Coronavirus Flash Update: June 2020 #8

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Alston & Bird’s Coronavirus Flash provides updates on policy and regulatory actions under consideration across many important industries being monitored by our teams. Links to key government and legal resources are provided throughout the report.


UPDATED 9:00 AM ET ON THURSDAY, JUNE 25, 2020

The Latest News

  • U.S. COVID-19 cases exceed 2,368,663 and 119,887 U.S. deaths. (Source: CDC) (Updated 6/25/20)
  • U.S. stock market: On Wednesday the major U.S. benchmarks dropped sharply, with the Dow losing 710 points, the S&P giving up 80 points, and the Nasdaq falling 222 points. (New)
  • The Departments of Labor, Health and Human Services, and Treasury have jointly released FAQs on the COVID-19 testing coverage mandate provisions included in the Families First Coronavirus Response Act (FFCRA) and the Coronavirus Aid, Relief, and Economic Security (CARES) Act. The FAQs state that the mandate applies to medically appropriate COVID-19 tests and related care for symptomatic individuals and those with known or suspected exposure to an individual with COVID-19 but does not apply to “return to work” screening testing and public surveillance testing. The FAQs also address a number of other testing-related questions and provide a safe harbor for large employers with respect to certain telehealth services. (6/23/20) (New)
  • The Governors from New York, New Jersey, and Connecticut jointly announced a 14-day quarantine restriction for incoming travelers from nine states where COVID-19 cases have surged in the past week. The restrictions will apply to states with infection rates that exceed 10 people per 100,000 on a seven-day rolling average, or if 10% of the total population tests positive on a seven-day rolling average. Nine states currently meet the criteria for restrictions: Alabama, Arizona, Arkansas, Florida, North Carolina, South Carolina, Texas, Utah, and Washington. (New)
  • And due to the increase in COVID-19 cases in:

COVID-19 Federal & State Legislation

  • Bill 4.0: The House is set to vote next week on State Healthcare Premium Reduction Act (combined with drug pricing provisions under the title, Patient Protection and Affordable Care Enhancement Act), H.R. 1425, to bolster health care coverage through the Affordable Care Act (ACA). The proposal would expand ACA tax credits, increase the federal portion for states which expand their Medicaid programs, increase funds for exchange outreach and education, and cap what any person may pay for the coverage premiums at 8.5% of their income. House Energy and Commerce Committee Chairman Frank Pallone announced this week that the ACA enhancements would be combined with drug pricing provisions previously passed and the combined measure called the Patient Protection and Affordable Care Enhancement Act. The Energy and Commerce Committee has posted a one page summary, section-by-section, and the text. The ACA enhancement measure and additional drug pricing proposal have passed the House in previous measures along party line vote. (New)
  • The HEROES Act was the first formal offer on a new emergency stimulus bill, 4.0: For the full details on the HEROES Act, H.R. 6800, which passed the House on May 15:
  • The Paycheck Protection Flexibility Act, H.R. 7010, was enacted on June 5. To learn more, see this A&B Summary of the Paycheck Protection Flexibility Act. (6/5/20)
  • Bill 3.5: Paycheck Protection Program and Health Care Enhancement Act, (R. 266) was enacted on April 24. Also available are a section-by-section summary and an overview of the health care provisions.
  • A&B detailed summaries are below:
    • A&B Summary5 Small Business Provisions
    • A&B Summary5 Health Care Enhancement Provisions
  • Bill 3.0: Coronavirus Aid, Relief, and Economic Security (CARES) Act, (R. 748) passed on March 27. A congressional section by section summary is available here.
  • A&B detailed summaries are below:
  • Congress has passed three coronavirus emergency response bills and the first two are below:
  • Bill 1.0: Coronavirus Preparedness and Response Supplemental (CPPRS) (R. 6074) passed on March 5
  • Bill 2.0: Families First Coronavirus Response Act (FFCRA) (R. 6201) passed on March 18

Transition to “Reopening”

