If our business must plan layoffs due to events associated with COVID-19, are we responsible for compliance with the NH WARN Act (Worker Adjustment and Retraining Notification)?

Under ordinary circumstances, some employers have NH WARN Act responsibilities, but RSA 275-F:4 provides exceptions to these. Specifically, at RSA 275-F:4 I (b) and (d) there are exceptions which would relax the requirement. The NH Labor Commissioner has authority to determine the application of exceptions, and has expressed the view that COVID-19 is clearly an emergent, exceptional event.