All Is Not Forgiven: PPP Forgiveness and Credits

Morrison & Foerster – On March 23, 2021, The House Small Business, Subcommittee on Contracting and Infrastructure held a remote hearing titled: “The Interaction Between the Paycheck Protection Program and Federal Acquisition Regulations:  What It Means for Government Contractors.”  The hearing focused specifically on the interplay between Paycheck Protection Program (PPP) loan forgiveness and Federal Acquisition Regulation (FAR) 31.201-5 “Credits,” and how that interplay impacts federal contractors that perform cost-type contracts.  This meeting highlights an area where contractors have, at best, incomplete guidance.