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HRA Plans and the Prohibition on Annual Limits
Wolters Kluwer Law & Business / ftwilliam.com 
[Guidance Overview] Jan. 27, 2013
"This set of FAQs clarifies the certain 'integrated' Health Reimbursement Arrangements (HRAs) are not subject to the health care reform prohibition on annual limits -- HRAs that are 'integrated' with other coverage as part of a group health plan. An HRA that is not integrated with group health plan coverage is subject to the health care reform prohibition on annual limits unless certain exemptions apply. The guidance, however, does not discuss these other exemptions available to HRAs (small carve out of HRAs that are not subject to HIPAA Portability and the exemption for FSAs)."
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