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ACA FAQs Address HRAs, Hospital Indemnity Plans and PCORI Fees (PDF)
Buck 
[Guidance Overview] Feb. 21, 2013
"Because retiree-only HRAs are not subject to the ACA's prohibition on annual or lifetime dollar limits on EHBs, stand-alone retiree HRAs remain a permissible option for pre-and post-65 retirees. Although it appears that retirees will be able to use HRA funds to purchase coverage through an Exchange, it is not clear whether retirees enrolled in an HRA would be eligible to receive subsidized Exchange coverage. Additional guidance on these issues is needed."
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