An ICHRA, now also called a CHOICE Arrangement, needs a notice at least 90 days before the plan year. For a January 1, 2027 start, that date has passed.
The federal government began calling the individual coverage HRA a CHOICE Arrangement in September 2026. The rules did not change. Employees generally need written notice at least 90 days before the plan year starts, so the start date you pick decides when the notice has to go out.
The notice deadline for each 2027 start date.
January 1 Start Needed Notice by October 3
A calendar-year start for 2027 needed the notice by October 3, 2026, which has passed. If notice did not go out, choose a later start date.
February 1 Start Needs Notice by November 3
A February 1, 2027 start leaves a short window. The notice must reach employees by November 3, 2026.
March 1 Start Needs Notice by December 1
A March 1, 2027 start gives you until December 1, 2026 and leaves time to build the allowance by class.
April 1 Start Needs Notice by January 1
An April 1, 2027 start puts the deadline at January 1, 2027, which lets you finish the class design and budget first.
May 1 Start Needs Notice by January 31
A May 1, 2027 start moves the deadline to January 31, 2027 and avoids the year end rush.
July 1 Start Needs Notice by April 2
A July 1, 2027 start gives the most planning room, with notice due by April 2, 2027.
The timing issues that catch employers.
Employees Who Become Eligible Later
New hires and employees who move into an eligible class later generally get the notice by the date they become eligible. Set a written process.
The Individual Plan Has a Deadline Too
A newly offered ICHRA can open a special enrollment period, generally 60 days before the start date. Marketplace coverage must start no later than the ICHRA start date.
Marketplace Dates Can Differ by State
HealthCare.gov and state exchanges set their own enrollment deadlines. Check the current dates for each state where your employees live before you pick a start date.
The Notice Has Required Content
The notice covers the allowance, who is covered, the start and end dates and how it affects premium tax credits. Federal agencies publish a model notice.
Same Rules Under Either Name
CHOICE Arrangement is the new federal name for the ICHRA. Carrier and vendor materials may use either, and the compliance rules are the same.
Class Design Comes First
The allowance and class rules must be settled before the notice goes out, because the notice states the amount.
What to settle before picking a start date.
Has a notice already gone out?
If one did, the start date is set. If not, move the start date.
Which start date leaves time to design classes?
Classes and allowances must be final before the notice.
Who is hired or promoted mid year?
Write the process for later eligible employees.
What are the marketplace deadlines for our states?
Check current dates for every state where employees live.
Who helps employees buy a plan?
Plan enrollment support before the notice goes out.
Is the group plan still the better answer?
Compare the two before you decide.
The questions employers ask about ICHRA notice deadlines.
How early does the ICHRA notice have to go out?
Employees generally need written notice at least 90 days before the plan year begins. For a January 1, 2027 start, that date was October 3, 2026.
Is an ICHRA the same as a CHOICE Arrangement?
Yes. CMS and the Small Business Administration announced the CHOICE Arrangement name in September 2026. The arrangement and its rules are the same.
What if we missed the deadline for January 1?
Choose a later start date and count 90 days back from it. An April 1, 2027 start puts the deadline at January 1, 2027.
What about employees hired after the plan year starts?
They generally need the notice by the date they become eligible. Put the process in writing.
Can employees buy an individual plan outside open enrollment?
A newly offered ICHRA can open a special enrollment period, generally 60 days before the start date. Confirm the current rules on HealthCare.gov.
Do the state exchange deadlines matter?
Yes. State exchanges can set their own deadlines, so check each state where employees live before you pick a start date.
What else do we need to send?
Other compliance notices may still apply. See our employee notices page and open enrollment checklist.
General information about individual coverage HRAs, not legal or tax advice. Plan-specific questions belong with ERISA counsel and your tax advisor, and we will bring them in.
Where these details come from.
This page summarizes public guidance reviewed in October 2026. Rules change, so confirm current requirements with counsel.
CMS: Individual Coverage HRAs →
U.S. Department of Labor: Employee Benefits Security Administration →
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