SIMERPU RESEARCH · SOURCE RECAP
20 Questions about Establishing a Health & Wellness Program in the Workplace
SIMERPU recap and commentary: Mardy Gould
Opened — main text retrieved
Quick recap
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.
SIMERPU’s viewpoint
The CPA Journal article offers a useful account of the reasoning behind WIMPER designs and their intended employee benefits. Its educational value increases when readers place the 2021 analysis alongside later guidance and the documents for a current proposal. The article supplies a framework for discussion; implementation still needs its own support.
What this source contributes
The twenty-question format makes the supportive WIMPER argument accessible and connects the intended benefit offering to its proposed funding structure.
What remains unanswered
The original analysis predates the 2023 memo. A reprint date does not explain how a present proposal addresses subsequent guidance or actual administration.
Mardy Gould’s take
There is value in giving this argument a fair reading. Employers deserve to understand why proponents believe the structure works. I would keep the twenty questions and add a practical test: can the provider answer them using today’s plan documents and an employee’s actual payroll illustration, including every fee?
Questions I would bring to the conversation
1. Which assumptions in the 2021 article still describe this proposal?
2. How does the provider address later IRS guidance?
3. What records connect the employee’s payment to the claimed reimbursement?
Mardy Gould · Co-Founder, SIMERPU →
What would change our assessment?
An updated, fact-specific explanation addressing later guidance and implementation records would make the article more useful for a current decision.
Continue with SIMERPU’s review
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: Peter Karl; Dominick G. Mondi
Publisher: The CPA Journal
Original Publication Date: 2021-01-27
Read this alongside…
Each connection has a specific purpose. Compare the sources’ facts, positions and publication dates as you read.
26 CFR §1.105-2 — Amounts expended for medical care
eCFR / Office of the Federal Register
Source position: Neutral / explanatory
Compare the authors’ reimbursement interpretation with the underlying regulatory text.
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
Read the earlier IRS advice discussed in the supportive argument.
Read the SIMERPU recap →
FICA Wellness & SIMERP: Tax Savings vs. Compliance Risk
OneDigital
Source position: Critical
Use a critical employer-focused assessment to test the article’s assumptions.
Read the SIMERPU recap →
Keep learning with SIMERPU
Build your understanding with learning resources, the free Professional Roadmap and our approach to reviewing sources.
About this source
Original Updated Date: 2024-09-30 (page metadata)
Source Type: Professional accounting / benefits publication
Model Discussed: WIMPER: §125 + §106 wellness + §105 SIMRP
Position: Supportive
Period: Historical — through 2022
Retrieved: October 31, 2026
Research and date notes
Original 2021 article retained. November 27, 2024 ICYMI reprint is the same work; reproduced inside multiple vendor packets. Alternate version/host: https://www.cpajournal.com/2024/11/27/icymi-20-questions-about-establishing-a-health-wellness-program-in-the-workplace/
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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