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End of Transition Period for SBA Size Standard Calculation; Five Year Measurement Period ‎Now Required

This is a reminder that as of January 6, 2022, the Small Business Administration is requiring all small businesses to use a five-year period of measurement in determining their size under a revenue-based size standard. On...more

Upcoming Events and Deadlines for OSHA Large Employer ETS ‎

There are several upcoming events and deadlines that are relevant to the Occupational Safety and Health Administration’s (“OSHA”) “large employer” emergency temporary standard (the “ETS”), which require businesses with 100 or...more

Eligible Uses of CARES Act Funds for Compliance and Management Expenses in 2022‎

Although the deadline for “incurring” CARES Act funds has passed, Alaska Native Corporations can still use CARES Act funds to pay for administrative and compliance related expenditures in 2022, including staff time spent...more

Federal Contractor Vaccine Mandate Update: Implementation Likely Delayed Until ‎February 2022- At The Earliest - If the Mandate...

On December 7, 2021, in Georgia v. Biden, No. 1:21-cv-163, a federal judge in the United States District Court for the Southern District of Georgia issued a preliminary injunction barring enforcement of President Joe Biden’s...more

OSHA Moves to Implement Large Employer ETS by January 10, 2022, After Sixth Circuit ‎Lifts Stay

In November 2021, OSHA issued an Emergency Temporary Standard that applied to employers with 100 or more employees (the “ETS”). The ETS required those employers to either adopt a policy requiring their employees to be...more

Treasury Update Regarding Guidelines on Use of CARES Act Funds

On December 14, 2021, Treasury issued an important update to its guidance on use of ‎CARES Act funds. Currently, there is a deadline of December 31, 2021 to spend CARES Act ‎funds on eligible expenses. While Congress is...more

Safer Federal Workforce Publishes Update Regarding Court Injunctions ‎Against Federal Contractor Vaccine Mandate

On December 9, 2021, the Safer Federal Workforce Task Force issued a new statement regarding the court orders enjoining implementation of the federal contractor vaccine mandate. The Task Force statement is as...more

House Passes Extension to Use of CARES Act Funds, Goes to Senate for Consideration

On Wednesday, December 8, 2021, the House of Representatives passed H.R. 5119. This bill extends the deadline for Tribal governments (which includes Alaska Native Corporations (“ANCs”)), to use CARES Act funds from December...more

Nationwide Injunction Against Federal Contractor Vaccine Mandate ‎

On Tuesday, December 7, 2021, in The State of Georgia, et. al. v. Biden, et. al., Case No. 1:21-cv-163, a federal district court judge in the United States District Court for the Southern District of Georgia issued a...more

District Court Issues Stay of Federal Contractor Vaccine Mandate in Kentucky, Ohio, and Tennessee

On Tuesday, November 30th, the United States District Court for the Eastern District of Kentucky issued a preliminary injunction halting the government's enforcement of the federal contractor vaccine mandate on federal...more

President Biden Reinstates a Version of the Nondisplacement of Qualified Workers Under Service Contracts Executive Order

On November 18, 2021, President Biden issued an executive order reinstating a version of the Nondisplacement of Qualified Workers Under Service Contracts executive order that had previously been implemented by President Obama...more

Implementation of OSHA’s 11/5/2021 Emergency Temporary Standard Stayed by Fifth Circuit Court of Appeals

On Friday, November 12, 2021, in BST Holdings, L.L.C., et. al. vs. Occupational Health and Safety Administration, et. al., Case: 21-60845, the Fifth Circuit Court of Appeals granted the plaintiffs’ motion to stay...more

What to Know About PPP Appeals and Next Steps - After the Economic Aid Act: An Updated Guide to the PPP Loan Forgiveness Review...

Update: On September 16, 2021, the Final Rule on Borrower Appeals of Final SBA Loan Review Decisions was posted and became effective on September 14, 2021 (the “Final Rule”). The Final Rule applies to all appealable final SBA...more

OSHA Issues Emergency Temporary Standard for COVID-19 Vaccinations and Testing

On November 4, 2021, the Occupational Safety and Health Authority (“OSHA”) issued the 490-page Emergency Temporary Standard for COVID-19 Vaccinations and Testing (“ETS”), which is to be effective as of November 5, 2021. The...more

DoD and CCAC Class Deviations from Federal Contractor COVID Safety Protocols

The Department of Defense (DoD) and the Civilian Agency Acquisition Council (CAAC) have both issued new Class Deviations from the FARs that implement Executive Order 14042, Ensuring Adequate COVID Safety Protocols for Federal...more

Class Deviations

The Department of Defense (DoD) and the Civilian Agency Acquisition Council (CAAC) have both issued new Class Deviations from the FARs that implement Executive Order 14042, Ensuring Adequate COVID Safety Protocols for Federal...more

Summary of New Guidance on COVID-19 Vaccine Mandate

On September 9, 2021, President Biden issued his Executive Order on Ensuring Adequate COVID Safety Protocols for Federal Contractors (the “Executive Order”) that, when implemented, will require most federal contractors to...more

Administration Actions Regarding COVID Protocols For Federal Contractors and Large Employers

On September 9, 2021, President Biden issued orders that have the intent of requiring employers to mandate that their employees are vaccinated against COVID-19 or undergo regular testing and other restrictions. ...more

Asking for Forgiveness: Further Revised PPP Loan Forgiveness Applications and Guidance - Update

Below are 10 important things to know about the Paycheck Protection Program (“PPP”) Loan Forgiveness ‎Applications and the detailed instructions for the further revised and updated applications posted on July 30, 2021, ‎as...more

What to Know about PPP Appeals and Next Steps

Update: On July 28, 2021, an Interim Final Rule on COVID-19 Revenue Reduction Score, Direct Borrower Forgiveness Process, and Appeals Deferment was posted. That Interim Final Rule conforms the applicable PPP rules to provide...more

First Draw PPP Loans $2 Million and Up and the PPP Necessity Questionnaires - Update #2

Starting around October 26, 2020, the Small Business Administrations (the “SBA”) asked Paycheck Protection Program (“PPP”) lenders to provide certain questionnaires to PPP borrowers with loans of $2 million or greater. There...more

First Draw Loans at or Over $2 million—SBA Discontinues Use of Necessity Questionnaires and What Is Next - Update

As per our earlier articles, in late 2020, the SBA began requiring borrowers with First Draw PPP loans $2 million or greater to complete a PPP Loan Necessity Questionnaire (Form 3509 (For Profit Borrowers) or Form 3510...more

First Draw Loans at or Over $2 million—SBA Discontinues Use of Necessity Questionnaires and What Is Next

As per our earlier articles, in late 2020, the SBA began requiring borrowers with First Draw PPP loans $2 million or greater to complete a PPP Loan Necessity Questionnaire (Form 3509 (For Profit Borrowers) or Form 3510...more

PPP Loans Over $2 Million and the PPP Necessity Questionnaires - Update #3

Starting around October 26, 2020, the Small Business Administrations (the “SBA”) asked Paycheck Protection Program (“PPP”) lenders to provide certain questionnaires to PPP borrowers with loans of $2 million or greater. There...more

First Draw PPP Loans $2 Million and Up and the PPP Necessity Questionnaires - Update

Starting around October 26, 2020, the Small Business Administrations (the “SBA”) asked Paycheck Protection Program (“PPP”) lenders to provide certain questionnaires to PPP borrowers with loans of $2 million or greater. There...more

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