SIMERPU RESEARCH · SOURCE RECAP

CCA 201622031 — Tax Treatment of Wellness Program Benefits and Employer Reimbursement of Premiums Provided Pre-tax Under a Section 125 Cafeteria Plan

SIMERPU recap and commentary: Mardy Gould

Opened — main text retrieved

Quick recap

Addresses cash rewards for wellness participation and reimbursement of premiums previously paid through §125 salary reduction. Explains why those payments are not excluded under the stated facts.

SIMERPU’s viewpoint

The memorandum is an important historical reference for two distinct issues: wellness participation rewards and reimbursement of premiums paid pre-tax. SIMERPU would keep those transactions separate when reviewing a proposal. Understanding which issue is present makes the subsequent discussion of medical care and payroll treatment more precise.

What this source contributes

The memo treats participation rewards and reimbursement of pre-tax premiums as distinct questions, a useful starting point for classifying payments.

What remains unanswered

Its historical examples do not supply the facts of a current proposal. Readers need to identify which, if either, of the transactions is present.

Mardy Gould’s take

Before debating a label, I would ask what the employee is being paid for. Is it participation, a returned premium or an identified expense? That answer shapes the rest of the conversation. I want the employer and the employee to hear the same explanation of what the payment represents.

Questions I would bring to the conversation

1. What event or expense creates the payment entitlement?

2. Was the premium already paid with pre-tax dollars?

3. How is a medical reimbursement distinguished from a participation reward?

Mardy Gould · Co-Founder, SIMERPU →

What would change our assessment?

A documented change in what the payment reimburses could affect the comparison; calling the same payment a different benefit would not establish 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: Stephen Tackney

Publisher: IRS Office of Chief Counsel

Original Publication Date: 2016-05-27

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Source Type: Government — nonprecedential tax memorandum

Model Discussed: Cash wellness rewards; reimbursement of pre-tax premiums

Position: Neutral / explanatory

Period: Historical — through 2022

Retrieved: October 31, 2026

Research and date notes

Release date; memorandum dated 2016-04-14. Nonprecedential advice addressing particular arrangements.

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.