"ECFC believes that any cap of the employer exclusion is bad for employees and will result in employers curtailing the maintenance of consumer-directed health accounts, particularly those accounts funded through employee salary deductions through a cafeteria plan.... [T]he enhanced Child Tax Credit could work in concert with the dependent care assistance FSAs to provide assistance in financing child care expenses for all working Americans.... While delay of the effective date of the Cadillac Tax is helpful in the short run, delay will only slow the trend of employers eliminating or curtailing employee contributions to FSA and HSA; only complete repeal of the Cadillac Tax or the exemption of employee contributions from the calculation of the tax will stop this trend."

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