Notice 2017-20 provides transition relief for new Small Business HRAs

 With the understanding that some employers may find it difficult to comply with the notice requirement absent additional guidance, the agency has decided to provide businesses with additional time to furnish this initial document to eligible employees. Therefore, those offering a Qualified Small Employer HRA (QSEHRA) are not required to distribute such communication/notification until after further guidance has been issued by Treasury.

Note: Employers that supply the QSEHRA notice to their employees in the interim, may rely upon a reasonable good faith interpretation of the statute without penalty.

See https://www.irs.gov/pub/irs-drop/n-17-20.pdf