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I'm confused by the recently proposed excepted benefit HRA that would allow an HRA to reimburse dental/vision premiums and other ACA exempt benefits if eligible employees are also offered group health plan coverage. 

https://www.federalregister.gov/documents/2018/10/29/2018-23183/health-reimbursement-arrangements-and-other-account-based-group-health-plans

I thought current rules already allow for a limited scope HRA that reimburses dental/vision expenses only (including premiums) as long as they are not an "integral part of a group health plan" or they are provided "under a separate policy, certificate, or contract of insurance" (such as an individual dental/vision policy)? What am I missing?

Treas. Reg. §54.9831-1(c)(3)(i); DOL Reg. §2590.732(c)(3)(i). (special rules relating to group health plans)

See Amendments to Excepted Benefits, 26 CFR Part 54, 29 CFR Part 2590, 45 CFR Part 146, 79 Fed. Reg. 59130, 59132 (Oct. 1, 2014)

Treas. Reg. §54.9831-1(c)(3)(ii)

DOL Reg. §2590.732(c)(3)(ii)

HHS Reg. §146.145(b)(3)(ii).

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