While FSA participation is likely to flatten or decrease, HSA participation is almost certain to explode. There are several reasons, but the main one is cost: HSA-compatible plans will probably be the lowest-priced option that will meet the new “bronze-level” minimum essential coverage requirements – they will help both individuals and employers avoid the penalties that begin in 2014.

These plans have grown exponentially for the last several years, and health reform will only accelerate this process.  Where HSAs – and, in fact, any account for which employees use debit cards to access funds – will suffer is in the amount they earn on “interchange.” Interchange is the per-swipe fee that banks and large TPAs earn when a customer uses their debit card, and the Dodd-Frank Bill, passed earlier this year, drastically cuts the interchange rate for debit card purchases.

Like HSAs, HRAs also could be a health reform winner. Front-end HRAs with a rollover feature can serve as great training wheels for an HSA – paternalistic employers who want to ease their employees into a consumer-driven plan might want to try this approach. Other employers will use a back-end HRA to reimburse a portion of the deductible for their employees.

This strategy will become much more common as insurance costs continue to rise – it will allow employers to save on premium and self-fund a portion of their deductible without jumping into the deep end and going totally self-funded.  Speaking of self-funding, those TPAs that provide this service to their clients also should see their business grow. Most experts agree a growing number of employers will choose to self-insure their health plans as a way to control premiums and avoid some of the requirements of the ACA.

TPAs with large COBRA blocks could see a significant decrease in billable clients as most employees will opt for a guaranteed-issue, government-subsidized individual plan through the exchange. On the other hand, if the notice requirements remain the same, there's no good reason an employer would want to begin taking on this responsibility, especially at a time when there are a lot of new administrative burdens to deal with already.

And these new requirements might be the ultimate silver lining for TPAs. Third party administrators exist because the government requires a lot of paperwork brokers aren't equipped to do and employers don't want to do. And these responsibilities aren't going to go away with health reform; on the contrary, employers will be responsible for completing more reports and issuing more notices than ever before.

This is a bad time to be an HR manager, which means it's a good time to be a TPA. Complexity is the friend of third party administrators, and any time the government gets involved, things definitely get more complex.

Sharon Alt-Bonnett is co-founder of Alt Bentley-Yates and can be reached at [email protected].