Ann,
The HRA is what was mentioned in that IRS 2013-54 notice that put a scare in all of the employers who dropped coverage, let employees get individual coverage, and then reimbursed them one way or another for that individual coverage. $36,500 of penalty per employee per year is pretty severe.
Also appears to only be for small groups. I'd presume large groups are still going to be penalized.
You are correct, Ray. However, I didn't understand how AllenChicago felt that this was affecting his life, disability and CI sales, when the HRA applied to medical insurance.