CPA & Advisors
PROGRAM OVERVIEW
Certified Public Accountants, tax professionals, consultants, and business advisors are often asked to evaluate opportunities that may affect an organization’s financial position, employee benefits, payroll tax treatment, and overall compliance posture.
The Self-Insured Medical Reimbursement Plan (SIMRP) is designed to operate within established IRS and ERISA frameworks and is often evaluated by advisors seeking to understand both its technical structure and practical application.
Unlike many strategies that rely upon aggressive interpretations or temporary provisions, SIMRP is structured around long-established sections of the Internal Revenue Code governing employee benefits, medical reimbursements, cafeteria plans, and qualified medical expenses.
For professional advisors, the primary questions are typically:
- What is the legal and regulatory framework?
- How is the program administered?
- What documentation supports the structure?
- How is compliance maintained?
- Has the structure been independently reviewed?
STRUCTURAL COMPONENTS
SIMRP is not based upon a single IRS code section.
The structure is built upon multiple established provisions of federal law working together within a documented employee benefit framework.
Key components include:
- IRC Section 105(b)
- IRC Section 106
- IRC Section 125
- IRC Section 213(d)
- ERISA governance
- Formal plan documentation
- Third-party administration
- Substantiation requirements
- Ongoing compliance oversight
Each component serves a specific purpose within the overall structure.
The result is a program designed to operate through documented procedures, established administrative controls, and recognized employee benefit frameworks rather than informal interpretations or unsupported tax positions.
PROFESSIONAL REVIEW
Organizations considering any employee benefit program should conduct appropriate due diligence and seek professional guidance when necessary.
Over the years, structures involving medical reimbursement arrangements, cafeteria plans, health and welfare benefits, and related employee benefit programs have been the subject of ongoing review by attorneys, accountants, actuaries, administrators, and regulatory professionals.
SIMRP is designed to operate within these established frameworks and is supported by formal documentation, administrative procedures, and compliance protocols intended to support consistent plan operation.
Professional advisors evaluating the program should focus on:
- Applicable IRS provisions
- ERISA requirements
- Plan documentation
- Administrative procedures
- Substantiation standards
- Payroll tax treatment
- Ongoing governance requirements
These areas form the foundation of a proper professional review.
INDEPENDENT EVALUATION
Every organization is unique.
Every advisor has a professional responsibility to evaluate opportunities based upon the specific facts and circumstances of the organization they serve.
For that reason, employers and advisors are encouraged to conduct their own independent review of any employee benefit program under consideration.
SIMRP is designed to withstand that review process through:
- Established statutory authority
- Formal plan documentation
- Third-party administration
- Compliance oversight
- Administrative consistency
- Independent professional analysis
The objective is transparency.
The objective is documentation.
The objective is allowing employers and their advisors to evaluate the program based upon facts, structure, and applicable law.
CPA JOURNAL ANALYSIS
The CPA Journal article provides an independent discussion of the legal, regulatory, and practical considerations associated with structured health and welfare reimbursement arrangements.
Advisors reviewing the program are encouraged to evaluate the article as part of their overall due diligence process.
SAFE HARBOR HEALTH WHITEPAPER
The Safe Harbor Health whitepaper provides additional discussion regarding plan structure, governing authorities, administrative requirements, compliance considerations, and the interaction of the various statutory provisions that support the program framework.
The whitepaper is intended to assist advisors, accountants, attorneys, and employers seeking a deeper understanding of how the various components operate together within a documented employee benefit structure.
DON'T TAKE OUR WORD FOR IT.
Check some of the most trusted sources business leaders use every day.
Use these trusted platforms to research the information for yourself and gain confidence in your decision-making.
ASK THESE THREE QUESTIONS:
Is a Self-Insured Medical Reimbursement Plan (SIMRP)
a government-recognized program?
Is a Self-Insured Medical Reimbursement Plan (SIMRP)
recognized under federal law?
Is a Self-Insured Medical Reimbursement Plan (SIMRP)
authorized under the Internal Revenue Code?
PRIMARY GOVERNMENT SOURCE – IRS.GOV
Explore these key sections of the Internal Revenue Code.
IRC §125
Cafeteria Plans
IRC §105
Reimbursement of Medical Expenses
IRC §106
Health Insurance Exclusion (Employer-Provided)
IRC §213(d)
Qualified Medical Expense Deductions
These sections of the Internal Revenue Code form the foundation for properly designed Self-Insured Medical Reimbursement Plans (SIMRP).
Do your own research.
Get your own answers. Make confident, informed decisions.
