"Employees covered by [an] HRA must be enrolled in an individual policy. Employees who cease to be covered by the individual policy must forfeit the HRA.... [E]mployers may permit employees to use the section 125 cafeteria plan to contribute on a pre-tax basis for non-exchange individual market coverage.... Employees must have the option to opt-out of the HRA coverage to maintain eligibility for subsidies on the exchange ... The HRA must have reasonable procedures in place to verify that anyone covered by the HRA is actually enrolled in individual health insurance coverage.... The proposed regulations also provide a new mechanism for employers to offer an HRA of up to $1,800 in value that is not integrated with individual market (or any other) coverage.... The proposed regulations would continue to treat an HRA as an 'eligible employer-sponsored plan' to qualify as minimum essential coverage[.]"