Insight by: Craig Stetson, Partner
April 18, 2020
Revised DPAP Q&A released – implementation of CARES Act, Section 3610
Revised DPAP Q&A released April 17, 2020 – re implementation of CARES Act, Section 3610. – See Blog posted 4.9.2020 with our expert insight.
Q27 – not unexpected nor unreasonable; contractors will need to provide thorough documentation to support requests for reimbursement
Q26 – employee paid time off less than 100% of employees’ total time may be reimbursable
Q24 – failure to agree with the government on requests for reimbursement is not subject to CDA
Q22 – the trigger allowing contractors to submit requests for reimbursement is determination from the CO of ‘affected contractor’ status; a contract mod is first required when seeking reimbursement under fixed-price contracts
Q23 – not clear at all; loans received and not forgiven under PPP may nonetheless qualify as credits to be used as reduction to requested reimbursements
CLICK TO DOWNLOAD FULL UPDATED FAQ – Implementation Guidance for Section 3610 of the Coronavirus Aid, Relief, and Economic Security (CARES) Act
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