SIMERPU RESEARCH · SOURCE RECAP
Too Good to Be True? Risks of Indemnity and Wellness Program Schemes
SIMERPU recap and commentary: Mardy Gould
Opened — main text retrieved
Quick recap
Traces premium-return and wellness-payment arrangements through IRS guidance. Explains risks and cautions against relying on marketing promises of tax-free cash.
SIMERPU’s viewpoint
This history of premium-return and wellness-payment arrangements helps readers compare current pitches with recurring concerns. SIMERPU would use the article to identify the transaction requiring explanation, then ask for the proposal-specific response. The value lies in understanding the reasoning behind the criticism and the evidence offered to address it.
What this source contributes
The article traces recurring concerns through identifiable IRS guidance rather than relying only on the appeal of a savings promise.
What remains unanswered
A particular provider’s response and operating facts need to be evaluated alongside the criticism.
Mardy Gould’s take
I would ask a provider to respond to the strongest part of this argument. Identify the transaction being criticized, show whether it exists in the proposed program and explain any difference. That gives an employer a substantive comparison and preserves room to consider the employee benefits on their own merits.
Questions I would bring to the conversation
1. Which recurring transaction concerns the authors?
2. Does the current proposal use that transaction?
3. What evidence supports a different conclusion?
Mardy Gould · Co-Founder, SIMERPU →
What would change our assessment?
A fact-specific response supported by program records could change the comparison; a general rebuttal would leave the underlying issue open.
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: Katrina Veldkamp
Publisher: Journal of Pension Benefits; Boutwell Fay reprint
Original Publication Date: Spring 2026
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
Start with the historical revenue ruling on returned 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
Follow the later wellness-reward and premium-reimbursement discussion.
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
Compare the 2023 fixed-indemnity facts with the article’s historical account.
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: Reposted 2026-07-30
Source Type: Professional accounting / benefits publication
Model Discussed: Double dipping tax avoidance schemes involving wellness payments
Position: Critical
Period: Recent — 2023–2026
Retrieved: October 31, 2026
Research and date notes
Original: Spring 2026, vol. 33, no. 3, pp. 60–62. Repost counted as the same article.
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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