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Most emphasis is being placed on Sections 1102 & 1106.  But from deep in the bowels of this thing comes Section 3610.  I don't understand it and I can't seem to get a plain English version.

DoD has hopped on this thing and issued a memorandum.  If DoD does it, I don't know what's stopping other agencies.

The general perception on my part is that contractors must credit the costs resulting from loan forgiveness and pass on:

  • the cost benefit to the govt for cost-plus contracts.
  • the recovery benefit in terms of hours to the govt for T&M contracts.
  • No pass through of the benefit for fixed-price contracts, however, there's nothing stopping a force majuere equity adjustment reduction due to changed legislation.

Due I have a clue what's going on with this section 3610?  Comments invited.

I am aware there is another thread going on that is more comprehensive.  But I see a different picture than COs riding a white horse to help contractors via 3610.  More like the above...

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