When It Matters
A stop-work order is a formal directive from a funder to pause all or part of a project immediately. A termination notice ends an award before its scheduled completion, and it may be followed by a formal change to the award agreement. A suspension is also a pause, and costs incurred during it are generally not allowable. The three can land in your inbox looking much alike, so your first job is to work out which one you are holding and whether it covers the whole award or only part of it.
The decisions after that come quickly. Someone has to decide which staff stay on payroll, what to tell the partners you fund, which costs can still go to the award, and what to say to the people who were counting on your services. Treat the notice as a deadline, not a routine administrative email.
Stop-work orders are more typical of contracts than of grants. Read the terms of your own award and use this page as a plain-language map, not as a legal opinion.
How It Works
Start with the paperwork. Read the notice for the reasons given, the effective date, and whether the termination is full or partial. Then work through these steps in order.
- Respond in writing. Acknowledge receipt and open a line to the funder's program or contracting officer. If you spot deficiencies in the notice itself, put them in writing too.
- Stop the covered work at once. Secure your sites and property, and pass the stop instruction down to every subrecipient and subcontractor.
- Send everything to the right people inside your organization. Forward funder communications to your grants or compliance office. Most replies to the funder must come from your authorized organizational representative, not from a staff member acting alone.
- Assess the damage. Look at what the stop does to operations and finances, and record the resulting costs separately from regular operating expenses so the effect is visible.
- Decide whether to challenge or accept. If the termination is not based on your own fault, you may accept it and pursue recovery of allowable costs through closeout.
Get legal counsel involved early, and read the clauses in your award that deal with stop-work, suspension and termination.
| Notice type | What it does | What it means for costs |
|---|---|---|
| Stop-work order | Requires immediate suspension of all or part of the project | Do not incur additional expenses unless explicitly authorized, and take all reasonable steps to minimize costs |
| Suspension | Pauses the award | Costs during the pause are generally not allowable, except for obligations properly incurred before it began and not made in anticipation of it |
| Termination | Ends the award early | Costs after the notice are at your own risk, with no guarantee of payment |
Under some contracts, a stop-work period is generally not to exceed 90 days, so check your own agreement. When it ends, or the order is lifted early, you are expected to resume work right away, so keep your materials, records and ability to restart intact.
Key Components
First actions, in two passes
Right away:
- Acknowledge the notice in writing.
- Stop the affected work and secure sites and property.
- Pass the notice to subrecipients and contractors.
- Forward all funder communications to your grants or compliance office.
- Call legal counsel.
- Freeze new commitments.
As the stop continues:
- Set up cost-capture codes so costs can later be sorted into allowable and unallowable.
- Decide what happens to each affected staff member.
- Keep people who should be paid through the stop date listed on the award, then reallocate their salaries to other funding afterward.
- List non-cancellable commitments, such as pre-paid tuition, stipends or fees, and gather the paperwork that justifies them.
- Chase subrecipients and contractors for outstanding invoices.
- Talk to the communities and partners you serve.
What can still be charged
Allowable costs can include unavoidable costs that could not be stopped immediately despite reasonable efforts, the lost useful value of equipment that was specific to the award and has no other use, and reasonable accounting, legal and clerical costs to settle subawards and claims.
What generally cannot
Costs from obligations you take on after termination, unless the funder expressly authorizes them. Costs that keep running because you negligently or willfully failed to stop them. Costs during a suspension, apart from the narrow exception above.
Best Practices
Decide on staff early, and be honest about the horizon. Some people can move to other work in your organization. Others may need to be furloughed or laid off. A furlough is a temporary reduction in hours or an unpaid break, with the expectation that the person returns soon. A layoff ends the employment relationship. If you cannot see an end to the funding gap, a layoff is generally the better choice, because a furlough promises a return you may not be able to deliver.
Choose who goes by neutral rules. Selection criteria should be objective and applied consistently, never tied to protected characteristics or to retaliation. Unclear or uneven criteria invite discrimination and retaliation claims.
