Late yesterday, the Internal Revenue Service issued its second lengthy notice (2015-52) containing initial guidance on the ACA’s 40% high cost plan excise tax a/k/a the Cadillac plan tax.  Timothy Jost from Health Affairs kindly prepared a summary of the notice here. A reader provided a link to a Huffington Post article on the tax which points out that

The bottom line is, as structured, this tax will significantly impact most workers, employers, and health plans. Even the Federal Employees Health Benefits Program (FEHB) will be negatively impacted. In a recent study, the FEHBP Blue Cross Blue Shield standard option plan was projected to hit the 40% tax in 2019 for employee-only coverage, and in 2025 for family coverage.

You can find a link to the referenced study on this American Benefits Council webpage.  The burden of administering this tax will fall on all employers.

Last Sunday, the Washington Post editorialized in favor of the 40% tax explaining that the tax is “a crucial reform” because it curbs the income tax exclusion for employer sponsored health benefits that “distorts the economy in multiple ways.”  If Congress wanted to curb that exclusion, then it should have done so directly rather than by creating this fiendishly complex indirect mechanism.  In the Wall Street Journal today, columnist Peggy Noonan perceptively observed

An untold story right now is that everyone was “right” about health care. The Republicans were right that ObamaCare would not and will never work. Democrats—though they haven’t noticed because they’re so busy clinging to and defending ObamaCare—were right that America would support national health care, but not as they devised it. We’ll get out of ObamaCare by expanding Medicare. Most of America, after the trauma of the past five years, won’t mind.

The FEHBlog is not crazy about this prediction about the next stage but you can’t rule it out.