Steps Plan Sponsors Should Take to Implement the Families First Act and the Cares Act

The Families First Coronavirus Response Act (Families First Act or FFCRA) and the Coronavirus Aid, Relief, an Economic Security (CARES) Act have brought a wide range of changes to employee benefit plans, including changes to health care coverage, retirement plans and leave policies.

In a recent International Foundation webcast, Andrew D. Sherman, senior vice president, national director, public sector at Segal and Melanie L. Walker, senior vice president, national compliance practice at Segal provided an in-depth look at the law’s impact on benefit plans.

Steps Plan Sponsors Should Take to Implement the Families First Act and the Cares Act

To help plan sponsors navigate implementation of the new laws, Sherman and Walker provide a helpful breakdown of the steps plan sponsors can take.

Steps to Address the Health Provisions of the Families First Act and CARES Act


  • Notify your participants of benefit plan changes, such as the required coverage for COVID-19 or expanded services in telehealth.
  • Consider covering COVID-19 treatment with no cost sharing. While testing must be covered with no cost-sharing, many carriers are also covering COVID-19 treatment services in full.
  • Communicate more about other existing benefits. Remind your employees of your EAP or other behavioral health services.
Open Enrollment Virtual Conference


  • Consider additional changes to other benefits programs. Should you cover more telehealth? Are there additional well-being benefits you would like to add?
  • Review your vendor contracts.
  • Start initial planning for returning to work.

In the Future

  • Amend the plan documents as you make plan changes.
  • Look at data analytics and how your benefits have changed.
  • Plan now for modifications to your open enrollment process if it is occurring in the summer or fall.

Steps to Address the Leave Provisions of the Families First Act


  • Post the Families First Act notice. Be sure to use the prescribed methods for posting remotely.
  • Contact your disability and leave administrators to coordinate the leave required by the Families First Act with the leave provisions you already provide.
  • Develop procedures for employees to request leave and to get the documentation you need.
  • Review applicable state or local leave laws to get up to speed on what your state law requires.


  • Explore paid leave donation and share programs if you have employees who need additional leave.
  • Project the impact on short-term disability coverage based on how your needs have changed.

In the Future

  • Review paid and unpaid leave policies to ensure that they are consistent with state and federal law and meet your new needs as an employer.

[Upcoming Webcast: Best Practices in Virtual Multiemployer Trust Fund Meetings| May 12, 2020]

Steps to Address the Retirement Provisions Under the CARES Act


  • The CARES Act provisions only apply through the end of the year, so you need to make quick decisions on which, if any, you want to enact.
  • Work with your vendors and administrators to determine what they can offer in customized programming.
  • Communicate with your participants about whatever you decide to offer.


  • Once you have made your decisions, implement plan changes as quickly as possible.
  • Monitor the actions your participants are taking so that you have an idea of their needs.
  • Consider the CARES Act’s tax-advantaged student loan repayment provisions.

In the Future

  • Amend your plan to reflect whatever changes you adopt.
  • Consider providing additional benefit offerings on financial literacy.

[Upcoming Webcast: Pension Trustees and Effective Governance of Climate-Related Risks | May 14, 2020]

Coronavirus Resources

Learn More About the Families First Act and the CARES Act

Tune in to the on-demand webcast Public Sector Plan Response to COVID-19. It’s available free to International Foundation and ISCEBS members. Find more resources for plan sponsors on the Foundation’s Coronavirus (COVID-19) Resources page.

Brenda Hofmann
Communications Manager at the International Foundation

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Communications Manager at the International Foundation

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Benefits-Related Topics That Grab Her Attention: Wellness, work/life balance, retirement security, parental leave policies and unique and trending perks.​

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