SIMERPU · INDUSTRY INTELLIGENCE

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Industry Intelligence

If you have been in this industry more than a year, you have heard someone say the IRS tried to kill wellness reimbursement plans in 2023 and failed. I want to walk through what actually happened, because the version most of us carry around is wrong, and the wrong version is now a liability in at least two states.

By Mardy Gould

October 2026

Public article

Original SIMERPU analysis is educational—not government guidance, program approval, or legal or tax advice. Read the sources and involve qualified advisers when a question requires professional judgment.

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