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.
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S041
Double Dip Tax
HUB International
Historical warning about wellness banks and similar arrangements promising free benefits and increased take-home pay. Discusses circular premium reimbursements and earlier IRS guidance.
Historical — through 2022
Source position: Critical
Opened — main text retrieved
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Original date: 2020-06-09
S042
Double-Dip Wellness Plans Abound Despite Clear Compliance Issues
Moreton & Company
Warns that wellness and indemnity programs promising tax savings may fail IRS requirements. Describes double-tax-benefit claims and possible employer/employee consequences.
Recent — 2023–2026
Source position: Critical
Opened — main text retrieved
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Original date: 2026-07-29
S043
IRS Warns Employers To Beware Of The "Double Dip"
American Fidelity
Insurer explanation contrasts questionable tax-saving wellness pitches with compliant benefit designs. Warns about premium-return payments and later tax liabilities.
Recent — 2023–2026
Source position: Critical
Opened — main text retrieved
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Original date: 2023-11-14
S044
Watch out for fraudulent health plan tax avoidance schemes
Aflac
Alston & Bird authors describe classic and newer wellness tax-avoidance pitches, historical enforcement and the distinction between coverage and cash-payment tax treatment.
Undated / current reference
Source position: Critical
Opened — main text retrieved
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Original date: Not stated
S045
No Risk at All
Leader’s Edge
Critiques health-screening indemnity policies marketed to convert wages into non-taxable benefits. Discusses employer, employee and broker exposure.
Recent — 2023–2026
Source position: Critical
Opened — main text retrieved
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Original date: 2023-03-01
S046
Too Good to Be True? Risks of Indemnity and Wellness Program Schemes
Journal of Pension Benefits; Boutwell Fay reprint
Traces premium-return and wellness-payment arrangements through IRS guidance. Explains risks and cautions against relying on marketing promises of tax-free cash.
Recent — 2023–2026
Source position: Critical
Opened — main text retrieved
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Original date: Spring 2026
S047
Wellness Tax Schemes
Apex Benefits
Describes high pre-tax premium and wellness-payment mechanics, criticizing the claimed net-pay and payroll-tax results. Links to a separate PDF version.
Recent — 2023–2026
Source position: Critical
Opened — main text retrieved
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Original date: 2026-09-09
S048
Double-Dipping With Wellness Programs
WageWorks, Inc.
Explains cash-reward and pre-tax premium-reimbursement issues using CCA 201622031 and Revenue Ruling 2002-3.
Undated / current reference
Source position: Critical
Opened — main text retrieved
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Original date: Not stated
S050
IRS alert: Beware of companies misrepresenting nutrition, wellness and general health expenses as medical care for FSAs, HSAs, HRAs and MSAs
IRS
Warns against treating general nutrition, wellness and health purchases as medical expenses for tax-favored spending accounts. Includes an example involving a general-health food claim.
Recent — 2023–2026
Source position: Neutral / explanatory
Opened — main text retrieved
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Original date: 2024-03-06
S051
Frequently asked questions about medical expenses related to nutrition, wellness and general health
IRS
Explains when exams, therapy, nutritional counseling, weight-loss programs and similar costs qualify as medical expenses. Distinguishes disease treatment from general health purposes.
Recent — 2023–2026
Source position: Neutral / explanatory
Opened — main text retrieved
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Original date: 2023-03-17 (FAQ additions)
S052
Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage
Federal Register
The tax-related preamble leaves proposed §1.105-2 amendments unfinalized and says that decision should not imply acceptance of exclusion claims. Discusses continuing compliance concerns.
Recent — 2023–2026
Source position: Neutral / explanatory
Opened — main text retrieved
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Original date: 2024-04-03
S053
Proposed Rules on Short-Term, Limited-Duration Insurance and Fixed Indemnity Excepted Benefits Coverage
Federal Register
Proposes changes addressing fixed benefit payments and medical-expense substantiation under §1.105-2. Retrieved pages also explain pre-tax versus after-tax premium funding.
Recent — 2023–2026
Source position: Neutral / explanatory
Partial PDF — first 40 of 63 pages
Read the available-source note →
Original date: 2023-07-12
S054
United States v. Carmelo Zanfei et al.
United States District Court for the Northern District of Illinois
Historical enforcement decision examines premium-reimbursement and Healthier Plan arrangements, medical-expense substantiation and tax representations made by promoters.
Historical — through 2022
Source position: Critical
Opened — main text retrieved
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Original date: 2006-09-29
S055
Wellness and the Tax Law
Georgia Law Review
Examines tax subsidies for medical care and the boundary with general wellness. Evaluates competing reform approaches, including broader wellness coverage, narrower subsidies and a restructured subsidy; does not validate SIMERP payroll arrangements.
Recent — 2023–2026
Source position: Neutral / explanatory
Opened — full 75-page journal PDF retrieved
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Original date: 2025
S056
Regulatory and Tax Issues for Worksite Wellness Programs
American Journal of Health Promotion
The abstract reviews legislation, HIPAA and regulatory issues for workplace wellness programs, including tax implications of incentive rewards and program expenditures.
Historical — through 2022
Source position: Neutral / explanatory
Abstract only — PubMed; Ovid full text restricted
Read the available-source note →
Original date: 2007-05/06
S057
Employee Wellness Plans: Some Benefits May Be Taxable
The Tax Adviser
Analyzes why the CCA’s fixed-indemnity wellness payments fall within gross income and employment-tax wages rather than the claimed benefit exclusions.
Recent — 2023–2026
Source position: Critical
Opened — main text retrieved
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Original date: 2023-11-01
S058
Wellness Program Benefits and Employer Reimbursements Under Sec. 125 Cafeteria Plan
The Tax Adviser
Explains cash wellness rewards and reimbursement of pre-tax premiums under the 2016 CCA. Distinguishes excluded coverage from taxable benefits and incentives.
Historical — through 2022
Source position: Critical
Opened — main text retrieved
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Original date: 2016-11-01
S059
Beware of tax promoters purporting to save employment taxes on health plans
The Tax Adviser
Examines marketed wellness and health plans, risk-shifting and unexpectedly large benefits relative to contributions. Discusses tax reporting and correction considerations.
Historical — through 2022
Source position: Critical
Opened — main text retrieved
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Original date: 2017-09-21
S060
IRS Opines on the Tax Treatment of Employer-Funded, Insured, Fixed-Indemnity Wellness Policies
McDermott Will & Emery (article as published)
Explains CCA 202323006’s rejection of the described tax treatment and connects it to earlier double-dipping arrangements.
Recent — 2023–2026
Source position: Critical
Opened — main text retrieved
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Original date: 2023-06-27
S061
Health Compass — White Pages and Compliance Review
Health Compass Inc.; chamber-hosted PDF
Vendor internal review defends combining a participatory self-funded accident/health plan with a §105(b) HRA. Discusses cited tax provisions and claimed distinctions from fixed indemnity.
Undated / current reference
Source position: Supportive
Opened — main text retrieved
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Original date: Not stated
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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.
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