SIMERPU RESEARCH LIBRARY

Follow the evidence.

Explore the documents behind SIMERP, WIMPER, PCMP and payroll-tax wellness claims. Read a brief SIMERPU recap, then follow the link to the original article or PDF. Research editor: Mardy Gould.

Library editor: Mardy Gould · Co-Founder, SIMERPU

137

Unique source records

123

Main texts retrieved

14

Limited or unavailable

Research snapshot: October 31, 2026. Four records have partial text or an abstract; ten are unavailable discovery records. Historical means through 2022; recent means 2023–2026. These search terms do not describe identical plan structures.

S001

CCA 202323006 — Tax Treatment of Employer-Funded, Insured, Fixed-Indemnity Wellness Policy

IRS Office of Chief Counsel

Concludes that the described pre-tax-funded policy’s wellness payments are income and employment-tax wages when employees have no related unreimbursed medical expenses. Includes the $1,200 premium / $1,000 monthly benefit example.

Recent — 2023–2026

Source position: Neutral / explanatory

Opened — main text retrieved

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Original date: 2023-06-09

S002

20 Questions about Establishing a Health & Wellness Program in the Workplace

The CPA Journal

Advocates combining participatory wellness, a cafeteria plan and medical reimbursement to fund employee benefits and generate payroll savings. Explains the authors’ interpretation of earlier IRS guidance.

Historical — through 2022

Source position: Supportive

Opened — main text retrieved

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Original date: 2021-01-27

S003

FICA Wellness & SIMERP: Tax Savings vs. Compliance Risk

OneDigital

Warns about arrangements converting salary reductions into recurring wellness cash payments. Discusses actual unreimbursed expenses, tax withholding and broader benefits compliance.

Recent — 2023–2026

Source position: Critical

Opened — main text retrieved

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Original date: 2026-08-10

S004

Is SIMERP Legal? The Definitive Guide to SIMERPs

SIMERP LLC

Vendor argues that documented service-based medical care distinguishes its SIMERP approach from fixed-indemnity cash schemes. Discusses substantiation, plan documents and the IRS memoranda.

Recent — 2023–2026

Source position: Supportive

Opened — main text retrieved

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Original date: 2025-09-23

S005

IRS Cautions Employers Again on Wellness Plans Purporting to Avoid Payroll Taxes Absent Medical Expenses

BDO USA, LLP

Explains IRS concerns about nonmedical wellness expenses and cash benefits presented as tax-free. Discusses §213(d), CCA 202323006 and potential payroll corrections.

Undated / current reference

Source position: Critical

Opened — main text retrieved

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Original date: Not stated

S006

Wellness plan schemes are addressed in IRS guidance

RSM US LLP

Reviews the 2023 CCA, proposed regulations and 2024 rulemaking. Explains why the authors regard the described wellness cash benefits as taxable wages.

Recent — 2023–2026

Source position: Critical

Opened — main text retrieved

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Original date: 2023-06-19

S007

Fixed-Indemnity Wellness Plans: The IRS Clarifies Taxation of Wellness Payments

Maynard Nexsen

Explains CCA 202323006 and the tax treatment of pre-tax-funded fixed-indemnity wellness payments when no unreimbursed medical expense supports the payment.

Recent — 2023–2026

Source position: Neutral / explanatory

Opened — main text retrieved

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Original date: 2023-07-05

S008

IRS Chief Counsel Advice Says Wellness Indemnity Payments Are Taxable If No Unreimbursed Medical Expenses Related to the Payment

Groom Law Group, Chartered

Analyzes the CCA’s $1,200 premium / $1,000 payment facts, income exclusion rules and employment taxes; connects the memo to earlier IRS advice.

Recent — 2023–2026

Source position: Critical

Opened — main text retrieved

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Original date: 2023-06-26

S009

What do we need to know when approached by vendors offering payroll tax savings programs?

WTW

Advises scrutiny of vendor programs promising large payroll savings. Reviews double-dip mechanics, 2023–2024 guidance and employer withholding exposure.

Recent — 2023–2026

Source position: Critical

Opened — main text retrieved

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Original date: 2025-05

S010

"Wellness" Doesn't Come Tax-Free: Promoters Keep Pushing Medical Indemnity Schemes Despite IRS Warnings

Steptoe

Criticizes continuing promotion of medical indemnity schemes. Examines cash payments, claimed medical-treatment distinctions, payroll taxes and promoter assurances.

