Some consultants feel that some plans may hang back to see what the demand level is from their employees before they adopt CV distributions or expanded plan loans. They are also free to adopt a more restrictive version than the CARES Act allows, eg not accepting rollbacks after the due date the extensions for 2020.
But once they agree for the first employee, they must then amend the plan by the deadline to do that. CARES allows employers and IRA Custodians to accept an employee certification of eligibility without requesting further documentation, and there is little chance that the IRS will request documentation.
I agree that the IRS needs to release further guidance ASAP, even if they will have to amend that guidance after the next relief bill.