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.