"As part of the proposal, the [DOL] for the first time is 'clarifying' whether an HRA combined with private individual health insurance will be a plan subject to ERISA. It is crucial for employers that only the HRA, and not the individual insurance coverages, be considered part of an ERISA plan.... The DOL leaves unanswered significant questions and issues ... Many employers have already moved, or are seriously considering moving, to HRA-based medical coverage for retirees.... [T]he major retiree health insurance exchange providers typically fail to identify any potential issue relating to the ERISA plan status of the HRA and exchange."

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