Some have questioned Rav Moshe’s ruling regarding counting a mechallel Shabbos or a kofer in a minyan for a davar she’bikedushah. They argue that while it is conceivable that for the halacha of befarhesya a mechallel Shabbos or a kofer could be counted in a minyan, for davar she’bikedushah he should not. They cite that there are differences between the two halachos (davar she’bikedushah and befarhesya). Namely, regarding the halacha of befarhesya the ten Jews need not be present, rather it is sufficient that they are aware of the aveira (see Shach Yorah Deah 157:4). While regarding a davar she’bikedushah ten Jews are required to be present.
While this distinction exists, the Gemara still derives the halachos from the same drasha, and from the same source – the meraglim. Therefore, even if there are differences in the application of the halachos, nevertheless in my humble opinion (not that he needs my approbation), the pashut p’shat remains as Rav Moshe ruled.