"[Notice 2015-17] clarifies several aspects concerning the scope of IRS Notice 2013-54. First, the IRS makes clear in this guidance that an employer's payment of Medicare Part B and/or D premiums is an impermissible employer payment plan except as provided in the Notice. Second, by excluding more traditional HRAs (i.e., HRAs that reimburse expenses other than premiums) from the transition relief, the IRS makes it clear that the Notice 2013-54 prohibitions apply to all arrangements that pay for or reimburse individual market health premiums. Many had previously taken an erroneous position that HRAs that reimburse solely individual market premiums were allowable under the prior Notice. Presumably, the limited transition relief is an acknowledgment of the confusion on this issue."