If there is one provision in the health care reform law for which there should be bipartisan agreement on repeal, it is the one that will impose a stiff excise tax on health care premiums that exceed statutory limits. Specifically, starting in 2018, a 40% excise tax, widely known as the “Cadillac tax”, will be slapped on group health care premiums that exceed $10,200 for single coverage and $27,500 for family coverage.

In the case of fully insured plans, the tax will be paid by insurers, while plan administrators will pay the tax for employers with self-funded plans. Ultimately, insurers and TPAs will pass the cost of the tax onto employers in the form of higher premiums and fees.

One justification for the tax has been that it will encourage employers to redesign their health care plans to better control costs to avoid, or at least delay, being hit with the tax.

To that we say: nonsense. Employers have all the incentives they need — chiefly the need to earn a profit and stay competitive — to design their health care plans to keep cost increases under control.

Indeed, it was the spiraling health care costs of a decade ago, not the threat of a federal excise tax, that led to the revolution in plan design that is helping employers keep the lid on cost increases.

A key part of that revolution is the employer move to consumer-driven health care plans, whose key feature is greater participant cost-sharing through higher deductibles and coinsurance requirements.

There is no question that CDHPs have made employees better consumers of health care services by, for example, moving them away from brand-name prescription drugs to less costly but identical generics, or going to urgent care centers rather than expensive hospital emergency rooms.

But aside from being unnecessary, we feel an excise tax is inherently unfair. Health care premiums vary enormously, reflecting, among other things, regional costs of living. Should an employer be exposed to the tax simply because it is based in a region where costs are above average? We think not.

Finally, we shudder at the complexity of the rules that would be needed to enforce the excise tax. An IRS request just for comments totaled two dozen pages. We fear regulations on the excise tax would be many times that.

For all those reasons, we hope lawmakers move quickly to junk the tax.