PPP Federal Contractors Guide - AS OF JUNE 30, 2020 - Aronson LLC

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PPP Federal Contractors Guide - AS OF JUNE 30, 2020 - Aronson LLC
PPP Federal
Contractors Guide
     AS OF JUNE 30, 2020
PPP Federal Contractors Guide - AS OF JUNE 30, 2020 - Aronson LLC
PAYCHECK PROTECTION PROGRAM

I. Overview
The Paycheck Protection Program (PPP) is one of several programs under the Coronavirus Aid,
Relief, and Economic Security Act (CARES Act) designed to help small businesses cope with
the financial devastation caused by COVID-19. This $650+ billion program provides potentially
forgivable loans to eligible small businesses in order to assist them with the payment of specific
expenses, namely, payroll costs, rent, utilities, and certain interest payments. PPP loans are
provided by SBA-certified lenders and guaranteed by the SBA. If certain conditions are met, up
to the full amount of a borrower’s PPP loan can be forgiven.

The amount companies can borrow under the PPP depends on their “payroll costs”, as taken
from the business’ calendar year 2019 records (though calendar year 2019 is not the only
measurement option). These payroll costs include:
•   Gross salaries/wages (salaries/wages before anything is withheld from the employee). This
    is capped at $100,000 per employee

•   PLUS company-paid benefits, such as health insurance and retirement plans

•   PLUS company-paid state and local taxes assessed on compensation, such as state
    unemployment tax
This total is divided by 12 and multiplied by two-and-a-half to arrive at the loan amount for which
the borrower is eligible.

The extent to which a PPP loan may be forgiven depends in part on the borrower’s forgivable
costs during a 24-week forgiveness covered period that starts on the date the loan funds are
disbursed to the business. PPP borrowers who received their loans before June 5, 2020 may
elect to use an eight-week forgiveness covered period. Forgivable costs include the above-
mentioned “payroll costs” as well as rent, utilities, and interest on certain loans. There are,
however, a number of ways in which the amount of loan forgiveness otherwise available may
be reduced.

An important tax feature for PPP loans is that forgiveness is tax-free to borrowers. However,
based on IRS Notice 2020-32 the associated forgivable costs are not tax deductible. Stay tuned
as legislative efforts are underway to overturn IRS Notice 2020-32.

This guide will focus primarily on those contractors that have closed on a PPP loan. Should your
business need assistance determining if it qualifies for the program and if it would be beneficial
to receive a loan, please reach out to the experts at Aronson for assistance. The deadline to
apply for a PPP loan is June 30, 2020.

The sections following will address the key considerations contractors should be aware of
should they choose to take a PPP loan. This is a complex program and this document cannot
address all of the things borrowers should consider. Each company’s situation will be different,
so consultation with a trusted advisor is recommended.

                                                              PPP FEDERAL CONTRACTORS GUIDE | 2
PPP Federal Contractors Guide - AS OF JUNE 30, 2020 - Aronson LLC
II. Paycheck Protection Program ­Maximum Loan Amount
Determining the PPP maximum loan amount is a complex process, however, below is an illustration
of how the maximum amount could be calculated.

To determine the maximum PPP loan amount, corporate borrowers follow a four-step process:
•   Step 1: Compute 2019 payroll costs
•   Step 2: Calculate the average monthly payroll costs (divide the amount from Step 1 by 12)
•   Step 3: Multiply the average monthly payroll costs from Step 2 by 2.5
•   Step 4: Adjust for outstanding EIDL loans, if applicable
For this purpose, payroll costs include the following:
•   Employee gross salaries/wages          •   Retirement contributions
•   Health insurance                       •   State and local payroll taxes
With respect to employee gross salaries/ wages, it is important to note that amounts in excess of an
annualized cap of $100,000 per employee are excluded, in addition to FFCRA emergency sick leave
wages, and only the wages of employees whose principal place of residence is the United States
should be included. With respect to health insurance, retirement contributions, and state and local
payroll taxes, keep in mind these would include only the employer portion (i.e., don’t include amounts
withheld from employees) and are not subject to the $100,000 cap. The illustration below walks
through a calculation of the maximum PPP loan amount for a corporation.

