DCArea1102

The first part of Section 3610 says only those who cannot perform their job remotely and they can’t access a Government or Government approved site are eligible.

Hi All, I have received a request for equitable adjustment using the authority given in Sec. 3610 of the CARES Act. The request is for nearly $125k total across various service CPFF Task Orders performed by a single contractor. I am having trouble determining if the contractor is even eligible for funds though. My agency has little guidance on the topic and I have looked to DFARS 231.205-79 and DoD posted checklists/guides for further guidance. I have a meeting with our agency counsel but would like to have a polished opinion to present to them. The problem, in my opinion, is the services are for coordinating and processing travel for Federal employees and invited guests of the agency. However, the agency stopped 95% of travel starting in March due to COVID-19. We all know how anyone can book travel remotely (ex. I can book hotels, rental cars, airfare, etc. all from my phone) and that it doesn't need to happen at a Government facility or Government approved site. The contractor is stating that because of the drastic reduction that now their employees can't bill enough time and are taking paid leave so they can continue to get paid. Furthermore, the contractor stated in their request that they have been able to process the 5% of travel remotely. So I'm looking at this from the perspective of: 1) they admitted the service can be performed remotely and 2) the services of booking travel regardless if for the Government or personal can be performed in a remote setting. I'm debating it from all angles because in the end it will probably affect about 15 contractor employees. Can anyone confirm my thinking is aligned with their understanding of the applicability portion of the section?