Check notice law. Notice laws may require advance written notice to employees and to government bodies before a large closure or mass layoff. Other employment rules may apply too, so ask counsel where your staff are based. When you tell someone they are laid off, give them their last day, the date of their final paycheck, and their options for continuing health and other benefits.
Handle group severance carefully. In the United States, if an agreement covers a group and includes a release of age-related claims, employees typically get 45 days to consider it and 7 days after signing to revoke. Check the rules where your staff are based.
Tell partners directly. Tell subrecipients and local partner organizations promptly and directly, then follow up so they submit outstanding invoices. Process every allowable subaward and contractor invoice before the funder's own invoicing or reporting deadlines.
Tell communities what is stopping. A survey of 55 organizations hit by recent funding cuts found respondents linking sudden stoppages to distrust among the people they serve, and 76 percent said they no longer had the technical capacity to meet essential standards. Explain what is stopping, what is not, and where people can go instead, since abrupt stops can lead to mistrust. Safeguarding matters here too: almost half of respondents (49 percent) said their ability to protect people had shrunk, which raises the risk of exploitation and abuse in the communities they serve.
Keep the paper trail. Record every step you took to minimize costs and every cost you incurred, including idle labor, idle facilities and overhead needed to stay ready to resume.
Common Mistakes
Spending on the assumption that wind-down time will be covered. Costs after a termination notice are at your own risk, even if the termination later proves improper, with no guarantee of payment. Spend only with explicit authorization.
Using a layoff to remove someone you wanted to move on anyway. A cut in funding is not cover for a performance problem. If the position was not genuinely eliminated, the risk of discrimination, retaliation or wrongful-termination claims goes up.
Forgetting the partners downstream. The stop instruction has to be passed down to every subrecipient and subcontractor, and their outstanding invoices need following up.
Treating the stop as purely administrative. Clinics close, distributions end, and people notice. Survey respondents described abruptly halted activities as leading to mistrust from the community members they serve.
Mixing termination costs into the general ledger. If idle labor, holding costs and settlement expenses sit alongside normal spending, you cannot show what the termination cost you.
Answering the funder from the wrong desk. Most responses to the funder must come from your authorized organizational representative, so route replies through that person.
Ignoring final reports. Stopping work does not end reporting. You must still meet every final requirement the funder communicates, which can include final financial and property reports.
Example
A small health nonprofit (an illustration, not a real case) receives a termination notice for a maternal health project. It funds several local clinics through subawards and employs a team of field nurses.
The program director reads the notice and confirms it is a full termination with an effective date. She acknowledges it in writing through the organization's authorized representative and asks the funder's program contact to clarify one point that seems inconsistent. That same day the clinics are told to stop covered work and to send in invoices for services already delivered.
The finance manager opens a separate cost code for everything tied to the termination. One item goes in straight away: the lease on a field office, which cannot be canceled on short notice. The nurses who should be paid through the stop date stay listed on the award, and their salaries are reallocated to other funding afterward. She writes a short justification for the lease and files the signed contract beside it. A partial shipment of medical supplies that arrived after the stop date goes in a different bucket: the team treats it as unauthorized and asks the funder in writing whether it will be covered, rather than assuming so.
For staff, leadership sees no realistic funding within a foreseeable period, so it plans layoffs with neutral criteria rather than a furlough. It gives each nurse a last day, a final pay date and information on continuing health coverage.
The program manager meets village leaders and clinic committees to explain what is ending and where care can be found.
At closeout, the organization has a clean file: unavoidable lease costs, settlement costs for the subawards, and final invoices, all separate from regular operations.
Further Reading
- Guidance for Terminations and Stop-Work Orders: immediate actions on receiving a notice, from payroll and non-cancellable commitments to final reports.
- What Recipients Need to Know if a Grant Is Terminated: a five-step sequence from reading the notice to closeout.
- Closing a Grant: what closeout involves and which termination costs are allowable.
- Navigating Stop-Work and Termination Orders in Government Contracting: first steps and cost capture during a stop-work period.
- When Layoffs Become Unavoidable: A Nonprofit Leader's Guide to Compliance, Compassion, and Credibility: furlough versus layoff, notice rules, selection criteria and severance.