                    2019 reported gross wages                                      $ 4,700,000
                    Less: adjustment for $100,000 cap                              $ (340,000)
                    Less: adjustment for principal place of residence              $-
                    2019 adjusted gross wages                                      $ 4,360,000
Step 1
                    2019 ER health insurance contributions                         $ 250,000
                    2019 ER retirement contributions                               $ 175,000
                    2019 ER SUI                                                    $ 15,000
                    2019 payroll costs                                             $ 4,800,000
Step 2              Average monthly payroll costs                                  $ 400,000
Step 3              Average monthly payroll costs times 2.5                        $ 1,000,000
Step 4        Adjustment for outstanding EIDL loans                                $-
Maximum loan amount                                                                $ 1,000,000

In the illustration above, if the borrower receives a PPP loan in the amount of $1,000,000, it
would initially be reported as a liability by the borrower. Financial accounting considerations are
discussed in Section V.

                                                               PPP FEDERAL CONTRACTORS GUIDE | 3
PPP Federal Contractors Guide - AS OF JUNE 30, 2020 - Aronson LLC
III. Paycheck Protection Program ­Potential
Forgiveness
While our hypothetical PPP borrower in the illustration above has a $1,000,000 liability on day
one, there is a potential for loan forgiveness depending on how the funds are used over the
ensuing 24 weeks.

Loan forgiveness will ultimately be based on a borrower’s forgivable costs over a 24-week
forgiveness covered period commencing on the date the lender makes the first disbursement
to the borrower. Forgivable costs include specified payroll costs and non-payroll costs.

Forgivable payroll costs include gross salaries/wages, employer health insurance contributions,
employer retirement contributions, and employer state and local payroll taxes. Gross salaries/
wages are generally subject to a $100,000 annualized cap per individual for this purpose (i.e.
not to exceed $46,154 for the 24-week period). Note that for business owners the rules are a
little different. The cap on business owner gross salaries/wages is the lesser of $20,833 or the
2.5-month equivalent of their applicable compensation in 2019. In addition, the following items
are to be excluded from forgivable payroll cost: (i) employer health insurance contributions
made on behalf of self-employed individuals, partners in partnerships, or owner-employees of
an S-corporation; and (ii) employer retirement contributions made on behalf of self-employed
individuals partners in partnerships.

Forgivable non-payroll costs include rent, utilities, and mortgage interest. Rent includes
payments for real or personal property under leasing agreements in effect prior to February 15,
2020. Utilities includes payments for expenses such as electricity, gas, water, transportation,
telephone, or internet access (service must have been established prior to February 15, 2020.
Mortgage interest includes real and personal property on real or personal property mortgages in
effect prior to February 15, 2020.

The amount otherwise available for forgiveness may be reduced (i) if employee headcount
levels are not maintained (based on a comparison of average FTEs for specified periods) or (ii) to
the extent individual salaries decrease by more than 25% during specified periods (applies only
to employees compensated at an annualized rate of $100,000 or less).

As if this framework wasn’t complicated enough, there is an additional wrinkle. Borrowers can
restore any reduction in FTEs or salaries that occurred between February 15, 2020 and April 26,
2020 if they do it by June 30, 2020.

In addition, PPP borrowers must contend with “the 60% rule.” The 60% rule establishes a
limitation on the amount of forgiveness based on forgivable payroll costs. Specifically, PPP loan
forgiveness cannot exceed the quotient of x ÷ y, where x = forgivable payroll costs, and y =
60%. So, if our hypothetical borrower had forgivable payroll costs of $540,000 during its
24-week forgiveness covered period, PPP loan forgiveness could not exceed $900,000.

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PPP Federal Contractors Guide - AS OF JUNE 30, 2020 - Aronson LLC
Forgiveness applications are to be submitted to the lender that is servicing the loan using SBA
Form 3508. Lenders are required to issue a decision to the SBA on forgiveness within 60 days
of the receipt of the application. The SBA then has 90 days to remit the appropriate forgiveness
amount to the lender, subject to any SBA review process.

In terms of recordkeeping considerations, to the greatest extent possible borrowers will want
to focus on keeping PPP loan proceeds segregated, tracking the usage of PPP loan proceeds
carefully, and maintaining appropriate supporting documentation. Supporting documentation
will vary depending on the applicable cost category. Attention to these details should serve PPP
borrowers well when it comes time to apply for loan forgiveness with their lenders.

