SIMERPU RESEARCH · SOURCE RECAP
26 CFR §1.105-2 — Amounts expended for medical care
SIMERPU recap and commentary: Mardy Gould
Opened — main text retrieved
Quick recap
Regulatory text addresses reimbursements of medical-care expenses, payments available irrespective of expenses, amounts exceeding expenses and related limitations.
SIMERPU’s viewpoint
This regulation is central reading when a proposal relies on medical-expense reimbursement. SIMERPU would connect its language to the actual expense, the amount paid and the conditions for payment in the proposed arrangement. That creates a concrete basis for reviewing how the program is documented and administered.
What this source contributes
The text addresses expense-based reimbursement, payments independent of expenses and amounts exceeding expenses.
What remains unanswered
The regulation does not supply a vendor’s operating facts. Those facts must be connected to its language, including the actual obligation and payment.
Mardy Gould’s take
This is where I would put the program’s transaction next to the words being relied on. Identify the expense, who incurred it, how much is paid and what creates the entitlement. An employer should be able to see that connection clearly instead of receiving a citation with no explanation of its application.
Questions I would bring to the conversation
1. What expense or obligation did the employee incur?
2. Is payment available without that expense?
3. How is the amount paid related to the amount of the expense?
Mardy Gould · Co-Founder, SIMERPU →
What would change our assessment?
Verified facts about the obligation, entitlement and amount could change the application of the regulation to a particular arrangement.
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: U.S. Treasury / IRS
Publisher: eCFR / Office of the Federal Register
Original Publication Date: Not stated — current regulation text
Read this alongside…
Each connection has a specific purpose. Compare the sources’ facts, positions and publication dates as you read.
Frequently asked questions about medical expenses related to nutrition, wellness and general health
IRS
Source position: Neutral / explanatory
Examine concrete IRS examples of medical-purpose expenses.
Read the SIMERPU recap →
26 CFR § 1.105-11 - Self-insured medical reimbursement plan
Cornell Legal Information Institute (reproduction)
Source position: Neutral / explanatory
Compare the separate framework for self-insured medical reimbursement plans.
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
See how the reimbursement language is applied in a specific IRS 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: eCFR title current through 2026-10-29
Source Type: Government — regulation / rulemaking
Model Discussed: Section 105(b) exclusion from gross income for medical care reimbursements.
Position: Neutral / explanatory
Period: Undated / current reference
Retrieved: October 31, 2026
Research and date notes
The title’s currency date is not the section’s publication or amendment 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.
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