SIMERPU RESEARCH · SOURCE RECAP

Fixed-Indemnity Wellness Plans: The IRS Clarifies Taxation of Wellness Payments

SIMERPU recap and commentary: Mardy Gould

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Quick recap

Explains CCA 202323006 and the tax treatment of pre-tax-funded fixed-indemnity wellness payments when no unreimbursed medical expense supports the payment.

SIMERPU’s viewpoint

This explanation of CCA 202323006 provides a focused starting point for understanding the fixed-indemnity payment issue. SIMERPU would use it to identify the facts that drive the conclusion, especially funding and unreimbursed expenses, before comparing another arrangement. That preserves the usefulness of the warning without losing the importance of plan design.

What this source contributes

The focused explanation highlights unreimbursed expenses and pre-tax funding, helping readers identify the facts behind the memo’s conclusion.

What remains unanswered

Readers still need the actual policy and reimbursement procedures to determine how the explanation relates to a different arrangement.

Mardy Gould’s take

I would use this as a short briefing before discussing a provider’s design. The key is to make the comparison concrete: what generates the payment, what expense supports it and what other coverage has already paid? Once those answers are visible, the conversation becomes easier for the employer to follow.

Questions I would bring to the conversation

1. Is payment tied to a particular expense?

2. How is payment by another plan accounted for?

3. What policy provision establishes the employee’s entitlement?

Mardy Gould · Co-Founder, SIMERPU →

What would change our assessment?

A different payment entitlement supported by the actual documents could alter the comparison. A general wellness benefit description would not settle it.

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: Kate Belyayeva

Publisher: Maynard Nexsen

Original Publication Date: 2023-07-05

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About this source

Original Updated Date: Not stated

Source Type: Law firm analysis

Model Discussed: Fixed-indemnity wellness plans

Position: Neutral / explanatory

Period: Recent — 2023–2026

Retrieved: October 31, 2026

Research and date notes

No additional retrieval note.

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.