SIMERPU RESEARCH · SOURCE RECAP
Two Plans Arrive with SIMERP on the Proposal. Only One Is What the IRS Memos Were About.
SIMERPU recap and commentary: Mardy Gould
Opened — main text retrieved
Quick recap
Argues that care subscriptions valued by an actuary differ from cash-for-activity indemnity plans. Discusses §1.105-2 and IRS memos in support of the vendor’s implementation.
SIMERPU’s viewpoint
The article directly presents the claimed difference between actuarially valued care subscriptions and cash-for-activity indemnity designs. SIMERPU would make that comparison explicit and examine how the valuation, expense and reimbursement are connected. The argument is strongest when each claimed distinction is supported by the program’s actual operation.
What this source contributes
The article states the claimed difference between a care subscription and a cash-for-activity design explicitly.
What remains unanswered
The subscription’s valuation, employee obligation and reimbursement entitlement must still be connected in the actual records.
Mardy Gould’s take
I would put both proposed structures on the same page and compare the transactions. What care is provided, what obligation arises and what determines the payment? That is a fair way to examine the distinction. The employer should be able to see why the difference matters without relying on the title of the article.
Questions I would bring to the conversation
1. What obligation arises from the care subscription?
2. How does valuation relate to the employee’s expense?
3. What facts differ from the cash-for-activity example?
Mardy Gould · Co-Founder, SIMERPU →
What would change our assessment?
A documented transaction comparison and a reasoned explanation of the expense relationship would strengthen the article’s central distinction.
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: Kristin Moore
Publisher: SIMERP LLC
Original Publication Date: 2026-09-11
Read this alongside…
Each connection has a specific purpose. Compare the sources’ facts, positions and publication dates as you read.
Enough Is Enough: A Compliance Defense of Service-Based SIMERP Implementation
SIMERP
Source position: Supportive
Read the fuller service-based defense from the same vendor.
Read the SIMERPU recap →
26 CFR §1.105-2 — Amounts expended for medical care
eCFR / Office of the Federal Register
Source position: Neutral / explanatory
Test the expense relationship against the regulatory language.
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
Compare the claimed distinction with the memo’s actual facts.
Read the SIMERPU recap →
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About this source
Original Updated Date: Not stated
Source Type: Vendor / adviser marketing or advocacy
Model Discussed: Service-based SIMERP versus indemnity
Position: Supportive
Period: Recent — 2023–2026
Retrieved: October 31, 2026
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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