SIMERPU RESEARCH · SOURCE RECAP
Revenue Ruling 2002-3 — Reimbursement of pre-tax health insurance premiums
SIMERPU recap and commentary: Mardy Gould
Opened — main text retrieved
Quick recap
Holds that reimbursing employees for health premiums already funded through excluded salary reductions does not qualify for the asserted income and employment-tax exclusions.
SIMERPU’s viewpoint
Revenue Ruling 2002-3 supplies a primary source for understanding the pre-tax premium-reimbursement issue. SIMERPU would use its facts to examine whether a proposed payment returns a premium already treated favorably or reimburses a different expense. The distinction should be demonstrated through the transaction records.
What this source contributes
The ruling supplies the original facts and reasoning for the pre-tax premium-reimbursement issue.
What remains unanswered
Applying it to a new proposal requires identifying whether the payment returns the same premium or addresses a different expense.
Mardy Gould’s take
I would trace the original premium and the later payment before accepting anyone’s description of double dipping. What was already excluded, what is being reimbursed and how do the records connect? That makes the discussion precise and gives a provider a fair opportunity to demonstrate a materially different transaction.
Questions I would bring to the conversation
1. Was the original premium paid through excluded salary reduction?
2. What exactly does the later payment reimburse?
3. What records distinguish any separately claimed expense?
Mardy Gould · Co-Founder, SIMERPU →
What would change our assessment?
Evidence that a different expense and entitlement are involved could change the factual comparison with the ruling.
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: IRS; principal author Janet A. Laufer
Publisher: IRS
Original Publication Date: 2002-01-22
Read this alongside…
Each connection has a specific purpose. Compare the sources’ facts, positions and publication dates as you read.
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
Read the later advice applying related concerns to wellness arrangements.
Read the SIMERPU recap →
Double-Dipping With Wellness Programs
WageWorks, Inc.
Source position: Critical
Compare a professional explanation that cites this ruling.
Read the SIMERPU recap →
26 CFR §1.105-2 — Amounts expended for medical care
eCFR / Office of the Federal Register
Source position: Neutral / explanatory
Examine the separate expense-reimbursement regulation.
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: Government — revenue ruling
Model Discussed: Employer reimbursements for health insurance premiums
Position: Neutral / explanatory
Period: Historical — through 2022
Retrieved: October 31, 2026
Research and date notes
Published in IRB 2002-3, p. 316. Standalone three-page ruling retrieved; bulletin copy deduplicated. Alternate version/host: https://www.irs.gov/pub/irs-irbs/irb02-03.pdf
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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