WIMPER vs. SIMRP: Why the IRS Only Recognizes the SIMRP
People search for both names. Only one appears in IRS regulations, and the other depends on it.
4 min read
Short answer: SIMRP is the structure in IRS regulations (26 CFR § 1.105-11). WIMPER is a marketing name for programs that depend on it.
The short answer
They are not two competing plans. SIMRP, a self-insured medical reimbursement plan, is the structure that federal tax regulations recognize, in 26 CFR § 1.105-11. "WIMPER" is a marketing name that some providers use for wellness programs that rely on that structure. The IRS does not use the word "WIMPER."
Start with the real structure: The Complete Guide to Self-Insured Medical Reimbursement Plans (SIMRP) explains the plan the IRS actually regulates.
Side by side
| SIMRP | "WIMPER" | |
|---|---|---|
| What it is | A self-insured medical reimbursement plan | A marketing name for a wellness program |
| Named in IRS regulations? | Yes, 26 CFR § 1.105-11 | No |
| Can it stand alone? | Yes, when paired with a Section 125 plan and run correctly | No, it depends on a compliant SIMRP |
| Rules that apply | Nondiscrimination tests; payments tied to medical care or coverage | The same SIMRP rules |
Why this matters when you compare providers
Because the tax treatment comes from the SIMRP, evaluate any program by the SIMRP rules, not the label. Ask how the plan meets the nondiscrimination tests, how payments connect to real medical care or coverage, and how payroll and W-2s are coded. The IRS's 2023 memo, CCA 202323006, is a reminder that flat wellness payouts with no medical expense behind them are taxable wages, whatever the program is called.
Read more in How a Compliant SIMRP Works.
Keep reading
- The Complete Guide to Self-Insured Medical Reimbursement Plans (SIMRP)
- What Is a WIMPER Plan? (And Why It Depends on a 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.
What Is a WIMPER Plan? (And Why It Depends on a SIMRP)
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.
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
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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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