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On Sunday, President Trump signed a combined COVID-Relief and Omnibus Spending Bill, The Consolidated Appropriations Act of 2021, which funds the Federal Government for FY 2021 and includes a variety of COVID-19-related relief measures.  Among those measures, Section 1002 of the Act extends the reimbursement period for Section 3610 of the CARES Act, which

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On December 9, 2020, the Department of Defense Office of Inspector General (DoD OIG) released its Audit of Department of Defense Implementation of Section 3610 of the Coronavirus Aid, Relief, and Economic Security Act.  The audit assesses the DoD’s issuance of relief under Section 3610, which authorizes certain agencies to reimburse contractors for any

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On November 6, the Information and Communication Technology (ICT) Supply Chain Risk Management (SCRM) Task Force, a public-private supply chain risk management partnership, published Lessons Learned During the COVID-19 Pandemic. In laying out the challenges posed by the pandemic, the report highlights the inevitable tension in supply chain risk management between achieving efficiencies and

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From the inception of the Paycheck Protection Program (PPP), borrowers questioned the meaning of the economic necessity certification that the Small Business Administration (SBA) required borrowers to make in the PPP loan application. While the SBA provided some definition to this certification in such Frequently Asked Questions as FAQs 31, 37, and 46, uncertainty remained.

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On October 2, 2020 (almost two months after the August 10, 2020 commencement of the acceptance period for forgiveness applications), the Small Business Administration (SBA) released an SBA Procedural Notice (the “Notice”) concerning required procedures for change of ownership of an entity that has received PPP loans (the “PPP Borrower”). Under the Notice, SBA approval

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On August 18, 2020, the Acting Principal Director for Defense Pricing and Contracting (DPC) issued updated guidance regarding contractor and subcontractor reimbursement of paid leave costs under the CARES Act § 3610, including two key Class Deviations, both effective immediately. First, it issued Revision 1 to Class Deviation 2020-O0013, which revises and supersedes

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On August 4, 2020, the Small Business Administration (SBA) released a Frequently Asked Questions (FAQs) addressing numerous technical issues on PPP Loan Forgiveness. On August 11, 2020, the FAQs were updated to include additional guidance for recipients of both PPP Loans and Economic Injury Disaster Loans.

The following are the major takeaways from the

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On August 10, the Federal Emergency Management Agency (FEMA), under the Department of Homeland Security, will be extending and revising a Temporary Final Rule (first issued in April this year) that invokes the Defense Production Act (DPA) to allocate certain Personal Protective Equipment (PPE) for domestic use and prohibit exportation of that PPE from the

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On July 28, 2020, the U.S. Small Business Administration (SBA) Office of the Inspector General (OIG) issued a report titled, “Serious Concerns of Potential Fraud in the Economic Injury Disaster Loan Program Pertaining to the Response to COVID-19.” The report identifies and summarizes OIG’s “serious concerns” of potential fraud and calls for “immediate attention and

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On July 6, 2020, the Small Business Administration (SBA) has made publicly available various types of information about all Paycheck Protection Program (PPP) loans, and targeted media scrutiny has immediately followed. For loans of $150,000 and above, the SBA has released the loan range (e.g., $150,000 – 350,000, $1,000,000 – 2,000,000, $5,000,000 – 10,000,000) and