Tracking the Excise Tax Impact on High-Value Health Plans

‘What if?’ scenarios can help avoid worst-case situations

By Joanne Sammer October 15, 2014
Update: The Affordable Care Act’s 40 percent excise tax on high-value health plans is now slated to take effect beginning in 2020. The levy—popularly known as the “Cadillac tax”— received a reprieve provided by the Consolidated Appropriations of 2016, enacted in December 2015.

On Jan. 1, 2020, U.S. employers will face a nondeductible 40 percent excise tax on high-cost health plans (popularly known as the Cadillac tax). Despite the length of time before the tax takes effect, it has garnered more than its share of attention.

“Even though, the excise tax is the last part of the Affordable Care Act that employers have to comply with, it is the No. 1 concern and has been for some time,” said Tracy Watts, national health care reform leader with Mercer. The question is, when do employers have to translate this concern about the tax into concrete actions?

The 40 percent will be levied on the value of health insurance benefits above a certain amount—$10,200 for single coverage and $27,500 for family coverage, indexed annually for inflation. The levy is expected to particularly hit hard plans that are costly because they are tailored for employees in high-risk professions or for employers with a large proportion of older employees. Self-insured employers will have to pay the tax themselves. Insurance carriers will pay the tax on behalf of employers with fully insured plans. However, carriers almost certainly will pass along the cost of the tax to employers.

Questions Remain: ‘What If?’

Although the tax is on companies’ radar screens, “few employers have taken a close look at it and rarely have those employers taken any action as a result,” said Tim Nimmer, chief health actuary with Aon Hewitt. “A lot of that has to do with the fact that there are still several unknowns; we do not have a comprehensive set of rules to work with.” (Conflicting views over which health benefits are likely to be included in the excise tax calculation are discussed in the SHRM Online article Big Employers Foresee Excise Tax Hit.)

Until guidance is forthcoming, employers will have to settle for calculating any projected tax based on various scenarios. A baseline calculation might focus solely on the types of coverage almost certain to be included in excise tax calculations, like major medical coverage. From there, employers can include the value of more types of benefits to generate some “What if?” scenarios.

For example, this calculation can answer questions such as: What if the guidance includes employer and employee contributions to flexible spending accounts (FSAs) and health savings accounts (HSAs), or the value of care provided by onsite medical clinics? By including every benefit that could reasonably be included in the calculation, employers can develop a sense of what a worst-case scenario might look like.

If employers do not have the tools to run these analyses themselves, they can ask a broker, plan administrator or consultant for help. There are also free calculators available online that can do basic calculations based on current costs and benefits. The Alliance has one such calculator.

When and how to take action using this information will depend on an organization’s circumstances. In some cases, employers in highly competitive industries like technology may find themselves with few options if they want to be able to attract and retain highly skilled workers with a rich benefit program. “Those industries are looking at this much more closely because the excise tax could have a more dramatic impact on those plans,” said Nimmer. Such companies may simply have to pay the tax to remain competitive, unless they find new ways to enhance their total rewards offering.

Tracking the Cost Trend

No matter what benefits are ultimately included in the tax calculation, how quickly an employer could reach the tax thresholds will largely depend on that employer’s benefit costs trend. The more health benefit costs increase each year, the faster and more likely it is that the employer could reach the tax thresholds in subsequent years.

“Much of this depends upon size,” said Mark Bagnall, president of Bagnall Co. in Phoenix. “The larger the employer, the easier it is to track and project.” He suggested that employers use their current cost trend rate to project when and if their health plans will be subject to the excise tax. “It is a good idea to use benchmarking to consider future plan design changes that can mediate any trend increases,” he said.

Use your plan’s current cost trend rate to project when and if it will be subject to the excise tax.

In the current climate, health care cost trend rates themselves can be wild cards, with many employers seeing historically low cost increases. Since it is difficult for an employer to project whether those lows will continue for the next three years, it makes sense to project future excise tax exposure using a few trend rate scenarios. This will give employers a sense of when the trend rate becomes high enough to increase the risk of hitting the tax threshold.

Using all of this information, the employer can rethink and recalculate its risk each year. This is a key point to remember. With so many variables at play, an employer is unlikely to get a definitive yes or no answer to the excise tax question right now. Rather, the focus in 2015 will be to gauge risk and to determine whether the risk is large enough a) to keep tracking, and b) to take action and if so, when and what kind.

Actions to Take, and When

The actions an employer can take to avoid the excise tax will depend on what counts as a benefit for the purpose of calculating the tax. HSAs could be an important tool to help employers neutralize any health plan design changes. For example, employers could shift to a higher deductible health plan to reduce the cost of the plan, then make up for that change by increasing HSA contributions. However, if HSA contributions are included in the tax calculation, that strategy will not solve the problem.

If an employer expects current health benefits to reach the tax threshold, it may want to start making changes over time to make them less jarring to employees. For example, employers can:

  • Introduce consumer-directed high-deductible health plans, which tend to have a lower cost trend than other types of plans, as an option for employees. Once employees get used to those plans, employers can then move to full replacement—that is, making a high-deductible plan the only option for employees to choose.
  • Index deductibles and out-of-pocket maximums to increase every year with inflation. “This creates the expectation among employees that these parts of the plan are going to go up every year,” said Watts.

Whatever employers decide to do, the important thing is to start thinking about the tax and what to do to avoid it. “Having this conversation now rather than when they are under time pressure when the law takes effect is the most prudent action any employers can take,” said Nimmer.

Steps to Minimize Excise Tax Exposure

According to October 2014 findings from an Aon Hewitt pulse survey of 317 U.S. employers, 40 percent expect the excise tax to affect at least one of their current health plans and 14 percent expect it to immediately impact the majority of their current health benefit plans. Of those employers that have determined the impact, 62 percent say they are making significant changes to their health plans, including:

  • Reducing the richness of their plan designs through higher out-of-pocket costs (33 percent of respondents), including 10 percent that say they will eliminate high-cost, rich design options.
  • Increasing the use of wellness incentives in their plans (31 percent).
  • Evaluating private exchange options for pre- and post-65 retirees (14 percent), while 7 percent are considering private exchanges for active employees.
  • Significantly reducing spousal eligibility or subsidies through mandates or surcharges (14 percent).
  • Implementing narrow/high-performance provider networks (5 percent).

Looking Ahead

Due to medical costs expected to rise more rapidly than the tax thresholds in the future, 68 percent of the surveyed employers expect the excise tax to affect at least one or the majority of their current health plans by 2023. When asked about future actions they are likely to consider in order to minimize their exposure to the tax, the vast majority (79 percent) expect to reduce plan design richness through higher out-of-pocket member share. More than 40 percent of employers say they are likely or highly likely to adopt cost control strategies, such as reference-based pricing and narrow provider networks.

Other strategies employers are likely or highly likely to consider include:

  • Restructuring coverage tiers to align with tax threshold ratios (37 percent).
  • Limiting FSA, HSA and/or health reimbursement arrangement (HRA) contributions counted against thresholds (31 percent).
  • Limiting buy-up options for employees (26 percent).
  • Moving to a private health exchange (16 percent).

Joanne Sammer is a New Jersey-based business and financial writer.

Related Resource


Job Finder

Find an HR Job Near You
Search Jobs


Find the Right Vendor for Your HR Needs

SHRM’s HR Vendor Directory contains over 10,000 companies

Search & Connect

HR Daily Newsletter

News, trends and analysis, as well as breaking news alerts, to help HR professionals do their jobs better each business day.