Eligibility for a subsidized plan does disqualify it.  "Paragraph (1) shall not apply to any taxpayer for any calendar month for which the taxpayer is eligible to participate in any subsidized health plan maintained by any employer of the taxpayer or of the spouse of, or any dependent, or individual described in subparagraph (D) of paragraph (1) with respect to, the taxpayer."  

So the issue is whether "employer" means the pension payer.  That's an interesting question.