SIMERPU RESEARCH · SOURCE RECAP
Double-Dip Health Arrangements Still Illegal Despite Recent IRS and Department of Treasury Opinions
SIMERPU recap and commentary: Mardy Gould
Opened — main text retrieved
Quick recap
Argues that the 2024 rulemaking did not authorize double-dip health arrangements and warns of tax exposure for employers and employees.
SIMERPU’s viewpoint
FNA’s article addresses a recurring interpretation of the 2024 rulemaking. SIMERPU would read the relevant preamble and distinguish a decision not to finalize a proposal from an affirmative endorsement of a marketed arrangement. The source is useful when it directs readers to the precise language behind the disagreement.
What this source contributes
The article challenges the inference that leaving tax proposals unfinalized authorized the marketed arrangements.
What remains unanswered
The provider’s actual interpretation and the relevant preamble language need to be examined directly.
Mardy Gould’s take
When the disagreement is about what a rule means, I want the text on the table. Identify the exact passage and explain the inference being made. That allows an employer to compare the competing interpretations without relying on a headline that compresses several different regulatory questions into one claim.
Questions I would bring to the conversation
1. Which preamble passage supports the asserted conclusion?
2. What was left unfinalized and why does that matter?
3. What independent support addresses the program’s actual payments?
Mardy Gould · Co-Founder, SIMERPU →
What would change our assessment?
A later authoritative resolution of the specific issue could change the analysis; a decision not to finalize a proposal should be described accurately.
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: Michael Bivona
Publisher: FNA Insurance Services, Inc.
Original Publication Date: 2025-05-08
Read this alongside…
Each connection has a specific purpose. Compare the sources’ facts, positions and publication dates as you read.
Short-Term, Limited-Duration Insurance and Independent, Noncoordinated Excepted Benefits Coverage
Federal Register
Source position: Neutral / explanatory
Read the actual 2024 tax-related preamble at the center of the disagreement.
Read the SIMERPU recap →
Proposed Rules on Short-Term, Limited-Duration Insurance and Fixed Indemnity Excepted Benefits Coverage
Federal Register
Source position: Neutral / explanatory
Compare the earlier proposal with what followed.
Read the available-source note →
CCA 202323006 — Tax Treatment of Employer-Funded, Insured, Fixed-Indemnity Wellness Policy
IRS Office of Chief Counsel
Source position: Neutral / explanatory
Keep the separate payment facts and conclusions of the IRS memo in view.
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: Benefits consultant / administrator
Model Discussed: Double-Dip health arrangements
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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