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