Readers of this document should be aware that as of the date of its publication, there are
numerous areas where a lack of clarity remains, and current guidance is subject to change.

In addition, because of the evolving terms of the program, and changes in economic
uncertainty, it is important that contractors document contemporaneously their basis for
making the certification in good faith that current economic uncertainty made the loan request
necessary to support their ongoing operations. Based on SBA guidance released on May 13,
2020, borrowers with loans less than $2 million will be deemed to have made the required
certification in good faith. However, additional scrutiny will be applied to borrowers of more than
$2 million. If you have concerns about your certification, consult with your legal and accounting
advisors.

Finally, while discussed in depth later, contractors should carefully consider the effect of loan
forgiveness on its direct and indirect costs. DoD guidance explicitly states loan forgiveness is
interpreted as a credit due back to the government on Federal contracts in accordance with the
FAR. More later.

RECOMMENDED TIPS

•   Keep meticulous records showing how the funds were used at the time they were
    expended.

•   Stay on top of any new guidance the SBA or Treasury issues, which occur regularly.

•   Extreme attention to detail is required to be able to proactively manage the loan proceeds to
    ensure forgiveness.

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PPP Federal Contractors Guide - AS OF JUNE 30, 2020 - Aronson LLC
IV. PPP Tax Implications
Although the loan forgiveness is tax-free to the eligible borrowers, there are a number of
tax implications associated with that forgiveness. Below we discuss some of the other tax
considerations impacted by the PPP program.

Non-Deductibility of Payments to the Extent Income Resulting from Loan Forgiveness:
IRS Notice 2020-32 states: “no deduction is allowed under the Internal Revenue Code
(Code) for an expense that is otherwise deductible if the payment of the expense results in
forgiveness of a covered loan.” The IRS is taking a tax position (for federal tax purposes) that
is disallowing a tax deduction for those same forgivable costs related to the PPP loan. The IRS
is arguing that the taxpayer receiving the loan forgiveness is essentially being reimbursed for
those associated forgivable costs. While legislation to make these expenses deductible has
been introduced, it has not been enacted into law.

PPP Interplay with Payroll Tax Credits and Payment Deferrals:
There have been a number of payroll related tax credits created recently under the Family First
Coronavirus Response Act (FFCRA) and CARES Act. There are interactions between the PPP
and these other tax provisions (please refer to our other guidance for details on the eligibility
requirements and applications).

FFCRA related credits (Paid Sick Leave-For Employee, Paid Sick Leave-As Caregiver and Family
and Medical Leave-As Caregiver) do not impact PPP eligibility. However, if an employer utilizes
the FFCRA payroll tax credits during the loan forgiveness period, those otherwise eligible
payroll costs will be reduced by the wages generating the payroll tax credits.

The CARES Act created another payroll tax credit: the Employee Retention Credit (ERC).
The CARES Act specifically prohibited the double benefit of PPP participation and the ability
to receive that payroll tax credit. The statute did contemplate a timing difference where an
employer could take advantage of the ERC until it received the PPP funding. Once PPP funding
is received, any previous ERC benefit will be recaptured and going forward the employer is not
eligible for the ERC.

The CARES Act also provided a payroll tax payment deferral for the employer portion of Social
Security taxes due between March 27, 2020 and December 31, 2020. Half of that deferred tax
payment would be due by December 31, 2021 and the remaining half due by December 31,
2022.

                                                              PPP FEDERAL CONTRACTORS GUIDE | 6
State Income Tax Conformity:
Many states generally follow the federal income taxation treatment for specific items/
transactions. However, there are a number of areas where states have deviated from the federal
tax treatment (ex. IRC Section 179 deduction and IRC Section 199A: Qualified Business Income
deduction). It remains to be seen whether states will decouple from the federal tax treatment
which allows the loan forgiveness to be non-taxable.

PPP TAX TIPS
When you are scheduling out your eligible payroll costs for loan forgiveness see if you can
“bracket” any of the other benefits that may not be eligible during that period:

•   See if you can avail yourself to FFCRA payroll tax credits before and after the 24-week period

•   Contemplate whether you should participate in payment deferral for payroll taxes (check with
    your payroll provider to go over the logistics of future deferred tax payments)

V. Financial Reporting Considerations
A look at the financial reporting considerations for CARES Act provisions most likely to be used
by middle market and small contractors.

