IRC §125
Provides the cafeteria-plan framework that allows qualifying employee payroll contributions to be made on a pre-tax basis.
The Self-Insured Medical Reimbursement Program (SIMRP) is structured around applicable federal tax and employee-benefit provisions. Employers should review the program’s actual plan documents, administrative procedures and proposed payroll treatment with their independent advisers.
SIMRP combines several long-standing provisions of the Internal Revenue Code together with ERISA, HIPAA, ADA, and Affordable Care Act rules. Each section serves a different role in the program's tax and benefit structure.
Provides the cafeteria-plan framework that allows qualifying employee payroll contributions to be made on a pre-tax basis.
Allows qualifying employer reimbursements for medical care to be excluded from an employee's gross income when the applicable requirements are met.
Defines qualifying medical care. The medical benefits used in the SIMRP structure are tied to services intended to fall within this definition.
Addresses the exclusion from gross income for qualifying employer-provided accident and health coverage.
Part of the federal framework governing accident-and-health reimbursements and self-insured medical reimbursement plans.
The ACA participatory-wellness provision that permits defined benefits without requiring employees to achieve a particular health outcome.
The plan is built around defined medical benefits rather than unrestricted cash. That distinction is central to the program's intended tax treatment.
Qualifying reimbursements are tied to §213(d) medical care. Under the governing plan documents, the qualifying nature of the benefits is maintained at the plan level rather than through routine individual receipts for every included service.
The program is designed under 42 U.S.C. §300gg-4(j)(2), allowing defined benefits without requiring employees to meet a specific health outcome.
The Wellness Incentive Medical Plan with Employer Reimbursement pairs a §125 pre-tax salary reduction with a §105(b) non-taxable medical-reimbursement framework. Premium treatment and medical reimbursement are separated to avoid a double exclusion.
The IRS and Department of Labor have warned about benefit designs that can create unintended tax liabilities. Similar terminology can describe very different mechanics, so employers should understand how the SIMRP structure is intended to differ.
Programs that reduce wages pre-tax and then return substantially the same amounts after tax without a genuine connection to qualifying medical expenses can be treated as taxable compensation.
The reimbursement component is tied to defined §213(d) medical benefits and is intended to operate as a §105(b) medical reimbursement rather than as unrestricted cash.
IRS Chief Counsel Advice 202323006 addressed certain fixed-indemnity or wellness-indemnity payments made without regard to actual medical expense and concluded the payments described there were taxable wages.
The program does not rely on unrestricted cash stipends, fixed-indemnity payouts, or wellness-event cash bonuses. The reimbursement structure is tied to defined qualifying medical benefits.
Arrangements that reimburse amounts already receiving pre-tax treatment can create an impermissible second tax exclusion.
The §125 and §105(b) components are designed to serve separate functions, and the program does not reimburse pre-tax premiums again.
Current program materials state that the tax and legal structure has been reviewed by a national accounting firm and a national law firm. Written opinion materials are made available to qualifying prospective employers under a mutual NDA during the discovery process.
GoRhoades coordinates the employer relationship. IronGate Business Advisors provides program administration services as defined in the governing agreements. Participating employers remain responsible for their own adoption decisions, payroll coordination, required records and professional review.
Before implementation, a workforce and payroll review identifies potentially eligible employees and prepares an employer-specific analysis for review. Eligibility and participation remain subject to the governing plan documents.
A fixed pre-tax deduction lowers participating employees' taxable wages. The 7.65% FICA rate does not change; it is applied to a lower qualifying taxable wage base.
The framework combines established federal benefit rules, including §125 cafeteria-plan rules, medical-reimbursement provisions, HIPAA-related healthcare rules, and applicable Affordable Care Act provisions.
The program is represented as designed under IRC §125, §104(a)(3), §105(b), §106(a), §213(d), Treas. Reg. 1.105-11(i), ERISA, HIPAA, ADA, and the ACA participatory-wellness framework. Documentation and administration are handled through third-party providers.
No. The program is designed to stack alongside existing major medical coverage. Employees keep their current plan. Where applicable, the program materials describe an included MEC component for employees without major medical coverage.
Current criteria generally include approximately $26,000+ in annual W-2 wages and an average of 30+ hours per week. Medicaid participants are not eligible, and 2%+ owners are excluded under the applicable criteria.
Current program materials describe the program as funded through the pre-tax structure, with no administrative fee charged against the employer's savings. Final treatment depends on the implementation and plan terms.
Discovery and eligibility review are followed by implementation and payroll setup, then guided employee onboarding. Once implementation is underway, setup typically takes about 2–3 weeks. The full process, from Discovery to first payroll, may take approximately 4–6 weeks, depending on employer responsiveness and documentation.
Program illustrations generally show take-home pay remaining similar and in some cases increasing modestly because of residual tax savings. Individual results can vary.
No. It is designed to work alongside existing coverage.
Eligible employees are generally enrolled through the employer's process and access routine benefits through the program platform or by phone.
Core telehealth and prescription benefits may extend to the enrolled employee plus up to seven additional enrolled household members. Certain employee-only benefits do not automatically extend to dependents.
Current materials describe included virtual-care and qualifying prescription benefits as available without additional copays or out-of-pocket fees, subject to plan terms.
Medical details are intended to remain confidential under applicable privacy rules. Employers receive only the participation information required for administration.
Employees with HSAs or FSAs should follow employer and program enrollment guidance so individual eligibility and enrollment are handled correctly.
Participation in the employer plan ends when employment ends. Separately issued portable life-insurance coverage is governed by its policy terms.
Virtual-care and qualifying prescription services are described as available throughout the United States, subject to provider and program availability.
Participation is voluntary under the program materials. Employees who do not want to participate should follow the applicable opt-out process.
Bring GoRhoades together with the employer's decision-makers and ask the initial questions.
Submit the requested payroll information for an eligibility and savings review.
Review the proposal and plan documents with counsel, CPA, or other tax adviser.
Confirm operational fit and implementation requirements with the payroll provider.
Proceed only after the employer is comfortable with the economics, documents, and operational responsibilities.
GoRhoades can coordinate a discovery conversation with the program administrator, the employer's CFO, CPA, legal counsel, and payroll team so everyone can review the same structure and documentation together.
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