SIMERPU RESEARCH · SOURCE RECAP
Debunking Double Dipping
SIMERPU recap and commentary: Mardy Gould
Opened — main text retrieved
Quick recap
Attorney commentary challenges valuation and reimbursement arguments used for wellness savings arrangements. Emphasizes expenses actually incurred and the §1.105-2 test.
SIMERPU’s viewpoint
The commentary focuses the debate on the relationship between valuation and expenses actually incurred. SIMERPU would ask a proponent of a service-valued reimbursement model to explain that relationship directly. A useful exchange should connect the valuation methodology to the expense and payment facts being asserted.
What this source contributes
The commentary focuses on the connection between a service valuation and an expense actually incurred.
What remains unanswered
The valuation methodology and employee-level expense facts for a particular program are still needed to evaluate the disputed connection.
Mardy Gould’s take
I would ask the provider to explain what the valuation measures and how that amount becomes the employee’s reimbursable expense. Those are connected questions, but they need to be answered explicitly. A clear explanation should help the employer follow the reasoning from the care delivered to the amount paid.
Questions I would bring to the conversation
1. What exactly does the valuation measure?
2. How does it relate to an employee’s actual obligation?
3. What records connect the expense to the reimbursement?
Mardy Gould · Co-Founder, SIMERPU →
What would change our assessment?
A documented expense relationship and a reasoned response to the regulatory objection would strengthen the valuation-based argument.
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: Chris Vanderwolk
Publisher: Vanderwolk, Esq.
Original Publication Date: 2026-04-21
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 expense and payment language central to the critique.
Read the SIMERPU recap →
Enough Is Enough: A Compliance Defense of Service-Based SIMERP Implementation
SIMERP
Source position: Supportive
Compare the critique with an affirmative service-based defense.
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
Examine how the IRS analyzes payments without related unreimbursed expenses.
Read the SIMERPU recap →
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About this source
Original Updated Date: 2026-04-24 (page metadata)
Source Type: Attorney commentary
Model Discussed: §105(b) reimbursement structures in wellness plans
Position: Critical
Period: Recent — 2023–2026
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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