  • State/Other Actions
    • For the latest information on state reopening decisions, see A&B 50-State Reopening tracker - updated in each A&B Coronavirus Flash. (Updated 6/22/20)
  • Administration Actions
    • The Department of Justice filed a statement of interest in Hawaii federal court in support of a lawsuit filed by Nevada and California residents who own property in Hawaii challenging Governor David Ige’s mandate of a 14-day self-quarantine for individuals entering Hawaii. (6/24/20) (New)
    • The Departments of Labor, Health and Human Services, and Treasury have jointly released FAQs on the COVID-19 testing coverage mandate provisions included in the Families First Coronavirus Response Act (FFCRA) and the Coronavirus Aid, Relief, and Economic Security (CARES) Act. The FAQs state that the mandate applies to medically appropriate COVID-19 tests and related care for symptomatic individuals and those with known or suspected exposure to an individual with COVID-19 but does not apply to “return to work” screening testing and public surveillance testing. The FAQs also address a number of other testing-related questions and provide a safe harbor for large employers with respect to certain telehealth services. (6/23/20) (New)
    • The President signed an executive order directing U.S. Embassy/Consular offices to cease issuance of H1B, H-4, H2B, J and L visas to persons who on June 24 do not have one of these valid nonimmigrant visa stamps in the their passport or other official travel documents. The order is in effect until December 31, 2020. (6/22/20) (New)
    • The CDC issued a new detailed report on its activities and initiatives that support the transition to reopening. (5/20/20)
  • The CDC updated or released guidance for reopening:

Department of Health and Human Services

  • The Department of Health and Human Services (HHS) Coronavirus toolkit page has been updated. (Updated 6/22/20)
  • HHS has a tracking feature that allows public viewing of all COVID-19 HHS grants and cooperative agreement awards on its website. The grants were distributed through programs in the ACF, ACL, ASPR, CDC, DHHS/OS, HRSA, IHS, NIH, and SAMHSA. (Updated 6/22/20)
  • The HHS Health Services and Resources Administration released a reminder to health care providers submitting a COVID-19 reimbursement claim for testing or treatment for uninsured patients, they have a step by step process. (6/24/20) (New)
  • HHS announced it was ending its funding of thirteen drive-thru testing locations (originally set up by HHS and FEMA in March) and notes information on private testing locations. (6/24/20) (New)
  • The HHS Administration on Children and Families (ACF) released information for parents and families of children with disabilities and for education staff on physical distancing. (6/24/20) (New)
  • The HHS ACF released strategies for supporting families experiencing homelessness and housing instability during COVID-19. (6/24/20) (New)
  • The HHS Office of Minority Health has announced a cooperative agreement with Morehouse School of Medicine, including a $40 million grant award to manage the initiative, to focus on effective COVID-19 outreach and communication in minority communities. (6/23/20) (New)
  • The HHS Administration on Community Living released an online tool to help socially isolated citizens connect and engage. The tool targets older adults, veterans, and people with disabilities and seeks to combat social isolation and loneliness. (6/23/20) (New)
  • The HHS Office of Biomedical Advanced Research and Development Authority (BARDA) announced it has partnered with MBio Diagnostics to develop an in vitro point-of-care serology test for the detection of human anti-SARS-CoV-2 antibodies from whole blood samples. (6/23/20) (New)
  • The National Institutes of Health has halted the clinical trial of Hydroxychloroquine to evaluate the safety and effectiveness for the treatment of adults hospitalized with COVID-19. (6/20/20) (New)
  • The HHS Assistant Secretary for Preparedness and Response released guidance on considerations for resumption of services for health care facilities. (6/19/20)

