DFC Contingency Plan

Agency Operations in the Absence of 

Appropriations

As required by OMB Circular A-11 Sec 124

U.S. International Development Finance Corporation 

Updated September 22, 2023
1. Introduction

The U.S. International Development Finance Corporation (DFC) has developed this contingency 

plan in accordance with Office of Management and Budget (OMB) Circular A–11 (2021), Section 

124, and OMB memorandum M- 13-22 (dated September 17, 2013). The actions outlined in

this plan would be initiated only in the event there is a lapse in appropriation. For the 

purposes of this plan, lapse of appropriations means both a lack of enacted appropriations 

law AND that DFC has exhausted its carryforward balances. This plan applies to all personnel

and contractors assigned to or performing services for DFC. This contingency document is 

provided for a short-term shutdown (1-5 days – A-11 [2021] 124.2). A long-term event will 

require further analysis and development.

As of September 22, 2023, DFC has sufficient carryforward balances to operate during a 

short-term lapse of appropriations. With limited exceptions, no furloughs or changes to 

operations will be required for any short- or medium-term lapse of appropriations. Seven 

detailed from other agencies would be subject to instructions from funding agency. DFC 

continues to update its budget projections and will update this plan accordingly.

While DFC has sufficient carryforward to maintain operations, DFC is developing plans to 

address interagency coordination, Congressional Notification process, and project approval

activities.

2. Shutdown Contingency Overview

The DFC is pursuing a comprehensive approach for a potential shutdown in the event that we 

exhaust our carryforward balances, which includes identifying functions and programs for 

which there is a legal basis for exception, including those required by “necessary implication” 

and protection of life and property. The functions and programs were identified based on longstanding OMB and U.S. Department of Justice guidance, and the legal opinion of DFC’s Office

of General Counsel (OGC). DFC’s OGC has reviewed this document to ensure compliance with 

these criteria.

As a result, DFC’s current projection is that approximately 47% of DFC employees would be 

required to perform excepted functions in the event that DFC should be impacted by a 

shutdown event. The number of employees to be retained under the plan meeting A-11, 

Section 124.2 criteria is 280, and the number of employees not otherwise exempt is 321.
DFC Lapse1 Plan Summary Overview

Estimated time (to nearest half day) required to complete shutdown activities: 1

Total number of agency employees expected to be on board before 

implementation of the plan: 601

Total number of employees to be retained under the plan for each of the following 

categories (may include duplicated counts):

Compensation is financed by a resource other than annual appropriations: 6

Necessary to perform activities expressly authorized by law: 1

Necessary to perform activities necessarily implied by law: 204

Necessary to the discharge of the President’s constitutional duties and powers: 0

Necessary to protect life and property: 81

Brief summary of significant agency activities that will continue during a lapse:

Honoring insurance (mandatory) and financing contracts. Failure to honor these DFC 

obligations would severely jeopardize the DFC's mission and activities as necessarily 

implied by law.

Safeguard the existing portfolio of contractual obligations to fund disbursements, providing 

consents, making payments under guaranties, insurance contracts and any other contracts 

with providers of goods and services, insurance premiums and loan repayments, except 

when DFC’s operations are dependent upon other government agencies severely affected 

by such a shutdown.

Protect life and property and ensure security of IT systems data.

Brief summary of significant agency activities that will cease during a lapse:

Committing support, sourcing new non-core mission business, recruiting, staffing, training, 

non-emergency procurement.

3. Orderly Shutdown

The Office of Human Resources Management (OHRM) will notify DFC employees regarding 

their status as excepted or non-excepted from a lapse in appropriation furlough. HRM will also 

provide guidance for orderly shutdown activities, including messaging to external stakeholders

and securing of Government Furnished Equipment (GFE). Appropriate operations notifications 

1

For the purpose of this plan, lapse of appropriations means a lack of enacted appropriations law AND DFC has exhausted its

carryforward balances.
will be placed on the DFC externally facing website. Employees will be advised to check the 

external website daily for operations updates.

IAA funded employees are subject to instructions from their funding agency. 

DFC’s Office of Administration (OA) will inform contractors (including Personal Services 

Contractors) of their status under a lapse in appropriation furlough.

With the exception of staff who are on official travel, orderly shutdown activities are expected 

to be completed within approximately two hours of the scheduled tour of duty for nonexcepted employees. Non-excepted staff who are on travel will receive instructions to return 

to their Duty Station and complete orderly shutdown activities as soon as possible.

4. Resuming Normal Operations

OA will utilize the DFC emergency notification system to contact employees when the agency 

is able to resume normal operations, and when they are expected to return to duty.

Operational information will also be updated on the DFC external website.

