The ever moving target of understanding the implications (good or bad) of the Affordable Care Act mandates has apparently moved again, as the Internal Revenue Service (IRS) last week announced yet another delay in its implementation.  Under the regulations, employers that offered health reimbursement arrangements (HRAs) for employees buying individual health insurance policies could have been subject to excise taxes of $100 per day per employee!  In a new notice, the IRS said small businesses with fewer than 50 employees with HRAs would not be subject to the excise taxes until July 1, 2015.  HRAs do not comply with the mandates of the Affordable Care Act.