HHS/CDC/CMS/HRSA CARES Act Provider Relief Funds

  • HHS has posted a resource on Provider Relief Fund disbursements to serve as summary of the key details. (6/18/20)
  • HHS - the CARES Act Provider Relief Fund (PRF) webpage and Portal (Updated 6/24/20)
  • And the PRF FAQs (Updated 6/22/20) have been updated and capture numerous modifications.
  • The most recent FAQ additions or clarifications include: (New)
    • Time Period for Use of Funds – new FAQ
      • HHS states that it expects providers “will only use Provider Relief Fund payments for as long as they have eligible expenses or lost revenue.”
      • HHS also states that if, “at the conclusion of the pandemic, providers have leftover Provider Relief Fund money that they cannot expend on permissible expenses or losses, then they will return this money to HHS.”
    • Clarification on Eligibility for Buyers in Asset Deals – modified FAQ - In its FAQ on stock and asset deals, HHS clarifies that in circumstances when PRF money does not transfer to the buyer, the buyer will be eligible to apply for future PRF payments.
    • 340B Savings – modified FAQ - HHS clarifies that patient care revenues include “savings obtained” by 340B Program enrolled providers.
    • Safety Net Hospital Distribution – new FAQs
      • HHS states that the data used to calculate this payment were pulled from hospital cost reports on May 27, 2020.
      • In response to a question about hospitals that underwent a change in ownership, HHS states that the hospital cost report margin data were not annualized.
    • Expenses and Lost Revenues – modification - In the FAQ discussing permissible uses of PRF payments, HHS reiterates that providers may use “any reasonable method of estimating” lost revenues but specifies March and April 2020.
    • Duration of Applicability of Terms and Conditions – new FAQ - HHS notes that the T&Cs have varying applicability timeframes, with some requirements (e.g., use of funds) that apply “until the provider has exhausted these funds.” Other T&Cs apply to a longer period (e.g., maintaining all records pertaining to PRF payment expenditures for three years from the date of final expenditure).
    • Purchases vs. Asset Deals – new FAQ
      • If the transaction is a purchase of an entity (e.g., purchase of stock or membership interests) that received PRF money, the PRF recipient may continue to use the funds, regardless of its new owner.
      • If the transaction is an asset purchase (whether for some or all of the PRF recipient’s assets), the original recipient must use the funds for its eligible expenses and lost revenues and return any unused funds to HHS (i.e., the PRF money does not transfer to the buyer).
      • If a bankrupt recipient is liquidated, it must use PRF payments for eligible expenses and lost revenues and return any unused funds to HHS.
    • Medicaid Distribution – new FAQs
      • HHS reiterates that a provider eligible for the General Distribution, even if it rejected the payment, is not eligible for a Medicaid Targeted Distribution payment.
      • If a provider is enrolled in Medicaid/CHIP, but did not bill Medicaid/CHIP during the eligibility window (1/1/2018–12/31/2019), may apply for this distribution as long as the provider:
      • Was not eligible for a General Distribution payment
      • Provided diagnoses, testing, or care for individuals with possible or actual cases of COVID-19 after January 31, 2020
      • If a provider has changed tax status between the most recent tax filing and the current year, the provider should use the status that was included in the most recent tax filing when applying for PRF payments
      • Patients’ out-of-pocket costs should be reported in the commercial payer amount or whichever category is applicable; this should not be separated out into the “other” field.
      • Lost revenue estimates should include revenue from all sources “that can be attributed to COVID-19”, which may include value-based payments (e.g., quality measure achievement payments that do not account for stay-at-home orders).
      • HHS clarifies that new Medicaid/CHIP providers (i.e., those who began billing between 1/1 and 5/31/2020) are not eligible to apply. They may be eligible for future allocations.
      • HHS collected 2018 and 2019 Medicaid/CHIP provider data from state and federal sources including corporate names, TINs, and payment amounts, and is using this data to validate Portal submissions. Data is not yet available for new providers who submitted claims between 1/1 and 5/31/2020.
      • Indian healthcare providers are eligible to apply for this distribution if they meet all the eligibility criteria.
      • Health care providers that bill either FFS or managed care Medicaid/CHIP are eligible for this distribution if they otherwise meet the other eligibility criteria.
      • It appears states have asked for HHS information on providers that received funds. HHS notes that it is currently posting payment information for providers who have attested to receiving a payment from the PRF and accepted the associated T&Cs.
      • HHS notes that all providers eligible for this distribution, including dentists, should apply by the 7/20/2020 deadline.
      • HHS has not determined the methodology for the dental allocation at this time but will share additional information in the future. Dental providers should not expect that there will be an advantage by applying for funds from one distribution over another. Dentists should apply for a PRF payment in the first distribution for which they are eligible.
    • Safety Net Hospitals Distribution
      • HHS revised the FAQ on the methodology to reflect the content of the PRF webpage.
      • There will not be future adjustments to the cost reports using SSI ratios that were released after the 2018 cost reports were filed.
      • The Uncompensated Care Cost per bed is based on line 30.00 of W/S S-10.
      • The calculations for the distribution were based on total margins, not on profit.
    • HHS announced three new Provider Relief Fund allotments completing the initial $100 billion authorized by the CARES Act. (6/9/20) The three new allotments are:
    • $10 billion for safety net hospitals. HHS has posted the state-by-state breakdown. (6/9/20)
      • HHS has provided additional detail on the Safety Net definitions and data source methodology. (6/16/20)
      • HHS released additional information on the hospital safety net distribution, clarifying that HHS had extracted information from the CMS Hospital Cost Reports and Provider Specific Files to identify acute care facilities and children’s hospitals that met each of the following criteria, respectively: (6/11/20)
        • Acute Care Facilities: A Medicare Disproportionate Patient Percentage of 20.2% or greater; Annual uncompensated care of at least $25,000 per bed; and Net Operating Margin of 3.0% or less.
        • Children’s Hospitals: A Medicare Disproportionate Patient Percentage of 20.2% or greater; Net Operating Margin of 3.0% or less.
      • $10 billion for a second round funding for hot spot hospitals.
      • $15 billion for Medicaid and Children’s Health Insurance Program (CHIP) providers that participate in state Medicaid and CHIP programs and have NOT received a payment from the Provider Relief Fund General Allocation and to receive funding an application must be submitted.
      • The CDC has posted an updated dataset of provider recipient specific payment from the Provider Relief Fund general distribution high impact targeted allocation and/or rural targeted allocation. The dataset includes who has attested to receiving one or more payments and agreed to the terms and conditions as of June 22. (Updated 6/23/20)
      • The CARES Provider Relief Fund hotline is (866) 569-3522.

