Revised DPAP Q&A released – implementation of CARES Act, Section 3610

Craig StetsonInsight 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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