SIMERPU RESEARCH · SOURCE RECAP
Double-Dipping With Wellness Programs
SIMERPU recap and commentary: Mardy Gould
Opened — main text retrieved
Quick recap
Explains cash-reward and pre-tax premium-reimbursement issues using CCA 201622031 and Revenue Ruling 2002-3.
SIMERPU’s viewpoint
The WageWorks explanation is useful for tracing premium-reimbursement and cash-reward concerns to identified IRS materials. SIMERPU would start with those underlying authorities and then examine the arrangement being proposed. This approach helps distinguish the source of a conclusion from later descriptions of it.
What this source contributes
The explanation points readers to specific primary materials for cash-reward and premium-reimbursement concerns.
What remains unanswered
Its application to a different program still requires identifying the actual transaction and funding.
Mardy Gould’s take
I would follow the citations before relying on anyone’s shorthand explanation of double dipping. Read the original example, then ask the provider to compare it with the employer’s proposal. That allows the discussion to focus on the payment and the evidence rather than the label being used for the program.
Questions I would bring to the conversation
1. Which cited example resembles the proposal?
2. What was paid pre-tax and what was returned?
3. What facts support any claimed difference?
Mardy Gould · Co-Founder, SIMERPU →
What would change our assessment?
A verified difference in the transaction could affect the comparison; the underlying citations remain useful for understanding the concern.
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: WageWorks
Publisher: WageWorks, Inc.
Original Publication Date: Not stated
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 revenue ruling discussed in the explanation.
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
Examine the primary wellness-reward and premium-reimbursement memorandum.
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 later recurring wellness payment 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: Not stated
Source Type: Benefits consultant / administrator
Model Discussed: IRS Memorandum number 201622031
Position: Critical
Period: Undated / current reference
Retrieved: October 31, 2026
Research and date notes
URL categorizes the page under 2018, but main text does not state a publication date.
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.
SIMERP
U
™
Understand the details. Lead with confidence.
© 2026 SIMERPU.