SIMERPU RESEARCH · SOURCE RECAP
IRS Guidance on Tax Treatment of Benefits Paid by Self-Funded Fixed-Indemnity Plans
SIMERPU recap and commentary: Mardy Gould
Opened — main text retrieved
Quick recap
Analyzes CCA 201719025, focusing on predictable benefits, after-tax employee contributions, insurance risk and wage treatment in the described self-funded plans.
SIMERPU’s viewpoint
Wagner’s analysis of the self-funded memo emphasizes the relationship between contributions, predictable benefits and the claimed insurance function. SIMERPU would use those factors to understand the economics of a proposed design. An explanation of what the arrangement actually covers helps employers evaluate both its value and its stated tax treatment.
What this source contributes
The analysis connects predictable benefits and contributions to the economic function of the described self-funded plans.
What remains unanswered
The comparison requires the actual benefit obligations and funding of the proposal being considered.
Mardy Gould’s take
I would ask the provider to explain the product before explaining the savings. What uncertainty is covered, what can vary and who pays the promised benefit? An employer should understand those fundamentals well enough to see how the financial illustration relates to the arrangement it is adopting.
Questions I would bring to the conversation
1. What determines the benefit amount?
2. How do contributions relate to promised payments?
3. Who bears the economic obligation when outcomes differ?
Mardy Gould · Co-Founder, SIMERPU →
What would change our assessment?
Verified differences in risk, contributions or benefit entitlement could alter the comparison with the memorandum’s designs.
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: The Wagner Law Group (no reliable individual byline)
Publisher: The Wagner Law Group
Original Publication Date: 2017-05-18
Read this alongside…
Each connection has a specific purpose. Compare the sources’ facts, positions and publication dates as you read.
CCA 201719025 — Tax Treatment of Benefits Paid by Self-Funded Health Plans
IRS Office of Chief Counsel
Source position: Neutral / explanatory
Read the original self-funded-plan memorandum.
Read the SIMERPU recap →
26 CFR § 1.105-11 - Self-insured medical reimbursement plan
Cornell Legal Information Institute (reproduction)
Source position: Neutral / explanatory
Distinguish the general plan framework from the particular designs examined.
Read the SIMERPU recap →
26 CFR §1.105-2 — Amounts expended for medical care
eCFR / Office of the Federal Register
Source position: Neutral / explanatory
Consider the separate medical-expense reimbursement requirements.
Read the SIMERPU recap →
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About this source
Original Updated Date: 2021-08-05 (page metadata)
Source Type: Law firm analysis
Model Discussed: Self-Funded Fixed-Indemnity Plans
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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