Centers for Disease Control and Prevention

Centers for Medicare & Medicaid Services

  • The Centers for Medicare and Medicaid Services (CMS) latest news alerts.(Updated 6/23/20)
  • For the latest COVID-19 related CMS guidance and FAQs visit the CMS Current Emergencies webpage. (Updated 6/24/20)
  • CMS has announced flexibility for clinicians participating in the Medicare Quality Payment Program (QPP) Merit-based Incentives Payment System (MIPS) due to the impact of the COVID-19 pandemic. Clinicians may submit an extreme circumstances exception application to reweight any or all of the MIPS performance categories. (6/24/20) (New)
  • CMS released preliminary Medicare COVID-19 claims data. The released included an FAQ on the data released. (6/22/20) (New)
  • CMS released an updated FAQ on COVID surveillance testing for nursing homes and other long-term care facilities. This FAQ clarifies when laboratories need a CLIA certificate and the risks of pooled sampling procedures. (6/19/20) (New)
  • CMS announced the membership of the 25 individuals to serve on the independent Coronavirus Commission on Safety and Quality in Nursing Homes. The Commission will seek an independent review and comprehensive assessment of nursing homes’ responses to COVID-19, and a report is due September 1. (6/19/20)
  • CMS announced it has instructed Medicare Administrative Contractors and notified Medicare Advantage plans to cover COVID-19 laboratory tests for nursing home residents and patients. Medicare Advantage plans must continue not to charge cost sharing or apply prior authorization or other utilization management requirements for COVID-19 tests and testing-related services. (6/19/20)
  • CMS has updated its Medicare Fee-for-Service billing FAQs. (Updated 6/19/20)

Food and Drug Administration

  • FDA provides a daily roundup on COVID-19 related actions. (Updated 6/24/20)
    • FDA updated its FAQs on Testing for SARS-CoV-2 relating to the development and performance of tests for SARS-CoV-2. (Updated 6/24/20)
    • FDA FAQs on Asymptomatic testing for COVID-19. (Updated 6/24/20)
    • FDA maintains its COVID-19 FAQs for the general public. (Updated 6/19/20)
    • FDA webpage for health professionals. (Updated 6/24/20)
    • The agency also maintains a public database of drug shortages. (Updated 6/24/20)
    • The FDA has published a new webpage on COVID-19 Educational Resources. (Updated 6/24/20)
  • The FDA and the U.S. Department of Agriculture released a joint statement on food export restrictions pertaining to COVID-19. (6/24/20) (New)
  • The FDA released a consumer update on COVID-19 and food safety. (6/23/20) (New)
  • The FDA is partnering with the Critical Path Institute (C-Path) and the National Institutes of Health’s National Center for Advancing Translational Sciences (NCATS) on the CURE Drug Repurposing Collaborative (CDRC). The CDRC is a forum for the exchange of clinical practice data to inform potential new uses of existing drugs for areas of high unmet need. The pilot project will focus on COVID-19. (6/23/20) (New)
  • The FDA has released guidance for drug and biologic industries on good manufacturing practice considerations for responding to COVID-19 infection. (6/22/20) (New)
  • The FDA issued guidance called “Effects of the COVID-19 Public Health Emergency on Formal Meetings and User Fee Applications for Medical Devices – Questions and Answers.” (6/22/20) (New)
  • The FDA posted a webpage on 3D printing and rapid response to COVID-19. (6/19/20) (New)
  • The FDA issued a letter to clinical laboratory and health care provider staff recommending they stop using COVID-19 antibody tests that are listed on the FDA’s “removed” test list. (6/19/20) (New)
  • The FDA posted a fact sheet on convalescent plasma. (6/19/20) (New)
  • The FDA advises consumers not to use any hand sanitizer manufactured by Eskbiochem. (6/19/20)

