from authorized government personnel determine what happens next.

What Is a Stop-Work Order in Federal Contracting?

If an agency determines that contract performance should stop, the Contracting Officer may issue a stop-work order where the applicable contract clause provides for it.

FAR 52.242-15 permits the Contracting Officer to require the contractor to stop all or part of the work covered by the order. Once the order is received, the contractor must comply and take reasonable steps to minimize costs associated with the stopped work.⁴

For a labor-intensive contact center, that instruction creates an immediate financial decision.

Agents may already be scheduled.

Payroll obligations may be approaching.

Supervisors, trainers, quality personnel, workforce planners, and subcontracted staff may all be attached to the program.

The contractor cannot simply continue performing in the hope that the Government will eventually pay for the work.

At the same time, immediately releasing trained personnel creates another risk. If appropriations return several days later, the contractor may be expected to restart operations quickly without knowing how many people will return.

A strong stop-work response therefore has two jobs:

control costs now and protect restart capacity later.

FAR 52.242-15 also provides a mechanism for an equitable adjustment when a stop-work order is canceled and it has increased the time or cost required for performance, subject to the contract terms and notice requirements. The clause generally requires the contractor to assert its right to an adjustment within 30 days after the stoppage ends.⁴

That makes contemporaneous documentation essential.

How Government Shutdowns Affect Contractor Payroll and Cash Flow

Federal employees affected by a lapse have statutory protection for retroactive pay under the Government Employee Fair Treatment Act of 2019. The law applies to employees of the United States Government and certain District of Columbia employees.⁵

Contractor employees do not have equivalent automatic protection.

The Professional Services Council’s 2025 shutdown guidance states plainly that no federal law guarantees shutdown-related back pay for contractor employees once appropriations are restored.⁶

For contact center contractors, that makes payroll runway part of continuity planning.

Before September 30, leadership should already understand the cost of several scenarios:

Three to five business days of disruption. Can payroll continue while the contractor waits for clearer direction?

Two weeks. Which workforce costs can the business absorb without reimbursement certainty?

Thirty days or longer. What retention decisions become necessary, and how would they affect restart?

The answer will differ by contractor, contract type, workforce size, and funding position.

What matters is that the decision has been modeled before the company is forced to make it under pressure.

Payroll planning should also distinguish between employees who continue performing funded work, employees whose work is stopped, and personnel who could potentially be redeployed temporarily.

Without that separation, the contractor risks making one workforce decision for employees facing very different contractual circumstances.

Workforce Contingency Planning for Federal Contact Center Contractors

The immediate temptation during a shutdown is to focus entirely on cost reduction.

For contact center programs, that can create a second problem when the shutdown ends.

A trained agent is not an interchangeable seat.

Employees may hold agency-specific knowledge, completed background checks, system credentials, specialized program training, or experience handling complex customer populations.

If those employees leave during an extended lapse, restarting the contract may require recruiting, onboarding, credentialing, and retraining before the contact center can return to its previous capacity.

Contractors therefore need a workforce contingency plan with more than one option.

Some employees may remain fully active because their work continues.

Others may move temporarily to another funded program where contractual and employment requirements permit.

Some may need reduced schedules or furloughs.

Critical supervisors, trainers, or specialized personnel may warrant a different retention strategy because losing them would materially slow restart.

The objective is to understand which workforce capabilities would be hardest to rebuild.

That analysis is particularly important for programs requiring specialized experience, public trust determinations, suitability requirements, or agency-specific systems knowledge.

A shutdown may last days. Reconstructing the workforce it disrupted can take considerably longer.

How Federal Contractors Should Manage Subcontractors During a Shutdown

Prime contractors cannot build shutdown resilience only around their direct workforce.

If subcontractors provide agents, recruiting support, training, technology, quality assurance, or other operational capacity, uncertainty flows downstream quickly.

Subcontractors need clear direction on:

whether work should continue
which tasks are affected
when costs should stop accruing
what documentation must be maintained
which personnel should remain available
how restart communications will work

The prime also needs visibility into subcontractor decisions that could affect continuity.

If a staffing subcontractor furloughs an entire workforce on day one, the prime needs to know what that means for restart capacity.

If personnel are redeployed elsewhere, how quickly can they return?

If a subcontractor continues incurring costs without clear authorization, who carries that exposure?

Shutdown planning therefore needs a communications path that reaches every organization responsible for contract performance, not simply the prime’s internal management team.

How to Document Shutdown Costs for Potential Cost Recovery

Shutdown conditions move quickly, which makes documentation easy to postpone.

That is a mistake.

If a contractor later seeks an equitable adjustment or other allowable recovery associated with a stop-work order, it needs evidence connecting the disruption to the resulting cost or schedule impact.

