I know HRAs can reimburse medical insurance premiums as defined under Section 213(d)(1)(D). But if the premium is paid pre-tax, would it be excluded from reimbursement?

Thanks.

It is my understanding, that pre-tax premiums are considered employeR paid, therefore since the employeE didn't pay anything, there would be nothing to reimburse. So any payment made would then be taxable income.

See here:
http://www.ebia.com/weekly/articles/2001/C...1227Double.html