A member is wondering how you are interesting the ARPA final rule in terms of premium pay. Here is their inquiry: I've been asked whether the City can provide premium pay to a broad range of employees who have not yet received any hazard pay (police officers and firefighters have already received such pay from the state). As I read the rule, to meet the criteria for premium pay, one must be an "eligible" employee (and that includes all municipal employees), must perform "essential" work, which excludes remote work, and such essential work must be performed during the health emergency (which is ongoing). Some of our employees worked in-person since March 2020. Some of our employees worked remotely for some or all of the period of March 2020 to June 2021. All of our employees have been in person since June 2021 (interacting with citizens and co-workers, etc.). Would you read the rules to mean that all of their employees qualified for the premium pay assuming they otherwise meet the wage requirements? The concern is around the fact that some had been working remotely but have now been in person since June 2021. Please feel free to send me your responses at akarras@imla.org<mailto:akarras@imla.org> and I'll pass them along or you can respond to the list as others may be interested in your responses as well. Thanks, Amanda Amanda Kellar Karras Executive Director / General Counsel P: (202) 466-5424 x7116 Email: akarras@imla.org [facebook icon]<https://www.facebook.com/InternationalMunicipalLawyersAssociation/>[twitter icon]<https://twitter.com/imlalegal>[linkedin icon]<https://www.linkedin.com/company/international-municipal-lawyers-association-inc./> [logo]<https://imla.org/> 51 Monroe St. Suite 404 Rockville, MD, 20850 www.imla.org<http://www.imla.org/> Plan Ahead! IMLA's Mid-Year Seminar, April 8-11, 2022 in Washington DC! IMLA's 87th Annual Conference<https://imla.org/annual-conference/>, Oct. 19-23, 2022 in Portland, OR!