PPP Loan:
For contractors that intend to repay the PPP loan, regardless of whether the loan could be
forgiven, the loan should be recorded as debt and interest accrued at the stated 1% rate. There
is no need to impute interest.

Not-for-Profit Organizations:
For contractors that are organized as not-for-profits (NFP), PPP recipients should treat the
loans as a government grant. The loan is considered a conditional contribution and should be
accounted for as a refundable advance (liability) until the conditions for forgiveness have been
substantially met. When the satisfaction of conditions occurs, the refundable advance is released
to contributions revenue. Since the conditions for the PPP program are met over time by virtue
of the payment of qualified expenditures, contributions revenue will be recognized as qualifying
expenses are incurred. If a NFP estimates that a portion of the loan will not be forgiven,
interest is accrued on that amount. Interest is not accrued on the portion that is expected to
be forgiven. The accounting standard prohibits netting the forgiven portion of the loan against
the expenditures that gave rise to the forgiveness. In other words, the contribution revenue
and qualifying expenses should be recorded at gross, not net. If a for profit entity has already
adopted a policy for government grants, the entity should consider the treatment of the PPP loan
under that policy.

                                                             PPP FEDERAL CONTRACTORS GUIDE | 7
Commercial Business Entities:
There is no U.S. generally accepted accounting principles (GAAP) guidance that specifically
addresses accounting by a commercial contractor that obtains a forgivable loan from a
government entity. Therefore, management must analogize to other guidance. If a contractor
has an existing policy for accounting for government grants, then management should
determine if the PPP loan fits under that policy. Otherwise, commercial contractors should
consider the following models:

•   The Government Grant Model described above.

•   International Accounting Standard 20 Model (IAS 20) on government assistance.

•   The Debt Model.

With respect to the Government grant model, as described above, companies that choose
this model should have a high confidence level (“substantially met”) they will meet the
criteria for the loan to be forgiven. Also note, under this model, contribution income and the
related forgiven expenses are required to be reported at gross. Adjustments will be required
to reconcile to the Company’s cost allocation methodology, or conversely, if expenses are
recorded at net in order to take advantage of a system’s ability to calculate indirect rates and
allocate indirect expenses, a top side entry will be required to show contribution revenue and
expenses at gross. An advantage of this model, as well as with the IAS 20 model below, is that
the credit for forgiveness will be accounted for in the same period as the covered expenditures,
resulting in more predictability of indirect cost rates.

The IAS 20 model is very similar to the Government grant model, with a few minor differences.
Under this model, as with the Government grant model, a liability is recorded upon the receipt
of funds. As qualified expenses are incurred, and management concludes there is “reasonable
assurance” the terms for forgiveness will be met, the entity releases the liability (credit) to the
income statement. Reasonable assurance, while not defined, is a slightly lower confidence level
than “substantially met” in the Government grant model. Unlike the Government grant model,
the IAS 20 model allows for gross or net presentation as a policy election. Finally, IAS 20 states
that a grant that becomes repayable is treated as a change in estimate.

Under the debt model, contractors record the loan as debt and accrue interest accordingly
unless and until forgiven. Interest is accrued at the 1% stated rate and should not be imputed.
The loan is recorded as current and/or long-term depending management’s assessment
of when the liability will be satisfied. The loan liability is derecognized only if it is legally
extinguished. We believe that as a best practice, the gain (credit) on derecognition should
follow the expenditures that were used to support the loan forgiveness application. In other
words, if PPP funds were used for direct labor, the credit should be applied against direct labor,
same for overhead and G&A labor and any other allowed disbursements. This is a good model
for contractors that are uncertain whether the loan will be forgiven. Its primary disadvantage is
the recognition of the credit for the forgiveness does not necessarily match the timing of the
incurred costs that resulted in forgiveness, so a situation could arise where costs are accounted

                                                              PPP FEDERAL CONTRACTORS GUIDE | 8
for in one period and forgiveness is accounted for in another. This could make for challenging
budgeting and contract management.

