S. DOT on 3/. ACEC is reviewing it and has asked our group of CPA experts for their analysis and feedback as well. They have also requested a meeting with DOT/FHWA to discuss the guidance and its potential impact on the industry.

The guidance appears to be largely consistent with the draft that FHWA put out in January, with a few new components.

• If the PPP loan proceeds are applied to costs (direct or indirect) within the scope of a federally funded contract and the PPP loan is forgiven, appropriate adjustments are necessary to comply with 48 CFR part 31 (the cost principles).
• AE consultants cannot use PPP loan proceeds to pay for the direct costs on a Federal-aid or Federal lands highway program funded contract.
• AE consultants cannot bill direct costs and use PPP loan proceeds to fund the compensation costs of direct labor and other direct costs dedicated to federally funded contracts. Read more