CARES Act Administrative Q&As—Government Plans

The CARES Act didn’t specifically address longer-term issues that have arisen in the wake of the COVID-19 outbreak. Below we address government plans.

These FAQs were updated as of July 1, 2020. A print version is available here.

GP1: How does the CARES Act apply to governmental or non-ERISA church plans?

A: The following provisions of the CARES Act apply to governmental and non-ERISA church plans (but please note that the required amendment date may be different for governmental plans):

• The distribution and loan provisions under Section 2202
• The waiver of the required minimum distributions under Section 2203

Note: The provision for the DOL to extend the deadline for plan notices (Section 3607) would not apply because these plans are not subject to ERISA.

Note: The provision regarding Single Plan Funding relief is not applicable to governmental and non-ERISA church plans because they are not subject to minimum funding requirements.