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
Read this alongside…
Each connection has a specific purpose. Compare the sources’ facts, positions and publication dates as you read.
CCA 202323006 — Tax Treatment of Employer-Funded, Insured, Fixed-Indemnity Wellness Policy
IRS Office of Chief Counsel
Source position: Neutral / explanatory
Read the fixed-indemnity memo discussed in the professional analysis.
Read the SIMERPU recap →
CCA 201703013 — Tax Treatment of Benefits Paid by Fixed-Indemnity Health Plans
IRS Office of Chief Counsel
Source position: Neutral / explanatory
Compare how contribution funding affects the earlier IRS examples.
Read the SIMERPU recap →
Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage
Federal Register
Source position: Neutral / explanatory
Place the discussion alongside the 2024 rulemaking’s tax-related preamble.
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: 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.
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