QUESTION:    “I hear that they changed the rules that apply to the Paycheck Protection Program so that nonprofits can qualify for PPP loan forgiveness if they employ no more than 500 employees at any given physical location, even if they employ more than 500 employees overall. Is that so?”

ANSWER:      Yes. Section 5001 of the so-called American Rescue Plan Act provides:  “a nonprofit organization shall be eligible to receive a covered loan if the nonprofit organization employs not more than 500 employees per physical location of the organization.”  An interim final rule implementing this change was promulgated by the U.S. Small Business Association on March 22, 2021.  86 Fed. Reg. 15083. This is so even if the organization employs more than 500 employees overall.