Murky Waters for Government Contractors Receiving PPP Funds

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Government contractors, constantly vigilant and monitoring compliance with Federal Acquisition Regulations are faced with unprecedented uncertainty and questions surrounding acceptance of Paycheck Protection Program (PPP) funds and payments under Section 3610 of the CARES Act. Contractors must consider a) the ban against ‘double dipping’ of funds and b) must also consider that loan forgiveness under the PPP may be interpreted as a credit due back to the government in accordance with FAR 31.201-1 (a).

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