"This guidance essentially puts an end to stand-alone HRAs and to health FSAs offered outside of a cafeteria plan. Although an HRA with fewer than two participants who are current employees on the first day of the plan year (i.e., retiree-only HRA) is an excepted benefit and exempt from the ACA market reforms, retiree-participants are not left unscathed. The Notice confirms that a stand-alone HRA reimbursing retirees for the purchase of individual health insurance coverage would still be considered minimum essential coverage."  MORE >>