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America’s New COVID-19 Relief Package — Unpacked

Client Alert
March 23, 2021

On March 11, 2021, President Biden signed the highly anticipated American Rescue Plan Act (the “Act”) into law, a $1.9 trillion COVID-19 relief bill aimed at addressing and resolving many of the lingering questions and concerns following the expiration of the Families First Coronavirus Response Act (“FFCRA”) on December 31, 2020.

Among the most notable provisions of the Act include the following:

FFCRA Tax Credit Extension | While employers are no longer mandated to provide paid sick leave to covered employees under the FFCRA, the Act grants an extension to the government tax credit previously provided to employers under the FFCRA if an employer elects to continue such paid time off to its employees. This tax credit remains available through September 2021 for employers with fewer than 500 employees. In addition, the Act now gives paid family leave for 12 weeks, instead of 10 weeks, ultimately providing an employee 14 weeks of paid leave when including the paid sick leave. Finally, the Act resets an employee’s FFCRA availability beginning on April 1, 2021. Meaning, any FFCRA time used before April 1, 2021 will not count against the employee’s leave entitlement after April 1, 2021.

COBRA Coverage | Also through September 2021, the federal government will subsidize the entirety of COBRA premiums for employees (and their covered family members) facing layoffs, ensuring health insurance coverage despite COVID unemployment concerns.

Unemployment Benefits | Prior to the passage of the Act, the weekly $300 unemployment supplement was set to expire in mid-March; however, now, these supplemental payments have been extended through September 6, 2021 — the first $10,200 of which will be tax-free for households earning up to $150,000. The Act additionally provides new protections for self-employed workers otherwise uncovered by state benefits.

Based on the changes to the FFCRA and the increased availability of vaccines, we recommend that clients consider revoking their FFCRA leave policies to avoid renewed employee eligibility for paid leave, including increased paid family leave for 12 weeks. If employers continue to provide paid leave under the FFCRA, they will remain eligible for payroll tax credits, up to the permitted maximums, for eligible leave time, through September 30, 2021.

As businesses across the country witnessed firsthand last year, federal and state legislation related to the COVID-19 pandemic is ever-evolving and requires a watchful eye to remain in the know. For more information on any of the above-provisions or for any questions related to the American Rescue Plan Act, please contact BMD Labor and Employment Partner Bryan Meek at bmeek@bmdllc.com or 330.253.5586.

Thank you to Monica Andress for her assistance drafting this Client Alert.

Labor and Employment LawBryan MeekAmerican Rescue PlanCOVID-19
Client Alert

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July 13, 2026USCIS has temporarily extended Employment Authorization Documents (EADs) for certain Temporary Protected Status (TPS) beneficiaries from Haiti and several other countries following recent court action. Employers and TPS recipients should review EAD expiration dates, monitor ongoing developments, and ensure compliance with Form I-9 and E-Verify requirements.Client Alert

HHS Accessibility Requirements for Medical Diagnostic Equipment: What Health Care Providers Need to Know

July 8, 2026Health care providers that receive federal financial assistance are now subject to updated HHS accessibility requirements for medical diagnostic equipment under Section 504 of the Rehabilitation Act. With the July 8, 2026, compliance deadline in effect, covered providers should ensure they have the required accessible equipment, train staff, and review operational practices to reduce compliance risk and provide accessible care for patients with disabilities.Client Alert

Florida Super Lawyers® Recognizes Brennan Manna Diamond Attorneys to the 2026 Lists

June 26, 2026BRENNAN, MANNA & DIAMOND is proud to announce that three of our attorneys have been designated to the 2026 Florida Super Lawyers® and Florida Rising Stars® lists. Super Lawyers is based on multiple categories of independent research and peer evaluation to identify outstanding lawyers.Client Alert

Supreme Court Clears Path for TPS Terminations: What Employers Need to Know

June 25, 2026The U.S. Supreme Court's June 25, 2026 decision in Mullin v. Doe and Trump v. Miot removed legal obstacles that had delayed the termination of Temporary Protected Status (TPS) for Haiti and Syria. The ruling also reinforces the administration's authority to terminate other TPS designations currently under review. Employers should immediately identify workers whose employment authorization is tied to affected TPS programs, review Form I-9 records, and prepare for forthcoming USCIS guidance before taking any employment action.Client Alert

The Risks of Outsourcing Medical Billing and the Importance of State-Law Compliance

June 24, 2026Offshoring medical billing and other administrative functions can reduce costs, but it also raises significant compliance, operational, and contractual risks. Although HIPAA does not explicitly prohibit protected health information from being accessed or stored outside the United States, healthcare providers and their vendors remain responsible for safeguarding patient information and complying with state-specific restrictions that may limit or prohibit offshore subcontracting.
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