Department of Homeland Security/FEMA

  • The Department of Homeland Security (DHS) posts a weekly update of its response to COVID-19. (Updated 6/22/20)
  • The Federal Emergency Management Administration (FEMA) has cancelled the annual national test called the 2020 Integrated Public Alert & Warning System due to the ongoing pandemic response. (6/19/20)
  • FEMA announced it was phasing out Project Airbridge. Project Airbridge served as FEMA’s program to shorten medical supply distribution for key COVID-19 supplies. (6/19/20)

Small Business Administration

  • Small Business Administration (SBA) announced it had reopened the Economic Injury Disaster Loan and the Advance Program to small businesses and nonprofits. (6/15/20)
  • The SBA Paycheck Protection Program (PPP):
  • Reminder: Small businesses must apply with a lender to be eligible for PPP funding by June 30. (New)
  • The PPP borrower application form has been revised. (6/24/20) (New)
  • The PPP lender application form has been revised. (6/24/20) (New)
  • The SBA has released interim final rule on additional eligibility. (Updated 6/24/20)
  • The SBA released interim final rule revisions to the loan forgiveness interim final rule and SBA loan review procedures interim final rule. (6/22/20) (New)
  • The SBA guidance on refinancing of Economic Injury Disaster Loans (EIDL) with PPP Loan Proceeds and Lender remittance of EIDL refinance proceeds to the SBA. (6/19/20) (New)
  • The SBA, jointly with the Department of Treasury, has released a statement that they will be releasing the business names and loan range, as well as demographic and location information. The announcement noted that steps would be taken to protect personally identifiable information. (6/19/20)
  • The SBA has launched a Lender Match tool to aid small businesses and non-profits to be matched with Community Development Financial Institutions (CDFIs), Minority Depository Institutions (MDIs), Certified Development Companies (CDCs) Farm Credit System lenders, microlenders, and traditional smaller asset size lenders. (6/19/20)

Department of Treasury/IRS/Federal Reserve

  • The Department of Treasury website for CARES Act business assistance programs.
  • The Internal Revenue Service (IRS) announced rollover relief for required minimum distributions from retirement accounts that were waived under the CARES Act. (6/23/20) (New)
  • The Federal Reserve and other federal and state regulatory agencies issued guidance for assessing safety and soundness of financial institutions considering the stress and impact from the pandemic. (6/23/20) (New)
  • The IRS released Notice 2020-50 to clarify the enhanced retirement plan distributions and plan loans as authorized under the CARES Act. This includes expanding the categories of individuals eligible for these types of distributions and loans and providing guidance on how qualified individuals will reflect the tax treatment of these distributions and loans on their federal income tax filings. (6/19/20)
  • The recent IRS guidance to expand the medical condition exception, also provides a COVID-19 medical condition travel exception. A&B translates this IRS guidance to offer a better understanding of the IRS procedures and FAQs covered in the recent information. (6/16/20)

