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The Aftermath of Hobby Lobby: HSAs and HRAs as the Least Restrictive Means
Prof. Edward A. Zelinsky via SSRN Link to more items from this source
Mar. 2, 2015
"An HSA or HRA permits the covered employee to spend employer-provided, pre-tax health care dollars on any medical service the employee chooses without implicating the employer in the employee's spending decision. The HSA/HRA alternative respects the religious rights of sponsoring employers since, unlike conventional insurance or self-insured health plans, the sponsoring employer's plan does not provide a menu of choices which frames the employees' decisions."

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