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Health Reimbursement Accounts Under the ACA (PDF)
Chao & Company, Ltd. 
[Guidance Overview] Feb. 6, 2013
"[A] Stand-Alone HRA that covers active employees and provides any EHB is subject to the PHS Section 2711 no limits requirement. For all practical purposes, employers that have been offering Stand-Alone HRAs will abandon such arrangements since it is unlikely that any employer will grant an employee unlimited coverage for any EHB under an HRA."
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