"In a notable Q&A from last year, ... the IRS emphasized that employer payment plans were subject to $100/day excise taxes, which could total $36,500 per year, per employee. The Departments acknowledge in Notice 2015-17 that some employers who have offered health coverage through an employer payment plan may need additional time to adopt an alternative ... However, the transition relief window provided under the Notice (that is, through June 2015) is relatively short."