What to expect from TTB during the government shutdown

January 21, 2018
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Update 1/23/2018: The government is now back open and TTB is back to work, at least for 3 more weeks.

Update 1/22/2018: TTB’s website has been updated with information about the cessation of operations. The post below has been revised to reflect the new information that Permits Online, Formulas Online, and COLAs Online will be available but not monitored.

When the government officially shut down at midnight on Friday night, TTB employees had already gone home for the weekend. Unless Congress is able to strike a deal to keep the government open over the next twelve hours or so, those employees will not report to work on Monday morning.

Lessons from 2013

We don’t have any word yet on what licensees should expect this time around in terms of available services from TTB during the shutdown. However, we do have some semi-recent experience that might inform what’s likely to happen tomorrow if the government does not open. In 2013, during the last government shutdown, TTB sent out an “Appropriations Lapse Notice” that detailed their cessation of services, including limited access to the TTB.gov website. Specifically, Permits Online, Formulas Online, and COLAs Online were all taken down and not accessible. Pay.gov, however, was available for filing of electronic payments and returns for federal excise taxes and operational reports.

What to expect

If the 2013 process holds true, licensees can expect the following during the shutdown.

  1. TTB employees will not show up for work and can not answer any questions.
  2. Permits Online will not be available. (2018 update: available, but not monitored)
  3. Formulas Online will not be available. (2018 update: available, but not monitored)
  4. COLAs Online will not be available. (2018 update: available, but not monitored)
  5. Excise tax and operational reports might be available through pay.gov. (2018 update: confirmed that pay.gov is available)
  6. Additional guidance on the new Federal Excise Tax (FET) law will be delayed.

Get ready!

During the furlough, we recommend that you continue your normal compliance processes, with a few exceptions. Here’s a list of tips for what to do during the shutdown.

  • Continue to file your operational reports and make your FET payments. Regardless of whether you use paper forms, or pay.gov, continue this process as per usual.
  • Get ready and organized with any new Formulas, COLAs, and Permit changes that you need to make. A “virtual queue” of these items that are waiting to be submitted will start to build during the shutdown, and when TTB resumes operations they’ll likely process each on a first-come, first-served basis. Accordingly, it’s important to be ready the minute that operations resume so you can submit and get at the front of the virtual queue. Continue to submit any new Formulas, COLAs, and Permit changes through the TTB website to make sure your applications are in the queue. Since TTB employees won’t be available to process the submissions though, expect delays and longer processing times.
  • If you’re a Compli client, continue to follow your normal processes as if nothing has changed. We’ll have your items all ready to go and will submit them as soon as services are available again. We will continue to submit them as normal during the shutdown.
  • If you’re not a Compli client, setup an appointment so we can show you how we add value to hundreds of beverage alcohol suppliers every day.

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