FFCRA Leave Effective April 1: DOL Issues Additional Guidance
DOL has issued additional guidance to assist employers in providing Families First Coronavirus Response Act (FFCRA) emergency sick and family leave. We previously wrote on the FFCRA on March 18, 2020 ( link ). Below is important information to prepare for implementation this week. Will state or local isolation orders qualify an employee for FFCRA sick leave? It depends. Leave taken prior to April 1 regardless of the qualifying reason will not be eligible for FFCRA’s tax credit. However, if needed after April 1, . . . Read More
The CARES Act and Leave Guide for Employers: Deciding Which Option is Best for You and Your Employees
Congress passed the Coronavirus Aid, Relief, and Economic Security Act (the “Act” or the “CARES Act”) on March 27, 2020 in an effort to mitigate the economic impact of COVID-19 on businesses and employees. President Trump is expected to sign the bill into law any moment. Once signed, the CARES Act allows businesses to apply for loans to continue paying employees and maintaining operations, which may be forgiven, expands on provisions of the Families First Coronavirus Act ( FFCRA ), and . . . Read More
Contracting Officers Can Pay You Even If the Contract Is Shut Down!
Yesterday, we discussed the emergency loan programs and loan forgiveness opportunities for small businesses in the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”). However, it is critical to understand that there are other avenues for relief that do not have to wait for SBA or private lenders to start processing such loans. Specifically, OMB Memorandum M-20-18 gave Contracting Officers (“CO”) broad authority and specifically states that all contracting personnel should “feel fully empowered to use acquisition flexibilities.” Further, Section 3610 of the Act, entitled “Federal Contractor Authority,” specifically states that . . . Read More
Senate Passes Historic COVID-19 Stimulus Package: Billions Set Aside for Small Businesses
On March 25, 2020, the U.S. Senate unanimously passed the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act”), and the House of Representatives is expected to similarly pass the CARES Act on March 27, 2020. The legislation represents an unprecedented stimulus package as the government attempts to mitigate the economic damage associated with the novel COVID-19 pandemic. Below is a summary of some of the central components of the stimulus package that focus on economic relief for small businesses. . . . Read More
Breaking Down SBA’s COVID-19 Economic Injury Disaster Loan
UPDATE: Since this alert was posted, all states and territories received an EIDL decaration. Also note that loan terms will change with the CARES Act. Please follow the linked text to PilieroMazza’s Client Alert “ Senate Passes Historic COVID-19 Stimulus Package: Billions Set Aside for Small Business ” for recent developments. _____________________________________________________________________________________________________________________________________________________________________________________________________ The unprecedented impact of the COVID-19 pandemic on small businesses has caused the Small Business Administration (SBA) to institute an Economic Injury Disaster Loan (EIDL) program aimed at aiding those affected by the pandemic. Whether you’re a government contractor . . . Read More
COVID-19 Emergency Sick and Family Leave: What Employers Need to Know
The United States Senate just rubber stamped the House version of emergency measures to help employees and families in response to the COVID-19 pandemic during this National Emergency. The law includes provisions you have likely been following closely. President Trump is expected to sign the bill this evening and it is expected to go into effect on April 2. Below, we’ve broken down what employers need to know now to prepare their business for sick and family leave in the era of . . . Read More
Alert! FAR Council Changes Rules Regarding Small Business Rerepresentation/Recertification and Multiple Award Contracts (MACs)
On February 27, 2020, the FAR Council published a final rule (Rule) that amends the Federal Acquisition Regulation (FAR) to implement regulatory changes made by the Small Business Administration (SBA) in 2013. See 78 Fed. Reg. 61114 (Oct. 2, 2013). Although these “new” rules have been reflected in SBA regulations for some time, their addition to the FAR is significant because, as any experienced government contractor knows, procurement officials do not always follow SBA’s rules, particularly if such rules are not incorporated . . . Read More
Coronavirus in the Workplace—What Employers Need to Know
As the potential spread of coronavirus disease 2019 (COVID-19) in the United States becomes a very real possibility, employers should prepare to address the condition and concerns in the workplace. The Center for Disease Control and Prevention and the Occupational Safety and Health Administration recently issued guidance on steps to mitigate the spread of COVID-19. In light of this guidance, employers should consider implementing certain policies and procedures to continue to ensure a safe and healthy workplace. The policy can . . . Read More
CMMC Is Coming: Are You Ready?
PilieroMazza previously blogged at length regarding the draft releases of the Cybersecurity Maturity Model Certification (CMMC) guidelines in anticipation of its final release. The Department of Defense (DOD) released the final version of the CMMC guidelines on January 31, 2020. For government contractors, the release signals the start of their preparation, in earnest, for CMMC certification to improve their chances of doing business with the DOD. IT system audits are set to begin in mid 2020, and DOD plans to require certification . . . Read More
The 2020 NDAA’s Impact on Government Contractors
On December 17, 2019, the Senate passed the National Defense Authorization Act (NDAA) for Fiscal Year 2020, sending it to the White House for the President’s signature. As with prior NDAAs, the 2020 NDAA includes a number of provisions that affect procurement policy, management, and related matters. Below, we summarize some of the more notable provisions that will impact government contractors. Section 823 – Modification of Justification and Approval Requirement for Certain Department of Defense Contracts Section 823 of . . . Read More