Management Advisory - Recommendations for Reimbursing Contractors’ Paid Leave Under the Coronavirus Aid, Relief, and Economic Security (CARES) Act

CARES Act Section 3610 allows Federal agencies to reimburse their contractors and subcontractors for any paid leave, including sick leave, that the contractors provide to keep their employees or subcontractors in what the section refers to as a “ready state.” Because these reimbursements present a number of risks and the U.S. Department of the Interior (DOI) is already receiving Section 3610 claims from contractors, the DOI urgently needs to put policies in place to ensure consistent oversight of reimbursed leave costs. In this management advisory memorandum, we offer three recommendations that, if implemented, will help the DOI prevent fraud, waste, and abuse related to costs reimbursed under Section 3610.