Guidance cited above is courtesy of the AICPA’s Center for Plain English Accounting, and is not
authoritative. Authoritative guidance may to be issued later, or alternatively, private companies
will benefit from reviewing public company filings. As shown above, when specific guidance
does not exist, entities may apply analogous U.S. GAAP for similar transactions and/or consider
nonauthoritative guidance from other sources, such as IFRS. It should be noted that entities
formed as not-for-profits should follow guidance that applies to them.

Of the three models above, contractors that conclude with reasonable assurance the Company
will meet the terms for forgiveness, will likely find the IAS 20 model to be their preferred model.
Regardless of the model chosen, disclosures of the accounting policy decisions will be required
in the Company’s annual financial statements. Contractors should consult with their advisors on
which model would be best for their situation.

Income Taxes:
Contractors should consider the effects of the CARES Act with respect to its current and
deferred income taxes. Any effects of the changes in the law will be recorded in the first
reporting period that includes March 27, 2020.

Corporate entities should evaluate the effect of the newly allowed NOL carrybacks on deferred
and current income taxes and the potential for reversal of valuation allowances. The Company’s
annual effective tax rate may need to be adjusted based on the periods the contractor is
carrying back to (21% vs. 35% tax rates). Valuation allowances that were recorded due to the
uncertainty of future recovery need to be re-assessed should the Company have the ability to
carry back those NOL’s.

Contractors may need to adjust their income tax receivables and payables for the increase
in the allowed deduction for business interest expense from 30% of the taxpayer’s adjusted
taxable income to 50% for 2019 and 2020.

Careful distinction should be made between provisions that affect income taxes versus other
types of taxes; payroll for instance. Credits for other taxes should be applied in the portion
of the income statement where the expenses are normally charged, ideally through a contra
account.

Other Considerations:
Contractors should consider whether there has been a triggering event that requires review of
goodwill, indefinite lived and other intangibles, and long-lived assets for impairment. Forecasts
and projected cash flows should be updated to show the new reality of the business.

The Financial Accounting Standards Board (FASB) has deferred the effective date of the leasing
standard for private companies with a calendar year to January 2021. The FASB has proposed
an additional deferral of the effective date until January 1, 2022. The comment period for the
proposed deferral ended on May 6, 2020.

                                                              PPP FEDERAL CONTRACTORS GUIDE | 9
Consider re-reading your debt agreements and ensure the entity is not in default of any
provisions in the agreement. Discussing any defaults with your lender is best done sooner
rather than later. Subjective acceleration clauses may turn what was a long-term liability into a
current liability.

Consider whether disclosures should be made about going concern. Let us face it, the world
has changed. While adverse events can bring out the best in people, be realistic about the
effects these events will have on your business. Management is required to assess the ability
of the entity to continue as a going concern within one year of the date the financial statements
are issued. Key stakeholders such as lenders and customers should also be kept apprised of
the situation.

TIPS
•   Account for use of the PPP loan funds contemporaneously rather than wait until the end of
    the year.
•   Read credit agreements as they may have provisions prohibiting new debt. Talk with your
    banker about how to handle this issue.
•   Determine the effect on current debt covenants. Common covenants such as debt to equity,
    current ratio, and debt service coverage will likely be affected.
•   Consider obtaining waivers for any triggered debt covenants or other violation of credit
    agreements. Also consider whether the classification of long-term debt should be made
    current if agreements contain a subjective acceleration clause.

•   Consider the effects of the exclusion of PPP loan forgiveness and non-deductible related
    expenses in your provision for income taxes.
•   Consideration of impairment should be started early in the fourth quarter, or sooner if
    a triggering event has been identified, as to not delay the issuance of year-end financial
    statements. Agree early on with your audit firm whether an outside analysis is required.
•   Stay informed as guidance is evolving and may change.

                                                             PPP FEDERAL CONTRACTORS GUIDE | 10
VI. Considerations for federal contractors on negotiated
contracts
There is a famous saying: buyer, or in this case - “borrower beware.” There are very few “things” that
come to federal contractors “no strings attached” and the PPP is no different. It is not the SBA that is
treating federal contractors differently, rather the contracts terms and conditions that were agreed to
within federal contracts. Negotiated contracts have a provision to receive “credits” associated with
allowable costs. It would be prudent for contractors to understand how loan forgiveness is interpreted
as a “credit” due back to the government on federal contracts in accordance with the FAR. The
Contracting Officer or Federal cognizant auditor would point to the FAR Part 31 for ALL negotiated
contracts and specifically cite the provision of FAR 52.216-7 for cost reimbursable contracts.

