The IRS releases Information Letter 2016-0019 providing additional guidance on employer reimbursement of Individual Health Insurance premiums.

Document Excerpt

If the employer does not offer the employee a group Health plan and the employee obtains other coverage, such as when the employee is covered by an Individual Health insurance policy, the separate arrangement cannot be combined with that other coverage to determine if it satisfies the market reform rules for group health plans. Consequently, the arrangement to reimburse the individual health policy premiums would violate the market reforms.

Link

https://www.irs.gov/pub/irs-wd/16-0019.pdf