The full and proper title of said award is "The Congressional Medal of Honor", is it not? This indicates that Congress can award such an honor under unusual circumstances (such as seems to apply here) to whoever it sees fit to, 'contractor' status or not. The real question would be, does Congress have the will to do so...
the infowarrior
‘Medal of Honor’ is military. ‘Congressional MoH’ is not an official name for it.
Congressional Gold Medal and Presidential Medal of Freedom are highest civilian honors.