SIMERPU RESEARCH · SOURCE RECAP
Double Dip Health Plans Marketed to Employers: Too Good to Be True
SIMERPU recap and commentary: Mardy Gould
Opened — main text retrieved
Quick recap
Criticizes plans returning large pre-tax premiums through allegedly tax-free payroll payments. Describes historical rulings, common marketing arguments and correction exposure.
SIMERPU’s viewpoint
This article is useful for recognizing premium-return patterns that have attracted criticism over time. SIMERPU would use that history to test the actual flow of money in a new proposal. A new product name or additional service should be connected to a specific explanation of how the transactions work.
What this source contributes
The historical comparison helps employers recognize a premium-return transaction even when the marketing language changes.
What remains unanswered
An employer still needs to determine whether its actual transactions match that pattern and assess the provider’s specific explanation.
Mardy Gould’s take
I would ask the provider to draw the money flow on one page. The employee’s deduction, each fee, each benefit and any payment back should all appear. If the explanation is sound, a clear diagram should help the employer understand it and reconcile it to the paycheck.
Questions I would bring to the conversation
1. Where does each deducted dollar go?
2. What is the legal basis for each payment back?
3. How do the plan documents match the illustrated flow?
Mardy Gould · Co-Founder, SIMERPU →
What would change our assessment?
A documented flow showing a materially different transaction could change the comparison. Additional benefits need their own connection to that flow.
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: Thompson Hine LLP
Original Publication Date: 2026-08-27
Read this alongside…
Each connection has a specific purpose. Compare the sources’ facts, positions and publication dates as you read.
Revenue Ruling 2002-3 — Reimbursement of pre-tax health insurance premiums
IRS
Source position: Neutral / explanatory
Read the earlier revenue ruling on reimbursement of pre-tax premiums.
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
Compare the later advice on wellness rewards and premium reimbursement.
Read the SIMERPU recap →
CCA 202323006 — Tax Treatment of Employer-Funded, Insured, Fixed-Indemnity Wellness Policy
IRS Office of Chief Counsel
Source position: Neutral / explanatory
Trace the progression to the 2023 fixed-indemnity example.
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: 2026-10-30 (page metadata)
Source Type: Law firm analysis
Model Discussed: Double dip health plans
Position: Critical
Period: Recent — 2023–2026
Retrieved: October 31, 2026
Research and date notes
Displayed article date. Page metadata says 2026-10-30; displayed date retained.
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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