One view (I'm hoping) is that as a US-Flag carrier, flying to or from the US, they'd be subject to the rule.
I've posted the text of the new law in another thread here on USAirways and also in Flyer Buzz. No distinction about foreign or domestic flights in the law, nor is there one regarding paid vs. award tickets.
One catch may be that the language applies to a "route" which may mean that if you're flying LGW-PHL direct another carrier is only required to consider sarrying you if they have a direct LGW-PHL flight.
OTOH, USAirways bailed out Midway passengers because they have service to all Midway cities.
There is a section of the DOT website that shows what accommodation has been offered to passengers for each US airline suspension since PanAm.