SIMERPU RESEARCH · SOURCE RECAP
Be Wary of Designs to Avoid Employment Taxes Through Wellness Plan Benefits
SIMERPU recap and commentary: Mardy Gould
Opened — main text retrieved
Quick recap
Warns that combining wellness programs, voluntary benefits and cafeteria plans does not alone create employment-tax savings. Explains the 2016 and 2017 memoranda.
SIMERPU’s viewpoint
Jackson Lewis draws attention to the interaction among the components of a wellness arrangement. SIMERPU’s view is that an employer needs to understand how those components work together, including the basis for each payment. Familiar tax-code references become useful when connected to a complete transaction description.
What this source contributes
The article encourages readers to examine how familiar benefit components work together instead of assuming their combination settles the payment treatment.
What remains unanswered
The operational links among a particular cafeteria plan, services and reimbursements still need to be demonstrated.
Mardy Gould’s take
An employer should not have to assemble the program explanation from four different presentations. I would ask for one account that connects the election, services, reimbursement and optional benefits. Each specialist can contribute, but the final explanation should be coherent enough for the employer to understand who does what.
Questions I would bring to the conversation
1. How do the plan components interact?
2. Which document governs the payment being questioned?
3. Who verifies that payroll follows that document?
Mardy Gould · Co-Founder, SIMERPU →
What would change our assessment?
A reconciled set of governing documents and actual procedures would make it possible to assess the interaction the article questions.
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: Keith A. Dropkin
Publisher: Jackson Lewis / Benefits Law Advisor
Original Publication Date: 2017-04-18
Read this alongside…
Each connection has a specific purpose. Compare the sources’ facts, positions and publication dates as you read.
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
Review the early advice on rewards and premium reimbursements.
Read the SIMERPU recap →
Frequently asked questions about medical expenses related to nutrition, wellness and general health
IRS
Source position: Neutral / explanatory
Distinguish qualifying medical expenses from broad wellness descriptions.
Read the SIMERPU recap →
What do we need to know when approached by vendors offering payroll tax savings programs?
WTW
Source position: Critical
Compare the article’s concerns with a practical employer review agenda.
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: Law firm analysis
Model Discussed: Wellness Plan Benefits and Tax Treatment
Position: Critical
Period: Historical — through 2022
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.
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