Thank you everyone! I think I finally have it figured out. After the HRA participant becomes vested, the plan releases the funds to them via a VEBA and it is at that point that the funds become property of the participant and can be divided as equitable distribution pursuant to a divorce.
This particular plan does allow for these accounts to be divided (weird, I know), and I found a few others online that do as well. It's for the benefit of the former spouse and not the child, so a QMCSO would not be appropriate.
I have received an inquiry regarding drafting a QDRO for a health reimbursement account (HRA), which is covered by ERISA, but can't find any resources for this online. Has anyone come across this before?