Most health reimbursement arrangements and some health care flexible spending accounts will be subject to this fee, according to Sterling. HRAs that are tied to a self-funded medical plan or are limited purpose (dental and vision expense reimbursement only) are not subject to the fee. The FSA plans have some special conditions that may make them subject to the fee, especially if the employer is making contributions to employee FSAs. There are also different allowable methods for calculating the plan's "average number of lives."

Also, according to SHRM, while PPACA allows parents to add their adult children (up to age 26) to their health plans, the IRS has not changed its definition of a dependent for health savings accounts. This means that an employee whose 24-year-old child is covered on their HSA-qualified high-deductible health plan is not eligible to use HSA funds to pay for medical bills for that 24-year-old.

If account holders can't claim a child as a dependent on their tax returns, then they can't spend HSA dollars on services provided to that child. According to the IRS definition, a dependent is a qualifying child (daughter, son, stepchild, sibling or stepsibling or any descendant of these) who:

• Has same principal place of abode as the covered employee for more than one-half of taxable year.

• Has not provided over one-half of their own support during taxable year.

• Is not yet age 19 (or not yet age 24 if a student) at the end of the tax year, or is permanently and totally disabled.

In addition, except for preventive care, which is generally covered at 100 percent and is not subject to the deductible, consumers in an HSA-qualified plan may be on the hook for the entire cost of medical care, including doctor visits, medications, tests and treatments, until they reach their deductible, according to NPR. (They'll be charged the negotiated rate their insurer has agreed to pay providers for services, however, not the "rack" rate paid by the uninsured.)

Regular high-deductible plans, on the other hand, offer many more options. In addition to covering preventive care at 100 percent, some function like traditional plans, requiring only a copayment for doctor visits and medicines even before the deductible is met. Or they may offer a limited number of doctor visits with a copayment before people meet their deductible, says Carrie McLean, senior manager of customer care at eHealthInsurance.com, an online vendor.

Consumers need to evaluate the full spectrum of costs and benefits for HSA plans, but the advantages may have nothing to do with medical expenses. "The true benefit you get from these accounts is because you're putting money away and you get that tax savings." 

Additionally, some changes are arbitrary and time-consuming, unwise and unfair. "Requiring prescriptions for aspirin or a doctor's visit for hay-fever is not health care reform, it's government overreach and interference," per Nebraska Senator Mike Johanns. "Families with children who have special needs are among those who rely heavily upon these accounts and they shouldn't be punished."

So, the very product designed to help consumers is getting hacked away bit by bit just so someone can recoup the cost of overwhelmingly horrific national health care legislation, punitive in many ways to consumers and businesses?

Yes, there are a few good things about PPACA, but this is not one of them. HSAs are a good thing, but be careful when you decide to put one in place.

Do your homework to make sure it meets your health care and financial needs. Health care reform should have been more thoroughly thought out than what it has become, but unfortunately hindsight was not foresight. Do your best to make it work for you.