A Stop-Work Order is a written direction from the Federal Government requiring a contractor to temporarily stop all or a specified portion of work under a contract. The order is used when the Government needs to suspend performance for a limited period while preserving the possibility that the work will later resume.
Stop-work authority is addressed in several parts of the Federal Acquisition Regulation, depending on the type of contract and clause involved. FAR 42.1303 discusses stop-work orders generally, while clauses such as FAR 52.242-15 establish procedures for covered supply, service, or research and development contracts. Construction contracts can involve different suspension provisions, so contractors should always identify the clause incorporated into the specific contract before determining their rights and obligations.
A stop-work order does not normally terminate the contract. The contractual relationship continues, but the affected performance is paused until the Government cancels the order, allows the applicable period to expire, extends it by agreement when permitted, or takes another contractual action.
What Happens When a Stop-Work Order Is Issued?
A stop-work order should identify the work being suspended and provide sufficient direction for the contractor to understand what activities must cease. Depending on the circumstances, the Government may stop the entire project or only a defined portion of performance.
The contracting officer may use a stop-work order when circumstances make continued performance temporarily undesirable. The reason can involve changes in government requirements, funding or program decisions, technical questions, review of the work, acquisition planning issues, or other matters requiring the Government to pause performance.
Once the contractor receives the order, the immediate priority is determining its scope. Continuing work that the Government has expressly ordered stopped can create questions about whether resulting costs are recoverable, while stopping activities that were not covered by the order can unnecessarily disrupt performance.
The contractor should promptly determine:
- which contract line items, tasks, locations, or activities are affected;
- the effective date and time of the stop-work direction;
- whether any activities must continue despite the order;
- which employees, subcontractors, suppliers, and facilities are affected;
- what costs can reasonably be avoided during the suspension;
- what steps are necessary to protect completed and partially completed work;
- what records will be needed if an adjustment is later requested.
The contractor is generally expected to comply with the order and take reasonable steps to minimize costs associated with the stopped work. This obligation makes cost control an immediate contract administration issue rather than something that can be addressed only after performance resumes.
The project team should also preserve the condition of work at the time of suspension. Records showing labor assignments, material commitments, subcontractor status, equipment utilization, inventory, scheduled milestones, and work in progress can later help establish the actual effect of the order.
Duration, Cancellation, and Resumption of Work
Under the Stop-Work Order clause at FAR 52.242-15, the contracting officer may order the contractor to stop work for a period of 90 days. The parties may agree to extend that period. The exact rights and procedures applicable to a particular contract depend on the clause and circumstances involved.
During the stop period, the Government may determine that performance should resume. The contracting officer can cancel the stop-work order, after which the contractor must resume the affected work according to the contractual direction provided.
Restarting work can involve more than simply returning employees to their previous assignments. A prolonged suspension may affect supplier availability, subcontractor schedules, equipment, material prices, staffing, sequencing, and delivery dates.
Consider a contractor that is performing a technical integration project when the Government orders work stopped for 60 days. During the pause, specialized personnel may be reassigned to other projects and a subcontractor may move its scheduled work to another customer. When the stop-work order is canceled, restoring the original project schedule could require additional mobilization and coordination costs.
A contractor should document both sides of the interruption:
| Stage | Records That May Be Important |
|---|---|
| Immediately Before the Stop | Schedule status, staffing, work in progress, outstanding commitments |
| During the Stop | Idle resources, mitigation actions, reassigned personnel, supplier communications |
| Before Restart | Availability of labor, materials, subcontractors, equipment, and facilities |
| After Restart | Remobilization costs, schedule changes, productivity effects, revised delivery dates |
| Final Cost Review | Actual additional costs, avoided costs, credits, and supporting documentation |
These records can help distinguish costs caused by the stop-work order from ordinary performance expenses or unrelated project problems. That distinction can become important when the contractor seeks an adjustment.
If the Government does not cancel the order, another contractual action may follow. Depending on the applicable clause and circumstances, the Government may terminate the affected work or otherwise modify the contract rather than directing performance to resume.
Cost and Schedule Adjustments After a Stop-Work Order
A stop-work order can produce financial effects even when no productive work is being performed. Employees may become temporarily idle, subcontractors may incur delay costs, equipment may remain committed, and the contractor may need to preserve materials or partially completed work.
