SIMERPU RESEARCH · SOURCE RECAP
Whack-a-Mole — IRS Takes Aim at Latest Wellness Program Scheme, But Overly Broad Language Can Be Taken Too Far as Applied to Traditional Coverage
SIMERPU recap and commentary: Mardy Gould
Opened — full article within 25-page issue
Quick recap
Criticizes hybrid wellness-indemnity arrangements lacking economic substance while arguing that broad IRS language should not upset traditional insured indemnity coverage. Explains premium double dipping and competing interpretations.
SIMERPU’s viewpoint
This article is valuable because it both criticizes certain wellness arrangements and questions an overly broad application to traditional coverage. SIMERPU would preserve that distinction when discussing fixed indemnity. Careful reading can identify a genuine concern without treating every product with a shared label as the same design.
What this source contributes
The article preserves a distinction between criticized hybrid designs and traditional indemnity coverage.
What remains unanswered
Its concerns and qualifications must both be retained when applying the historical analysis to another product.
Mardy Gould’s take
This is the kind of distinction I want readers to notice. A source can identify a real problem and still question whether an explanation has been applied too broadly. I would ask which product and funding facts are being discussed before using the article to support a conclusion about an entire category.
Questions I would bring to the conversation
1. Which hybrid design does the article criticize?
2. What traditional coverage does it distinguish?
3. Which facts determine where the proposed product belongs?
Mardy Gould · Co-Founder, SIMERPU →
What would change our assessment?
Verified differences in economic structure, funding and benefit terms could change the relevant comparison.
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: John Hickman; Carolyn Smith; Christine Keller; Katie Bjornstad Amin
Publisher: ECFC FLEX Reporter, vol. 21, no. 1; Wagner Law Group-hosted copy
Original Publication Date: 2017
Read this alongside…
Each connection has a specific purpose. Compare the sources’ facts, positions and publication dates as you read.
CCA 201703013 — Tax Treatment of Benefits Paid by Fixed-Indemnity Health Plans
IRS Office of Chief Counsel
Source position: Neutral / explanatory
Compare the primary funding scenarios with the article’s qualifications.
Read the SIMERPU recap →
CCA 201719025 — Tax Treatment of Benefits Paid by Self-Funded Health Plans
IRS Office of Chief Counsel
Source position: Neutral / explanatory
Read the separate advice on particular self-funded designs.
Read the SIMERPU recap →
Legal, tax issues with fixed-indemnity plans, wellness “double-dip” schemes
Mercer
Source position: Critical
Compare a later discussion distinguishing coverage and payment treatment.
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: Professional accounting / benefits publication
Model Discussed: Wellness Program Arrangements and IRS Response
Position: Mixed
Period: Historical — through 2022
Retrieved: October 31, 2026
Research and date notes
Issue copyright 2017; filename labels March 2017 but month not separately verified. May seminar version retained in duplicate ledger. OCR renders Amin as Admin in some bylines.
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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