While we do not think this is a deterrent to accepting the loans, nor the forgiveness of the loans,
contractors should be aware they cannot “have their credit and keep it too.”

LET’S LOOK SPECIFICALLY AT THE FAR:
FAR part 31, Contract Cost Principle and Procedures, which contains cost principles and procedures
for all contracts entered into by negotiation under FAR Part 15, Contracts by Negotiation (basically,
contracts outside commercial item acquisition) specifically addresses credits when determining the
composition of total cost.

FAR 31.201-1 (a), Composition of total cost reads:
(a) The total cost, including standard costs properly adjusted for applicable variances, of a contract is
    the sum of the direct and indirect costs allocable to the contract, incurred or to be incurred, plus
    any allocable cost of money pursuant to 31.205-10, less any allocable credits. In ascertaining
    what constitutes a cost, any generally accepted method of determining or estimating costs that is
    equitable and is consistently applied may be used.

FAR 31.201-5 Credits reads;
   The applicable portion of any income, rebate, allowance, or other credit relating to any allowable
   cost and received by or accruing to the contractor shall be credited to the Government either as a
   cost reduction or by cash refund.…

Also, the provision of FAR 52.216-7, which is required for cost reimbursement contracts,
addresses the issue, as well:
   The Contractor shall pay to the Government any refunds, rebates, credits, or other amounts
   (including interest, if any) accruing to or received by the Contractor or any assignee under this
   contract, to the extent that those amounts are properly allocable to costs for which the Contractor
   has been reimbursed by the Government. Reasonable expenses incurred by the Contractor for
   securing refunds, rebates, credits, or other amounts shall be allowable costs if approved by the
   Contracting Officer. Before final payment under this contract, the Contractor and each assignee
   whose assignment is in effect at the time of final payment shall execute and deliver.

                                                             PPP FEDERAL CONTRACTORS GUIDE | 11
RECOMMENDED TIPS
•   Keep meticulous record of the use of the funds.
•   Continue to monitor guidance released by federal agencies.
•   Prepare cost models considering the application of a credit to allowable costs paid for with
    PPP loan proceeds at varying rates beginning with 100% loan forgiveness.
•   Prepare indirect rate projections considering FFCRA and PPP and well as any other changes
    to operations for the year.
•   Open communication with contracting officers.
•   As guidance is received and facts and circumstances are known, i.e. forgiveness of loan/
    amount of forgiveness determine the impact, we believe this will be complex (thus we
    focus on meticulous details of records).

       •   Determine if a credit could be due on direct labor.
       •   Calculate indirect rates to determine if there is a material change, if yes resubmit
           provisional billing rates.

                                                             PPP FEDERAL CONTRACTORS GUIDE | 12
EXAMPLE

PPP loan forgiveness example FAR accounting
EXAMPLE ASSUMES A $1,000,000 LOAN 100% FORGIVEN.
The $1,000,000 PPP loan was used as follows:

•   $900,000 for payroll costs: $850,000 in labor, and $50,000 for fringe benefits (health
    insurance). $850,000 labor cost as follows:

       •   $500,000 was attributed to direct labor.

       •   $200,000 and $150,000 to overhead and G&A labor, respectively.

•   $100,000 of proceed were used for rent for facilities that were charged to G&A during this
    period due to 100% telework.

