SIMERPU RESEARCH · SOURCE RECAP

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

SIMERPU recap and commentary: Mardy Gould

Opened — main text retrieved

Quick recap

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

SIMERPU’s viewpoint

BDO’s discussion highlights the importance of defining the expense underlying a claimed tax-free benefit. For SIMERPU, that question belongs early in program design, alongside the value of the services employees receive. A legal explanation is most useful when it addresses the actual payment process and documentation.

What this source contributes

BDO centers the underlying medical expense and raises the practical possibility of payroll corrections, connecting design questions to administration.

What remains unanswered

The discussion does not supply the documents for a particular employer. It also leaves a provider’s specific service-based explanation to be examined on its facts.

Mardy Gould’s take

I want an employer to be able to answer a basic question: what are we reimbursing? If that answer requires several disconnected presentations, the explanation needs work. Employees can receive valuable services, and employers should understand the separate reasoning supporting the payment treatment before building it into payroll.

Questions I would bring to the conversation

1. Whose expense is being reimbursed?

2. How is the amount determined for each employee?

3. What happens in a period with no corresponding expense?

Mardy Gould · Co-Founder, SIMERPU →

What would change our assessment?

A complete expense and reimbursement record could resolve factual uncertainty. The claimed financial result alone would not answer BDO’s concern.

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: Not stated

Publisher: BDO USA, LLP

Original Publication Date: Not stated

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About this source

Original Updated Date: Not stated

Source Type: Accounting firm / tax analysis

Model Discussed: Wellness cash benefits / fixed indemnity; §213(d) expense boundary

Position: Critical

Period: Undated / current reference

Retrieved: October 31, 2026

Research and date notes

A publication date could not be verified in retrieved main text or metadata. Cites IR-2024-65; that is not an article publication date.

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.