What the WIMPER Program Is
WIMPER is an IRS-aligned strategy designed to:
- Reduce taxable wages through a Section 125 structured pre-tax contribution
- Reimburse eligible §213(d) medical and preventive services through a compliant Section 105(b) SIMRP
- Redirect FICA tax leakage into real employee benefits
- Improve EBITDA without cutting headcount or reducing compensation
- Operate alongside your existing major medical or MEC plan
Unlike fixed-indemnity “wellness schemes,” the WIMPER framework uses qualified medical benefits, not cash incentives. This is what distinguishes it from the fixed-indemnity double-dipping arrangement the IRS addressed in CCA 202323006, a non-precedential IRS position. WIMPER reimburses actual §213(d) medical expenses rather than paying fixed cash, so it is structured to be distinguished from that fact pattern. The CCA does not endorse or approve WIMPER or any other specific program.
Review the Compliance Framework →
How the Structure Works
1. Section 125 Structured Contribution (Pre-Tax)
Employees elect a pre-tax contribution, reducing taxable wages and lowering FICA for both employer and employee. (26 U.S.C. §125; FICA wage exclusion under 26 U.S.C. §3121(a)(5)(G); see also IRS Publication 15.)
2. Preventive-Care & Virtual Health Benefits
Employees receive comprehensive services including virtual urgent care, primary care, mental health, chronic disease support, and prescription assistance.
3. Section 105(b) Reimbursements
A Self-Insured Medical Reimbursement Plan reimburses qualified §213(d) medical expenses tax-free, designed to align with IRS requirements and to avoid “double-dip” patterns. (26 U.S.C. §105; employer-provided coverage exclusion under 26 U.S.C. §106; definition of medical care at 26 U.S.C. §213; nondiscrimination rules at Treas. Reg. §1.105-11.)
Employer Outcomes
- Estimated $1,120 per participating employee in annual employer FICA savings
- Improved EBITDA and cash flow
- No reduction in employee take-home pay
- Designed and structured to comply with IRC Sections 125, 106, 105(b), and 213(d) when properly implemented
- 30–45 day implementation timeline
- Compatible with ADP, Paychex, QuickBooks, Gusto, and other payroll systems
The $1,120 figure is an estimate, not a guarantee. Actual savings depend on each employee’s salary, the size of their pre-tax election, and your participation rate. The estimate assumes a per-employee Section 125 election of roughly $1,220/month ($14,640/year) at typical mid-market participation. Your results will vary; request a pro forma for figures based on your own census.
Employee Outcomes
Employees receive a meaningful increase in perceived compensation through:
- Virtual urgent care ($0 copay/$0 deductible)
- Virtual primary care and mental health services
- Chronic condition support
- Weight-health programs
- Prescription savings
- Supplemental benefits (accident, disability, life, critical illness)
These services enhance retention, reduce absenteeism, and improve overall worker satisfaction.
Who Qualifies?
Most employers qualify if they meet the following criteria:
- 10+ eligible W-2 employees
- 30+ hours/week
- Existing MEC or major medical plan
- Compatible payroll system
- Participation rates typically between 70–80% for mid-market companies
Check Your WIMPER Eligibility →
Implementation & Support
WIMPER Institute serves as your educational and compliance resource.
We do not sell insurance or administer benefits.
We provide:
- Compliance and structural evaluation
- Educational resources for CFOs and finance teams
- Feasibility guidance
- Documentation and due-diligence framework
- Connection to certified implementation specialists
Implementation specialists (such as Brandon Attebury) manage:
- Census review
- Payroll configuration
- Employee onboarding
- Compliance documentation
- Ongoing management
Implementation typically completes within 30–45 days.
Connect With a Program Specialist →
Frequently Asked Questions
How is WIMPER different from fixed-indemnity wellness plans?
Fixed indemnity plans pay cash benefits and often create double-dip tax issues. WIMPER instead uses a Section 105(b) SIMRP and reimbursable §213(d) medical care, designed to align with IRS code and applicable ACA/HIPAA/ERISA guidance.
Does this change our major medical plan?
No. Your existing major medical or MEC plan remains in place. WIMPER works alongside your current benefits.
Is this compliant with IRS rules?
The structure is designed and structured to comply with established IRS Code Sections 125, 106, 105(b), and 213(d) when properly implemented, and it is structured to be distinguished from the fixed-indemnity double-dipping arrangement the IRS addressed in CCA 202323006, a non-precedential IRS position. Whether the program is compliant as applied to your organization depends on your facts and how it is implemented, so you should confirm with your own tax and legal advisors.
What if employees don’t participate?
Non-participating employees simply don’t enter the program. Participation rates typically range from 70–80% for mid-market employers.'
How long does implementation take?
Most employers go live within 30–45 days, including payroll configuration and employee communications.'
How does WIMPER work with EHP?
The WIMPER Institute evaluates whether an employer is a good fit for a structured medical reimbursement program and then connects qualified employers with EHP for implementation. EHP manages the plan setup, interfaces with payroll, administers the SIMERP structure, and coordinates employee communications and wellness tracking. This division of roles allows WIMPER to stay focused on education and strategy while EHP specializes in day-to-day administration.
What is a SIMERP in the context of the WIMPER program?
A Self-Insured Medical Expense Reimbursement Program, or SIMERP, is the underlying structure used to deliver tax-advantaged reimbursements and wellness benefits. In the WIMPER program, the SIMERP is configured as an integrated Section 105 plan that emphasizes preventive care and wellness, with at least one qualifying wellness activity per year required for participating employees. EHP documents and administers this structure in line with IRS and regulatory requirements.
What are the typical employer outcomes?
When the program is a good fit and implemented correctly, employers may see reduced payroll tax expenses, increased perceived value of their benefits package, and higher engagement with preventive care and wellness services. Employees gain access to virtual primary care, mental fitness resources, and other wellness tools without reducing their take-home pay. The WIMPER Institute helps employers model these outcomes in advance through pro forma analysis.
What does implementation look like for HR and payroll?
Once an employer chooses to proceed, EHP works directly with HR and payroll teams to configure the necessary payroll entries and establish the workflows for ongoing administration. This includes employee enrollment, communication materials, wellness tracking, and reporting. The WIMPER Institute provides high-level guidance so that HR and finance stakeholders know what to expect at each step.
How are employees informed and supported?
Employees receive clear onboarding materials explaining how the program works, what wellness activities are required, and how to access Revive Health and other tools. EHP provides ongoing outreach—via email, SMS, app notifications, and support centers—to guide employees through their activities and answer questions. This combination of education and support is essential for keeping participation high and ensuring compliance.