"The [IRS] continues to struggle with the question of how the [ACA] affects various arrangements through which employers attempt to pay premiums for employees to purchase health insurance coverage in the individual market.... On February 18, 2015, it released yet another guidance on this issue, this one focused on small employers.... The agencies have taken the position that employer payment plans are group health plans, and thus must comply with the ACA's market reforms. A group health plan must under these reforms cover at least preventive care and may not have annual dollar limits. A premium payment-only HRA or other payment arrangement that simply pays employee premiums does not comply with these requirements. An employer that offers such an arrangement, therefore, is subject to a fine of $100 per employee per day."