SIMERPU RESEARCH · SOURCE RECAP
26 CFR § 1.105-11 - Self-insured medical reimbursement plan
SIMERPU recap and commentary: Mardy Gould
Opened — main text retrieved
Quick recap
Regulatory text defines self-insured medical reimbursement plans and explains nondiscrimination, highly compensated individuals, plan benefits and tax consequences.
SIMERPU’s viewpoint
The regulation provides a useful foundation for understanding self-insured medical reimbursement plans and nondiscrimination issues. SIMERPU would distinguish that general framework from the additional claims made for a particular wellness program. A familiar plan category is a starting point for explaining the specific design.
What this source contributes
The reproduced regulation provides a starting point for plan definition and nondiscrimination questions.
What remains unanswered
Recognizing a plan category does not establish the treatment of every payment or the operation of a marketed bundle.
Mardy Gould’s take
I would use this to help an employer distinguish the underlying plan from the product name. Then ask how eligibility, benefits and administration actually work. The category matters, but the employer still needs an explanation of the particular payments and the responsibilities that come with adopting the arrangement.
Questions I would bring to the conversation
1. What provisions establish the self-insured plan structure?
2. How are eligibility and benefits administered?
3. What separate support addresses the treatment of each reimbursement?
Mardy Gould · Co-Founder, SIMERPU →
What would change our assessment?
The actual plan terms, eligibility data and payment procedures would allow a more specific assessment of the regulatory framework.
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: Cornell Legal Information Institute (reproduction)
Original Publication Date: Not stated — regulation text
Read this alongside…
Each connection has a specific purpose. Compare the sources’ facts, positions and publication dates as you read.
26 CFR §1.105-2 — Amounts expended for medical care
eCFR / Office of the Federal Register
Source position: Neutral / explanatory
Read the separate regulation governing amounts paid for medical expenses.
Read the SIMERPU recap →
CCA 201719025 — Tax Treatment of Benefits Paid by Self-Funded Health Plans
IRS Office of Chief Counsel
Source position: Neutral / explanatory
Compare particular self-funded designs examined in IRS advice.
Read the SIMERPU recap →
20 Questions about Establishing a Health & Wellness Program in the Workplace
The CPA Journal
Source position: Supportive
See how a supportive WIMPER article applies the broader plan framework.
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: Regulatory reproduction
Model Discussed: Self-insured medical reimbursement plan
Position: Neutral / explanatory
Period: Undated / current reference
Retrieved: October 31, 2026
Research and date notes
Reproduced regulatory text, not a vendor-specific approval.
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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