OA will inform contractors (including Personal Services Contractors) when the agency is able to 

resume normal operations and provide instructions for resuming work.
Appendix A. Impact of the Shutdown on the

Workforce2

DFC ORGANIZATION

EMPLOYEES 

DURING 

NORMAL 

OPERATIONS

FULLY FUNDED: 

WILL CONTINUE 

TO WORK

EXCEPTED 

EMPLOYEES (OTHER 

LEGAL BASIS: WILL 

CONTINUE TO 

WORK)

NONEXCEPTED 

EMPLOYEES 

(SUBJECT TO 

FURLOUGH)

Office of the Chief Executive Officer 

(OCEO) 66 4* 17 49

Office of Development Credit (ODC)

85 1* 53 32

Office of Financial and Portfolio 

Management (OFPM) 92 0 61 31

Office of General Counsel (OGC)

69 0 40 29

Office of Development Policy (ODP)

64 0 22 42

Office of Structured Finance & 

Insurance (OSFI) 49 1* 26 23

Office of Administration (OA)

51 0 20 31

Office of Equity and Investment Funds 

(OEIF) 33 0 17 16

Office of External Affairs (OEA)

23 0 5 18

Office of Information Technology (OIT)

27 0 13 14

Office of Human Resources 

Management (OHRM) 42 0 6 36

Total DFC 601 6 280 321

 Office of the Inspector General (OIG) 14 14 0 0

*Six IAA funded employees.

2

This portion of their plan is tentative and that in the case of an extended lapse that lasts over a couple months, DFC will 

need to re-assess to confirm which specific functions may continue during a lapse.
5

Appendix B. Effect of Lapse of Funding on DFC Activities3

DFC Unit Total # of 

Employees

# of Fully 

Funded (not 

subject to 

lapse; will

continue to 

work)

# of Excepted 

Employees 

(legal basis; 

will continue 

to work) Legal Basis for Decision or Full

Funding Source

Functions to be Performed

# of Non-Excepted 

Employees(subject 

to furlough)

Office ofthe Chief 

Executive Officer 

(OCEO)

66 0 17 PAS = 2

Fully funded by Department of 

State = 4

Necessarily implied = 15 

Protection of life and property = 1

Core Mission 49

Office of the 

Inspector General 

(OIG)

14 14 0 2-year appropriation = 14 Core 

Mission

0

Office of 

Development Credit 

(ODC)

85 2 53 Fully funded by USAID = 1

Necessarily implied = 7 

Protection of life and property = 

46

Core Mission 32

Office of Financial 

and Portfolio 

Management 

(OFPM)

92 0 61 Necessarily implied = 58 

Protection of life and property = 3

Core Mission 31

Office of General 

Counsel (OGC)

69 0 40 Necessarily implied = 40 Core Mission 29

3

This portion of their plan is tentative and that in the case of an extended lapse that lasts over a couple months, DFC will need to re-assess to confirm which specific 

functions may continue during a lapse.
6

DFC Unit Total # of 

Employees

# of Fully 

Funded (not 

subject to 

lapse; will

continue to 

work)

# of Excepted 

Employees 

(legal basis; 

will continue 

to work) Legal Basis for Decision or Full

Funding Source

Functions to be Performed

# of Non-Excepted 

Employees(subject 

to furlough)

Office of 

Development Policy 

(ODP)

64 0 22 Necessarily implied = 22 Core Mission 42

Office of Structured 

Finance & Insurance 

(OSFI)

49 4 26 Fully funded by USAID = 1

Necessarily implied = 9 

Protection of life and property = 

17

Core Mission 23

Office of 

Administration (OA)

51 0 20 Necessarily implied = 20 Mission Support 31

Office of Equity and 

Investment Funds 

(OEIF)

33 0 17 Necessarily implied = 7 

Protection of life and property = 

10

Core Mission 16

Office of External 

Affairs (OEA)

23 0 5 Necessarily implied = 5 Mission Support 18

Office of Information 

Technology (OIT)

27 0 13 Necessarily implied = 13 Mission Support 14

Office of Human 

Resources 

Management 

(OHRM)

42 0 6 Necessarily implied = 6 Mission Support 36
7

Appendix C – Suspended Functions in Event of a Lapse in Appropriation

Organization Functions to be Suspended

OCEO Sourcing of new non-core mission business; training

ODC Sourcing of new non-core mission business; training

OFPM Training

OGC Training

ODP Training

OEA Non-emergency communication; training

OSFI Sourcing of new non-core mission business; training

OA Training; non-emergency procurement

OEIF Sourcing of new non-core mission business; training

OIT New IT projects; training

OIG N/A; All staff are Exempt

OHRM Hiring, recruiting; training