And one more “gut feel” thing if you don’t mind.
In the absence of a positive test, which will not apply if someone is not positive or even if the test is unavailable to that person (asymptomatic or mild), then it is necessary to experience adverse financial consequences.
Most people will experience one of the listed events, such as work hour reduction or even fewer hours for an independent contractor. I realize the adminsitartor “may” rely on the participant representaion, but what do you think will actually happen when an entity such as Fidelity/Vanguard…and so on gets a contribution outside of the 60 days that the participant represents is a return of the Corona distribution? Will they accept that representation? If not, then what?
I assume further guidance will be out shortly but there seems a need to have some type of protection beyond the administrator “may” treat it as qualified. These people often seems very clerical in their approach. And also quite sure they understand the rules best.