Other Agencies

  • The U.S. Department of Agriculture has awarded $86 million in rural broadband service grants in eight states. (6/24/20) (New)
  • The U.S. Department of Commerce Economic Development Administration began awarding grants to eligible county and metropolitan communities this week under the CARES Act to boost economic recovery. (6/24/20) (New)
  • The Consumer Financial Protection Bureau (CFPB) issued its interim final rule on loss mitigation options for home owners to “transition out of financial hardship” caused by COVID-19. (6/23/20) (New)
  • The Federal Communications Commission approved an additional 77 telehealth funding applications totaling $29.41 million in 44 states. (6/24/20) (New)
  • The Federal Trade Committee (FTC) and SBA sent warning letters to six companies that may be misleading small businesses seeking SBA loans as a result of the COVID-19 pandemic. The warning letters detail the claims that could lead small businesses to believe the companies are affiliated with the SBA, or that small businesses can apply on their websites for loans through the Paycheck Protection Program (PPP) or other programs authorized by the Coronavirus Aid, Relief, and Economic Security (CARES) Act. The FTC and SBA warn the letter recipients to take immediate action to remove deceptive claims, to remediate any harm to consumers, and to notify the FTC within 48 hours about the specific actions they took to address the agency’s concerns. (6/24/20) (New)
  • The FTC filed a complaint on June 16 in U.S. District Court for the Eastern District of Louisiana against a Louisiana-based company that allegedly deceived consumers with mailers that claimed to direct them on how to obtain federal COVID-19 stimulus benefits, but instead lured them to a used car sale. The mailing envelopes were labeled “IMPORTANT COVID-19 STIMULUS DOCUMENTS” and led consumers to believe they could obtain stimulus relief temporarily in person at a “relief headquarters” in Florida. When consumers showed up to the address, they only found a lot hosting a car sale. The FTC is seeking injunctive relief to stop the defendants’ actions and to require them to provide redress to their consumers. (6/16/20)
  • The U.S. Department of Housing and Urban Development (HUD) announced it was awarding $962,160 in grants to state and local fair housing organizations in nineteen states as authorized by the CARES Act. (6/24/20) (New)
  • The Department of Labor will host a webinar on coronavirus-related sick leave requirements for business owners, employers and other stakeholders. The webinar will be held on June 30, 9:30am to 10:30am CDT. (6/23/20) (New)
  • The Department of Labor developed an online tool to help employees determine eligibility for paid sick leave due to coronavirus. (6/23/20) (New)
  • The Department of Justice released a statement that a Texas man has been charged with fraudulently seeking $13 million in PPP loans. (6/24/20) (New)
  • The Department of Transportation announced it had approved a request from Sun Country for an exemption from the CARES Act airline service obligations through September 30. (6/19/20) (New)

Business Insurance Issues Related to COVID-19

  • For a 50-state review of business interruption insurance related issues see this new COVID-19 Insurance Litigation and Regulatory Issues tracker. (Weekly update 6/21/20)
  • On June 15, Lieff Cabraser Heimann & Bernstein, LLP filed a complaint on behalf of its client Atelier 1 2 3 Restaurant LLC dba Atelier Crenn against insurers Farmers Group Inc. and Truck Insurance Exchange alleging that Farmer’s Group Inc. wrongfully denied plaintiff’s claim for business interruption coverage. Plaintiff argues that the denial of coverage was “part of a premeditated strategy by Defendant to deny all claims related to the ‘shelter in place’ orders and COVID-19.”Plaintiff claims that the policies at issue provide coverage for several reasons, including because the shelter in place orders resulted in a loss of access to the insured premises necessitating a suspension of business operations. Plaintiff asserts claims for breach of contract, breach of covenant of good faith and fair dealing, unfair business practices under California’s Unfair Competition Law, and declaratory relief. The case is Atelier 1 2 3 Restaurant LLC, et al. v. Farmers Group Inc., et al., No. CGC-20-584762 (San Francisco Cnty. Sup. Ct., filed June 15, 2020).
  • On June 15, Society Insurance moved to dismiss Rising Dough, Inc.’s putative class action alleging wrongful denial of business interruption coverage. Society cited several grounds for dismissal including that the policy did not provide business income or extra expense coverage because COVID-19 did not cause “direct physical loss of or damage to covered property.” Moreover, Civil Authority coverage did not exist because Plaintiffs’ alleged losses were not caused by an order of civil authority prohibiting access to the premises on grounds of either damage to other property or a dangerous physical condition. The docket entry is Rising Dough, Inc. v. Society Insurance, No. 2:20-cv-00623-JPS (E.D. Wis.), Dkt. No. 20.

For background and the most up-to-date information, please visit the Centers for Disease Control and Prevention Coronavirus Disease 2019 website: HERE. The additional federal agency links are provided by the White House Coronavirus Task Force: What You Should Know:

Information for Businesses:

Information for Travel and Transportation:

Information for Healthcare Providers, First Responders, and Research Facilities:

Download PDF of the Flash Update

[View source.]

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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