Final rules released by the Departments of Labor, Health and Human Services and Treasury on June 13, 2019 have the potential to transform how employers pay for health care coverage for employees. The rules permit the use of a new type of health plan called an individual coverage health reimbursement arrangement (“ICHRA”). Under an ICHRA, the employer provides an amount that can be used by the workers to pay for all or some of health coverage obtained in the individual market. These plans will presumably be utilized by employers that want to offer a health benefit to employees without maintaining a full (major medical) group health plan. However, an important notice deadline is approaching. Employers that want to adopt an ICHRA for 2020 (effective January 1, 2020) must provide a notice to employees by no later than October 3, 2019. The new ICHRA guidance is complex and includes rules related to enrollment, classes of employees, opting out, substantiation of expenses and the annual notice requirement described above. Given the short time frame to analyze whether to proceed under the new rules, work out the details and issue the required notice, many employers may take a wait and see approach and defer this decision to the 2021 plan year or beyond. Early adopters, however, need to act soon if this is on their agenda for 2020.