SIMERPU RESEARCH · SOURCE RECAP

New IRS Memo Confirms Tax Treatment of Wellness Programs & Incentives

SIMERPU recap and commentary: Mardy Gould

Opened — main text retrieved

Quick recap

Explains the 2016 CCA’s treatment of wellness incentives and premium reimbursements, emphasizing that tax rules remain separate from other wellness compliance requirements.

SIMERPU’s viewpoint

The 2016 explanation is useful for showing that wellness rules can address different questions. SIMERPU would distinguish participation and program-compliance requirements from the treatment of incentives and premium reimbursements. That helps employers understand why one compliance statement may not answer the entire review.

What this source contributes

The explanation makes clear that different wellness compliance rules address different questions.

What remains unanswered

An employer needs separate support for program classification and the treatment of its incentives or premium reimbursements.

Mardy Gould’s take

I would ask what a compliance statement actually covers. Does it address participation rules, a premium or a payment to the employee? Keeping those answers distinct helps the employer understand the program and prevents a valid explanation of one component from being stretched to cover the entire arrangement.

Questions I would bring to the conversation

1. Which compliance question does each statement answer?

2. What supports the treatment of the incentive or reimbursement?

3. How do the separate analyses fit the actual program?

Mardy Gould · Co-Founder, SIMERPU →

What would change our assessment?

A complete set of fact-specific analyses could address the separate questions; one general compliance label would leave them unresolved.

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: Lisa Van Fleet

Publisher: Bryan Cave / BCLP; accessible through JD Supra

Original Publication Date: 2016-06-15

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: Law firm analysis

Model Discussed: IRS Chief Counsel Memo

Position: Neutral / explanatory

Period: Historical — through 2022

Retrieved: October 31, 2026

Research and date notes

JD Supra credits Lisa Van Fleet and BCLP; original BenefitsBryanCave URL now returns parking content. Original authorship retained. Alternate version/host: http://benefitsbryancave.com/new-irs-memo-confirms-tax-treatment-of-wellness-programs-incentives/

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.