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The Aftermath of Hobby Lobby: HSAs and HRAs as the Least Restrictive Means
Prof. Edward A. Zelinsky via SSRN 
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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