- We have no ability to change co-pays or deductibles or we will not be grandfathered into the "Cadillac Plan" tax exemption. If we do tweak a co-pay by even $5, we will be set the company up for the 40% tax.
- Many of our employees fully use the current $5,000 Health Savings Account benefit; this is reduced to $2,500 starting next year, increasing their personal tax liability.
Some points:
- The excise tax is more than seven years down the road.
- The point of the excise tax itself is not dissimilar from the aim of the consumer-driven health care movement that backs HSAs coupled with high-deductible plans: shifting away from overly comprehensive (er, "Cadillac") coverage and relying on greater cost-sharing (e.g. higher deductibles) to mold people into more cost-conscious health consumers. If you're relying on high-deductible plans but still contributing enough (>$27,500) to your HDHP to eventually be subject to the excise tax, you're quite possibly doing it wrong.
- How much you can change your co-pay while still maintaining grandfathered status depends on the value of the co-pay. You can change it by up to the greater of 1) $5 +($5 * the rate of medical inflation), or 2) a percentage change of 15% + the rate of medical inflation. For a small co-pay, obviously the former is going to be the larger number and you'll only be able to increase the co-pay by five dollars and some change. But if you're looking at a larger co-pay you can raise it by 15% + 3.4% (assuming that's roughly what medical inflation for the relevant period will be) = 18.4%. So for a $100 copay, it could be raised by as much as $18.40 without the plan losing its grandfathered status.
- As already noted, the amounts for HSAs in 2011 are unchanged from 2010.