March 25, 2020

Dear Member:

The Senate has reached a deal on The Coronavirus Aid, Relief and Economic Security (CARES) Act, also known more commonly as Phase III. It is our expectation the Senate will pass this legislation soon, and the idea behind the lengthy behind the scenes negotiations is that the House should follow suit in the coming days. This, however, like all things in Washington, DC, is subject to change.

For your convenience, below you will find two links to the actual legislative text, and below that you will find an outline of a “Section by Section” summary that summarizes the main sections of the legislation.

Additionally, attached is a summary of the SMALL BUSINESS provisions prepared by the Chairman and Ranking Member of the Senate Small Business Committee. These are likely the most applicable to you and your businesses.

Additionally, as you and your employees may have questions, below are some common Q&A prepared by the Ways & Means Minority that we have found helpful:

Q: If (and when) the CARES Act gets passed, who gets the tax rebate checks?

A: As long as a person has a valid Social Security number, they can receive the credit and have no tax liability requirement.

  • The full credit amount ($1,200 individuals, $2,400 couples, $500 for children) is available for those with incomes at or below $75,000 individual/$112,500 head of household/$150,000 joint.
  • The credit phases out above those thresholds and will be phased out completely for single taxpayers with incomes exceeding $99,000 and $198,000 for joint filers.
  • See the attached Ways and Means document for more information.

Q:When will we see guidance from DoL on how employees and employers will be able to take advantage of the protections and relief offered by the Families First Coronavirus Response Act (FFCRA) when it takes effect on April 1, 2020?

A: Today, the U.S. Department of Labor’s Wage and Hour Division (WHD) announced its first round of published guidance

Q:How are programs like TANF being utilized to help families being adversely impacted by COVID-19?

A: Attached is guidance about how state and tribal grantees might use Temporary Assistance for Needy Families (TANF) to help those in need.

  • States and tribes set the criteria for “needy,” and can set different income levels for different services. A state or tribe could assist needy families in which parents are unable to work due to contracting the disease, exposure to someone with the disease, because their children’s school or child care provider has closed, or because their own work place has closed.

Q:  Given the critical shortage of PPE and vitally important supplies during the pandemic, what are we doing to remediate those scarcities?

A: Companies are shifting their production lines to produce materials Americans desperately need, like hand sanitizer, and the US government is cutting red tape to allow them to do so:

  • See the linked FDA guidance, “Temporary Policy for Manufacture of Alcohol for Incorporation Into Alcohol-Based Hand Sanitizer Products During the Public Health Emergency (COVID-19)” that clears the way for distilleries, who are not currently regulated by FDA as drug manufacturers, to produce alcohol-based hand sanitizers.
  • Watch the linked video that highlights Desert Door distillery, located in Rep. Brady’s district, about how they are utilizing FDA’s recent issuance.

Useful Links:


This member exclusive update has been provided in consultation with our Washington, DC-based government affairs and global business advisory firm, The Vogel Group –

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