FAR 52.242-15 provides a mechanism for an equitable adjustment when a stop-work order is canceled or expires and the suspension results in an increase in the time required for performance or in the contractor’s properly allocable costs. The contractor must comply with the clause requirements, including applicable timing requirements for asserting the right to an adjustment.
Potential effects can include:
- additional labor associated with shutdown and restart activities;
- reasonable costs of protecting work during the suspension;
- equipment or facility costs attributable to the delay;
- subcontractor costs caused by the stop and subsequent restart;
- remobilization expenses;
- schedule extensions resulting from the period in which work could not proceed;
- other properly supported costs attributable to the Government’s direction.
These costs are not automatically reimbursable simply because they occurred during the same period as the stop-work order. The contractor should be able to demonstrate a causal relationship between the Government’s direction and the claimed impact.
Mitigation is equally important. If a contractor could reasonably avoid certain costs but chooses not to do so, recovery can become more difficult. Project managers should document decisions such as reassigning personnel, canceling unnecessary deliveries, placing subcontractor work on hold, or reducing equipment commitments.
An adjustment may involve both money and time. A contractor whose work was stopped for 45 days may need more than a 45-day extension if the interruption caused additional sequencing or mobilization effects, but those consequences should be supported by project records rather than assumed.
The contract clause also establishes procedural requirements for seeking an adjustment. Contractors should review those requirements when the order is received, not months after work resumes, because notice and submission periods can affect recovery.
Stop-Work Order, Suspension, and Termination
Several government actions can interrupt contract performance, but they should not be treated as identical. A stop-work order is generally temporary and anticipates that the Government will later decide whether performance should resume or whether another contractual action is necessary.
A suspension of work may arise under clauses designed for particular contract types, especially construction. FAR 52.242-14, Suspension of Work, addresses certain unreasonable suspensions, delays, or interruptions ordered by the contracting officer in covered construction contracts.
Termination is fundamentally different because it ends all or part of the contractor’s obligation to continue the terminated work. A termination for convenience reflects the Government’s contractual right to discontinue performance when appropriate, while a termination for default or cause can involve contractor performance failures and significantly different consequences.
The practical distinction is important when a contractor receives government direction that affects performance. Before deciding how to respond, the company should identify the actual contractual authority being used rather than describing every interruption as a “stop-work order.”
The wording of the contracting officer’s direction, incorporated clauses, affected work, duration, and stated authority can determine what procedures apply. An informal request from program personnel to “pause” work can also create risk if the person issuing the instruction lacks authority to change contract performance.
Contractors should seek appropriate contracting officer direction when there is uncertainty about whether work has formally been stopped. Continuing or suspending substantial performance based solely on informal instructions can create later disputes over authorization and cost responsibility.
Managing a Stop-Work Order in Practice
The first days following a stop-work order often determine how well a contractor can later explain its cost and schedule impact. The project team should establish a separate record of affected activities rather than allowing stop-related costs to become mixed with normal contract performance.
Accounting and project controls should identify incremental costs and avoided costs where possible. The contractor should also track which personnel were reassigned, which commitments were canceled, and which expenses continued because they could not reasonably be avoided.
Communication with subcontractors deserves particular attention. A prime contractor may remain responsible for managing its subcontract relationships even though the Government has directed the prime to stop work. Flowing appropriate instructions to affected subcontractors and documenting their resulting costs can prevent later uncertainty.
The contractor should also avoid assuming that the Government’s order automatically authorizes additional spending. The purpose of the stop is generally to halt affected performance, so any preservation, shutdown, or other necessary activities should be evaluated against the contract and the contracting officer’s instructions.
When the order is canceled, the contractor should establish a clear restart record. Updated schedules, staffing plans, supplier confirmations, and revised completion forecasts can show how the interruption changed the remaining work.
A well-documented stop period creates a factual timeline connecting the Government’s direction to its actual consequences. If the interruption produces a compensable increase in cost or performance time, those records provide the basis for preparing an equitable adjustment rather than relying on estimates reconstructed long after the event.
For a GSA contractor, the same basic principle applies when a stop-work clause is incorporated into the relevant order or contract. The contractor should look first to the actual contractual language governing the work because rights and remedies depend on the applicable clause, not simply on the fact that the procurement involves a GSA contract vehicle.
A Stop-Work Order should therefore trigger two actions at the same time: immediate compliance with the contracting officer’s direction and immediate documentation of its effects. The work may be temporary paused, but the contractor’s contract administration responsibilities continue throughout the interruption.
