“The most recent COVID conundrum presented to me is the interplay between Section 3610 and the Paycheck Protection Program or PPP (Sections 1102 and 1106 of the CARES Act).”
“The former is a cost allowability concept designed for potential reimbursement to government contractors to keep employees who are unable to work as a result of COVID-19 in a “ready state.” The latter is a type of disaster relief measure designed to provide potentially forgivable loans to small businesses in an effort to maintain employees on payroll and relieve financial stress caused by the pandemic. A challenge arises where a contractor receives payments from multiple sources…”
“In its April 17 guidance memo, OMB, also looking to avoid federal funds from “being used to make multiple payments for the same purposes,” cautioned agencies that, as part of maintaining adequate documentation for COVID-related expenses…”
“All of this may appear redundant because, as noted in my April 28 commentary, there are already many FAR provisions intended to prevent double dipping…” Read the full article here.
Source: Contractors face contradictions among COVID-19 guidance – By James Fontana, May 11, 2020. Washington Technology.