The results will vary based on the use of the proceeds and amounts forgiven

Fringe Pool
Leave (Holiday & PTO)                        500,000		                                   500,000
Statuatory fringe (FICA FUTA SUTA WC)        500,000		                                   500,000
Health Benefits                              225,000              (50,000)               175,000
Employer 401(k)match                         125,000		                                   125,000
                                             1,350,000		                               1,350,000

Fringe Base                                  4,500,000            (850,000)            3,650,000
Fringe Rate                                  30.0%		                                         35.6%

Overhead Pool
Overhead Labor                               700,000              (200,000)              500,000
Fringe on Overhead Labor                     210,000              (31,918)              178,082*
Other overhead cost                          250,000		                                   250,000
                                             1,160,000            (231,918)              928,082
Overhead Base
Direct Labor                                 3,500,000            (500,000)            3,000,000
Fringe on Direct Labor                       1,050,000            (18,493)             1,031,507
                                             4,550,000            (481,507)            4,068,493
Overhead Rate                                25.49%		                                        22.81%

                                                             PPP FEDERAL CONTRACTORS GUIDE | 13
General & Administrative Pool
G&A Labor                                    300,000             (150,000)                 150,000
Fringe on Labor                              90,000              (36,575)                   53,425
Other G&A Costs                              400,000             (100,000)                 300,000
                                             790,000             (286,575)                 503,425
General & Administrative Base
Direct Labor                                 3,500,000           (500,000)                3,000,000
Fringe on Direct Labor                       1,050,000           (18,493,00)              1,068,493
ODC                                          250,000 		                                    250,000
Overhead Labor                               700,000             (200,000)                 500,000
Fringe on Overhead Labor                     210,000             (31,918)                  178,082
Overhead Costs                               250,000 		                                    250,000
                                             5,960,000           (713,425)                5,246,575
G&A Rate                                     13.26%		                                         9.6%
Wrap Rate                                    1.85%		                                         1.83%
*Note: Once calculated, the actual fringe after the applied credit is used, thus 35.6%.

If a contractor had 100% cost reimbursement contracts, we believe the costs would flow back
through the reduction of $ 500,000 of DL and the following adjustment to indirect rates.

                              Total costs reduced by $1,000,000
Direct Labor                                 3,500,000 		                                 3,000,000
Fringe Rate                                  30.0%		                                         35.6%
Fringe on Direct Labor                       1,050,000 		                                 1,068,493
Overhead Base                                4,550,000 		                                 4,068,493
Overhead Rate                                25.49%		                                       22.81%
Overhead Pool                                1,160,000 		                                  928,082
G&A                                          5,710,000 		                                 4,996,575
ODC                                          250,000 		                                    250,000
G&A Base                                     5,960,000		                                  5,246,575
G&A Rate                                     13.26%		                                         9.6%
G&A Pool                                     790,000 		                                    503,425
Total Cost                                   6,750,000 		                                 5,750,000

                                                            PPP FEDERAL CONTRACTORS GUIDE | 14
Contact Us
The Paycheck Protection Program is a complex area to navigate and each federal contractor will
have their own unique solution. Aronson can assist you in finding that solution.

Contact our team today at 240.630.0702 to start the conversation on how we can help your
business navigate the PPP process.

AUTHOR                     AUTHOR                    AUTHOR                  AUTHOR

Nicole Mitchell            Tom Christiana            Mike Muscatello William Foote
PARTNER                    PARTNER                   PARTNER                 PARTNER
                                                                             William Foote, CPA leads
Nicole Mitchell, CPA,      Tom Christiana, CPA,      Mike Muscatello,
                                                                             the Forensic & Valuation
CGMA, MBA, is a            MST, is a partner in      CPA, CGMA, is a
                                                                             Services and Transaction
partner in Aronson’s       Aronson’s Tax Services    partner in Aronson’s
                                                                             Advisory Services
Government Contract        Group, where he           Government Contract
                                                                             practices at Aronson. He
Services Group, where      specializes in the tax    Services Group where
                                                                             assists clients across
she specializes in         issues affecting          he specializes in
                                                                             a variety of industries,
accounting and financial   government contractors.   providing thoughtful
                                                                             including government
issues impacting                                     business, accounting,
                                                                             contracting.
government contractors.                              and tax solutions
                           p: 240.364.2624
                                                     to government           p: 301.231.6299
p: 301.222.8231            e: tchristiana@
                                                     contractors.            e: wfoote@
e: nmitchell@              aronsonllc.com
                                                                             aronsonllc.com
aronsonllc.com                                       p: 301.231.6277
                                                     e: jmuscatello@
                                                     aronsonllc.com

                    INFO@ARONSONLLC.COM | ARONSONLLC.COM

                                                              PPP FEDERAL CONTRACTORS GUIDE | 15
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