As Proposed, Tax on Cadillac Plans May Be A Non-Starter

"The main take-away message is that you can't put in a flat dollar amount," Dobson says. What's smarter and fairer is to figure out an actuarial value that would have to be risk adjusted."

Plans covering a group of employees who are predominantly younger, say a group of 30-year-old males, cost about $155 a month, or less than $2,000 per year. But for a plan covering employees who are largely 60-year-old females, the per member per month cost is $717, or $8,604, which comes close to exceeding the ceiling currently under discussion.

And there also is the question of occupational risk. Certain professions have higher utilization of the medical system than others, for example, firefighters or coal-miners. "Does this reform risk penalizing those in higher-risk professions?" Dobson asks.

Dobson says that current hikes in these thresholds, which were intended to be responsive to some concerns about fairness, don't go far enough to resolve the problems.

Dobson asks if the reform proposals under discussion "install both a ceiling and a floor without leaving room to even stand up? . . . It is certainly not out of the question for situations to arise where the ceiling for a given employer group could be lower than one or more of the prescribed floors."