COVID-19 Guidance for Employee Benefit Plans

DOL issued new COVID-19 Guidance for Employee Benefit Plans. The guidance includes a few helpful documents:

• Extension of Certain Timeframes for Employee Benefit Plans, Participants, andBeneficiaries Affected by the COVID-19 Outbreak;
• EBSA Disaster Relief Notice 2020-01; and
• Frequently Asked Questions.

Unfortunately, benefits plans issues are always complicated. Take, for example, this question that both employers and employees have been struggling with:

Q1: If my place of employment temporarily closes because of the COVID-19 outbreak, am I still covered by my employer's group health plan?

What's the answer?

As long as the employer exists, continues to sponsor a health plan, and employs you, and you continue to meet your employer's eligibility requirements, you would generally remain covered under your existing health plan, even if the employer's physical location closes

This just raises more questions. Are employees who are laid off during the quarantine still "employed?" What if they're on UC? What are the eligibility requirements? And on, and on. This guidance is a good start though.