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

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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.