Recent — 2023–2026

Source position: Critical

Opened — main text retrieved

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Original date: 2026-06

S011

What Goes Around: IRS Audits of Fixed Indemnity Health/Wellness Benefit Plans that Offer Purported Tax Savings

Morgan Lewis / ML BeneBits

Reports that the IRS has begun auditing certain fixed-indemnity health/wellness arrangements. Describes premium-return designs, disputed tax exclusions and potential employer assessments.

Recent — 2023–2026

Source position: Critical

Opened — main text retrieved

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Original date: 2026-09-29

S012

Double Dip Health Plans Marketed to Employers: Too Good to Be True

Thompson Hine LLP

Criticizes plans returning large pre-tax premiums through allegedly tax-free payroll payments. Describes historical rulings, common marketing arguments and correction exposure.

Recent — 2023–2026

Source position: Critical

Opened — main text retrieved

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Original date: 2026-08-27

S013

CCA 201622031 — Tax Treatment of Wellness Program Benefits and Employer Reimbursement of Premiums Provided Pre-tax Under a Section 125 Cafeteria Plan

IRS Office of Chief Counsel

Addresses cash rewards for wellness participation and reimbursement of premiums previously paid through §125 salary reduction. Explains why those payments are not excluded under the stated facts.

Historical — through 2022

Source position: Neutral / explanatory

Opened — main text retrieved

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Original date: 2016-05-27

S014

CCA 201703013 — Tax Treatment of Benefits Paid by Fixed-Indemnity Health Plans

IRS Office of Chief Counsel

Examines fixed-indemnity benefits under different funding situations, including employer funding and employee pre-tax salary reductions, distinguishing coverage exclusions from benefit-payment treatment.

Historical — through 2022

Source position: Neutral / explanatory

Opened — main text retrieved

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Original date: 2017-01-20

S015

CCA 201719025 — Tax Treatment of Benefits Paid by Self-Funded Health Plans

IRS Office of Chief Counsel

Analyzes self-funded arrangements whose predictable benefits exceed after-tax employee contributions. Discusses insurance risk, employer funding and inclusion in income and wages.

Historical — through 2022

Source position: Neutral / explanatory

Opened — main text retrieved

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Original date: 2017-05-12

S016

Wellness program benefits: Tax free or not?

Journal of Accountancy

Surveys 2016–2017 IRS memoranda on wellness rewards, fixed indemnity and self-funded arrangements. Identifies income and employment-tax consequences by benefit and funding design.

Historical — through 2022

Source position: Critical

Opened — main text retrieved

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Original date: 2017-10-01

S017

Be Wary of Designs to Avoid Employment Taxes Through Wellness Plan Benefits

Jackson Lewis / Benefits Law Advisor

Warns that combining wellness programs, voluntary benefits and cafeteria plans does not alone create employment-tax savings. Explains the 2016 and 2017 memoranda.

Historical — through 2022

Source position: Critical

Opened — main text retrieved

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Original date: 2017-04-18

S018

Wellness Indemnification Payments Includible in Employees' Taxable Income

Current Federal Tax Developments

Walks through CCA 202323006, separating income exclusion analysis from FICA, FUTA and withholding rules for monthly wellness indemnification payments.

Recent — 2023–2026

Source position: Neutral / explanatory

Opened — main text retrieved

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Original date: 2023-06-11

S019

The Ultimate Guide to WIMPER Programs In the Workplace

1st Capital Financial

Vendor guide explains WIMPER components, payroll illustrations, benefit choices and compliance claims. Presents employer savings and zero-net-cost employee benefits as program advantages.

Recent — 2023–2026

Source position: Promotional

Opened — main text retrieved

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Original date: 2024-09-12

S020

What is a SIMERP? A Beginner's Guide to Self-Insured Medical Expense Reimbursement Plans

Kevin A. Jerry / KAJMST

Promotes SIMERP as a way to add wellness and financial-protection benefits without changing net pay. Discusses eligibility, funding and implementation examples.

Recent — 2023–2026

Source position: Promotional

Opened — main text retrieved

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Original date: 2025-12-31

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How this library was assembled

The inventory used 49 search queries with no publication-date cutoff. Researchers opened or attempted 149 URLs and consolidated 12 alternate versions into 137 distinct source records. Sources span government agencies, law and accounting firms, benefits consultants, trade media, vendors and academic publications.

This is a documented discovery inventory, not an exhaustive statement of law or an endorsement list. Search engines, indexing gaps, inaccessible LinkedIn pages, paywalls, missing dates and partial PDF retrieval limit coverage. Access labels describe the material obtained on the retrieval date.