FAR 52.242-15 specifically requires contractors receiving a stop-work order to minimize costs allocable to the stopped work and establishes conditions for adjustments after work resumes.⁴

Contractors should therefore maintain a shutdown record from the first notice through restart.

That record should capture:

written direction from the Contracting Officer
dates and times when work stopped or changed
affected contract line items or functions
staffing actions taken
payroll and benefit costs
subcontractor instructions and responses
costs incurred to preserve the workforce
canceled or postponed training
system or facility access interruptions
restart costs
schedule or performance impacts
steps taken to mitigate additional expense

Informal conversations can help teams operate, but contractual direction should be documented through the appropriate government channels.

The shutdown file should make it possible to reconstruct what happened without relying on memory weeks or months later.

What Should Be Included in a Federal Contractor Shutdown Contingency Plan?

A useful shutdown plan should answer operational questions before appropriations become uncertain.

Funding and Obligated Contract Value

What amount is currently obligated, and what period of performance or work does it support?

Government Personnel and System Dependencies

Which agency employees, systems, facilities, and approvals are necessary to continue service?

Stop-Work and Continuation Authority

Who is authorized to tell the contractor to continue, reduce, or stop performance?

Workforce Retention and Redeployment

Which employees would continue working, which could be redeployed, and which positions are most important to retain for restart?

Payroll Runway and Cash Flow

How long can the contractor maintain different workforce scenarios without assuming reimbursement that has not been authorized?

Subcontractor Communication

What instructions and reporting requirements will flow downstream?

Cost and Performance Documentation

Who owns the record of shutdown-related direction, costs, workforce changes, and operational impacts?

Restart and Workforce Recovery

How quickly can the program return to normal staffing and service levels once appropriations resume?

That last question deserves as much attention as the shutdown itself.

Continuity planning is successful when the program can absorb the interruption without losing the workforce, knowledge, or operating capacity it needs when the government reopens.

How Salem Solutions Supports Government Shutdown Workforce Continuity

Salem Solutions helps federal contact center contractors build workforce models that can respond when operating conditions change quickly. That includes maintaining candidate pipeline depth, supporting rapid backfill, planning for surge and redeployment needs, and protecting workforce continuity when programs move between full operations, reduced activity, and restart.

For prime contractors, appropriations uncertainty is easier to manage when the workforce plan already accounts for who must stay, where staffing can flex, and how quickly capacity can be restored.

Preparing your federal contact center workforce for FY27? Talk to us about building a continuity and restart staffing plan before you need it.

References

Office of Management and Budget, “Section 124: Agency Operations in the Absence of Appropriations,” OMB Circular No. A-11, 2025, https://www.whitehouse.gov/wp-content/uploads/2025/08/a11.pdf.
U.S. Department of Justice, “Lapse in Appropriations Reference Guide,” Justice Management Division, accessed August 2026, https://www.justice.gov/doj/page/file/779511/dl?inline=.
Federal Acquisition Regulation, “52.232-22 Limitation of Funds,” Acquisition.gov, effective March 13, 2026, https://www.acquisition.gov/far/52.232-22.
Federal Acquisition Regulation, “52.242-15 Stop-Work Order,” Acquisition.gov, effective March 13, 2026, https://www.acquisition.gov/far/52.242-15.
U.S. Department of Justice, “Government Employee Fair Treatment Act of 2019,” January 2019, https://www.justice.gov/doj/page/file/1124746/dl.
Professional Services Council, “Government Shutdown Fact Sheet,” updated November 12, 2025, https://www.pscouncil.org/a/Resources/2025/Shutdown_2025/Government_Shutdown_Fact_Sheet.aspx.

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References

Government Shutdown Resilience for Contact Center Contractors

What Happens to Federal Contractors During a Government Shutdown?

How Funding Status Affects Federal Contract Performance During a Shutdown

What Are Excepted Services During a Federal Government Shutdown?

What Is a Stop-Work Order in Federal Contracting?

How Government Shutdowns Affect Contractor Payroll and Cash Flow

Workforce Contingency Planning for Federal Contact Center Contractors

How Federal Contractors Should Manage Subcontractors During a Shutdown

How to Document Shutdown Costs for Potential Cost Recovery

What Should Be Included in a Federal Contractor Shutdown Contingency Plan?

Funding and Obligated Contract Value

Government Personnel and System Dependencies

Stop-Work and Continuation Authority

Workforce Retention and Redeployment

Payroll Runway and Cash Flow

Subcontractor Communication

Cost and Performance Documentation

Restart and Workforce Recovery

How Salem Solutions Supports Government Shutdown Workforce Continuity

References

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