SIMERPU RESEARCH · SOURCE RECAP
CCA 202323006 — Tax Treatment of Employer-Funded, Insured, Fixed-Indemnity Wellness Policy
SIMERPU recap and commentary: Mardy Gould
Opened — main text retrieved
Quick recap
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.
SIMERPU’s viewpoint
This memorandum makes the payment mechanics central to the discussion. SIMERPU’s approach is to distinguish the purchase of coverage, the delivery of care and a cash benefit, then compare the actual proposal with the memo’s facts. A claimed difference deserves a documented explanation of why it changes the analysis.
What this source contributes
The memo separates coverage premiums from later cash benefits and examines the payment itself. That distinction makes an employer’s transaction easier to test.
What remains unanswered
The memo addresses stated facts, not a named current proposal. A different design needs a documented comparison of funding, entitlement and reimbursed expenses.
Mardy Gould’s take
The first thing I want to see is one employee’s complete transaction. Start with the deduction, identify the benefit and explain the final payment. A provider who says its design is different should be able to show exactly where the difference sits and why the employee’s records support it.
Questions I would bring to the conversation
1. What triggers the payment?
2. What expense remains after other coverage pays?
3. Which documented fact distinguishes this proposal from the memo?
Mardy Gould · Co-Founder, SIMERPU →
What would change our assessment?
A documented difference in the expense, entitlement or funding could change the comparison. A different product name would not establish that difference.
Read the original source
The original author and publisher are credited below. Continue to their article, document or source page for the complete context.
Original Author: Laura Warshawsky; Lynne Camillo
Publisher: IRS Office of Chief Counsel
Original Publication Date: 2023-06-09
Read this alongside…
Each connection has a specific purpose. Compare the sources’ facts, positions and publication dates as you read.
CCA 201703013 — Tax Treatment of Benefits Paid by Fixed-Indemnity Health Plans
IRS Office of Chief Counsel
Source position: Neutral / explanatory
Compare the earlier memo’s funding scenarios with the 2023 payment example.
Read the SIMERPU recap →
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
Source position: Neutral / explanatory
Separate wellness rewards and premium refunds from the later fixed-indemnity discussion.
Read the SIMERPU recap →
26 CFR §1.105-2 — Amounts expended for medical care
eCFR / Office of the Federal Register
Source position: Neutral / explanatory
Read the reimbursement regulation behind the memo’s expense analysis.
Read the SIMERPU recap →
Keep learning with SIMERPU
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About this source
Original Updated Date: Not stated
Source Type: Government — nonprecedential tax memorandum
Model Discussed: Employer-funded / §125-funded fixed indemnity wellness policy
Position: Neutral / explanatory
Period: Recent — 2023–2026
Retrieved: October 31, 2026
Research and date notes
Release date; memorandum dated 2023-05-09. Nonprecedential Chief Counsel Advice; addresses stated facts.
Each record identifies the material retrieved. SIMERPU’s viewpoint and Mardy Gould’s take are editorial commentary; the source-position label describes the original source’s stance. Read the original and its qualifications when evaluating a particular arrangement.
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