HRAs May Cause Retirees to be Ineligible for Exchange Subsidies

The IRS has clarified that a retiree covered by a standalone health reimbursement arrangement (?Ç£HRA?Ç¥) will not be eligible for a premium tax credit under the Affordable Care Act to purchase coverage through an exchange.?á The HRA would constitute ?Ç£minimum essential coverage?Ç¥ for any month in which there is an available amount in the HRA, even after the employer has stopped contributing to the HRA. IRS Notice 2013-54 can be found here.