What Is a WIMPER Plan? (And Why It Depends on a SIMRP)
WIMPER is a marketing name. The IRS regulates self-insured medical reimbursement plans, not "WIMPERs." Here is what that means for your organization.
5 min read
Short answer: WIMPER is a marketing name, not an IRS term. Programs sold as WIMPERs depend on a compliant self-insured medical reimbursement plan, which is what the IRS regulates.
Searching for WIMPER? Here's what it really is
"WIMPER" is a name used in marketing for a type of employee wellness program. It is not a legal or regulatory term. The IRS does not use the word "WIMPER" in its regulations.
What those regulations do address is the self-insured medical reimbursement plan (SIMRP), governed by 26 CFR § 1.105-11, usually paired with a Section 125 cafeteria plan. A program sold as a WIMPER cannot exist on its own: it depends on a compliant SIMRP underneath it.
Start with the real structure: The Complete Guide to Self-Insured Medical Reimbursement Plans (SIMRP) explains the plan the IRS actually regulates.
Why the name matters less than the plan
Whatever a program is called, the tax treatment comes from the underlying plan and how it is run. The questions that matter are the same ones that apply to any SIMRP:
- Is there a properly documented Section 125 plan and a Section 105 self-insured medical reimbursement plan?
- Does the plan pass the nondiscrimination tests in 26 CFR § 1.105-11?
- Are payments tied to real medical care or coverage?
- Is payroll and W-2 coding handled correctly?
In 2023 the IRS warned, in Chief Counsel Advice memorandum 202323006, that fixed wellness payments made without any unreimbursed medical expense are taxable wages. A label does not change that.
Who uses these programs
Private businesses, schools, colleges, and public employers look at these programs to lower payroll taxes and improve take-home pay. Eligibility runs through the SIMRP rules:
- Your organization does not have to offer health insurance. Eligibility is decided employee by employee.
- Employees qualify with compliant health coverage from any source, such as an employer plan, a spouse's or parent's plan, their own paid coverage, TRICARE or state subsidies.
- Employees on federally subsidized marketplace coverage, or with no coverage, do not qualify on their own.
- If some employees need coverage, a SIMRP Advisor may be able to provide guidance so they can take part.
- There is no minimum number of employees. Every organization starts with a free, no-obligation payroll census that shows who is eligible.
Frequently asked questions
Is WIMPER an IRS term?
No. WIMPER is a marketing name. The IRS regulations address self-insured medical reimbursement plans under 26 CFR § 1.105-11.
Can a WIMPER exist without a SIMRP?
No. A program sold as a WIMPER depends on a compliant self-insured medical reimbursement plan, usually paired with a Section 125 cafeteria plan.
Keep reading
- The Complete Guide to Self-Insured Medical Reimbursement Plans (SIMRP)
- WIMPER vs. SIMRP: Why the IRS Only Recognizes the SIMRP
- Is a WIMPER Plan Legal? What the IRS Actually Regulates
- How a Compliant SIMRP Works (and the IRS 2023 Wellness Plan Warning)
Sources
Educational only, not tax advice. This page is a general explanation and is not tax, legal, or accounting advice. Every organization is different, so talk with a qualified tax professional about your plan.
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Related articles
The Complete Guide to Self-Insured Medical Reimbursement Plans (SIMRP)
A plain-English guide to self-insured medical reimbursement plans: Section 125 and 105, eligibility, the 26 CFR § 1.105-11 nondiscrimination tests, compliant vs. non-compliant plans, payroll basics, and FAQs.
WIMPER vs. SIMRP: Why the IRS Only Recognizes the SIMRP
SIMRP is the structure in IRS regulations (26 CFR § 1.105-11). WIMPER is a marketing name for programs that depend on it.
Is a WIMPER Plan Legal? What the IRS Actually Regulates
The IRS regulates self-insured medical reimbursement plans, not "WIMPERs." What the 2023 IRS memo means and what keeps a plan compliant.
See if a compliant SIMRP fits your organization
There is no minimum number of employees. Start with a free payroll census to see what your organization could save. Any savings figure is an estimate.
Written by Jake Parvu
Jake Parvu is a licensed financial agent and benefits educator with SIMRP Health & Wellness™. Licensed since 2007, his background includes serving Florida public school employees and working as a Certified Federal Retirement Consultant. He now educates public schools and private businesses on the proper use and administration of IRS Code Compliant Self-Insured Medical Reimbursement Plans.
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