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Jun 5 2020    Next issue: Jun 19 2020

Can you get 3610 & PPP?

      Federal contractors that qualify for forgivable loans under the Paycheck Protection Program--and also qualify for Section 3610 relief from some payroll costs--face “complex and sometimes conflicting guidance” on whether they are permitted to accept funds under both programs, according to an analysis by Holland & Knight LLP.

      Most agencies allow contractors to access both CARES Act programs, as long as the funds are not applied to cover the same costs, Holland Knight attorneys wrote in a recent blog.

      However, some agencies, in their guidances, regulations and contract modifications, suggest that Section 3610 funding must be reduced by the amount of PPP, even if a contractor applies each program to separate costs.

      “What if a contractor uses PPP funds to pay for one set of payroll and business costs, while using Section 3610 funds to pay for a different set of payroll costs?” they wrote. “Both scenarios are consistent with the CARES Act, but some agency guidance may suggest a different view.”

More Information:
Holland & Knight alert: https://bit.ly/2Y08jA6

     

Inside this edition:

Defense Production Act brings compliance risks for vendors

8(a) STARS hits ceiling

GSA says 80% have OK’d ‘mass mod’

Updated Coronavirus Resources for Small Business Federal Contractors

OPM guides on flex schedules

Prepping for CIO-SP4

GSA’s OASIS SB picks

IG reviewing Sweeney’s role in tribe relief

Can you get 3610 & PPP?

Column: Five Steps for Employers Preparing a Returning Workforce in a COVID19 Environment

Washington Insider:

  • House bill has extras for defense contractors
  • Rule to require notices of bundling
  • SBA removes some former SDB rules



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