
Self-insured medical reimbursement plans are a type of employee benefit that allows businesses to take control of their healthcare expenses.
Businesses can establish a self-insured plan to provide medical reimbursement to their employees, which can be more cost-effective than traditional group health insurance.
A self-insured plan is not subject to the same regulations as group health insurance, which can give businesses more flexibility in designing their plan.
Employers can use tax-free dollars to fund these plans, making them a more attractive option for businesses looking to offer healthcare benefits.
By offering a self-insured medical reimbursement plan, businesses can attract and retain top talent, improve employee morale, and reduce healthcare costs.
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What is a Self-Insured Medical Reimbursement Plan?
A Self-Insured Medical Reimbursement Plan (SIMRP) is a separate written employer plan that reimburses employees for medical expenses not covered by insurance or prepaid healthcare plans.
SIMRP plans can be voluntary or offered in conjunction with an employer's group health plan. They may provide limited benefits, such as educational health-related information, or more extensive benefits, like biometric testing and individualized coaching.
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There are two main types of SIMRP plans: activity-only and outcome-based. Activity-only plans require employees to complete a health-related activity to receive an award, while outcome-based plans require employees to achieve a specific health outcome to receive an award.
Here are some common examples of SIMRP plans:
- Activity-only programs: diet and exercise programs
- Outcome-based programs: smoking cessation programs or achieving certain biometric screening results
Highly compensated employees may receive more reimbursements, but these may be taxable. Employers must ensure that most of the eligible employees benefit from the company plan.
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What Is SIMERP?
SIMERP, or Self-Insured Medical Expense Reimbursement Program, is an IRS-qualified workplace program that allows businesses to provide voluntary benefits to employees at no cost to employers with no reduction in employees' take-home pay. This program is a type of self-insured medical reimbursement plan (SIMRP) that uses tax advantage provisions under the Internal Revenue Service codes.
SIMERP allows employees to directly fund healthcare expenses and benefits with their own tax savings, giving business owners greater longevity and lower turnover for their employees. Employers can save approximately $500 a year per employee on payroll taxes.
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Businesses get the autonomy to tailor healthcare plans to meet the specific needs of their employees, improving employee satisfaction and promoting a healthier workforce. This is a key advantage of SIMERP, as it allows employers to design benefit packages that align with their workforce's unique demographics and preferences.
Here are some examples of typical MERP reimbursements that may be included in a SIMERP:
- Doctor's office visits
- Emergency room or urgent care visits
- Hospitalization and surgical procedures
- Prescription drugs
- Glasses, contacts and other vision prescriptions
- Physical therapy and acupuncture
- Asthma inhalers and other prescription medications
- Over-the-counter medications, such as pain relievers, antibiotic ointments, eye drops, decongestants, cough syrup and antihistamines
- Women's menstrual care products, including pads, tampons, cups and liners
In addition to the cost-effectiveness and customization benefits, SIMERP also offers risk management benefits because businesses have greater control to proactively manage and mitigate their financial risks associated with healthcare claims.
What Is an HSA?
An HSA, or Health Savings Account, is a tax-exempt trust or custodial account that allows you to deduct contributions from your income before taxes, reducing your overall medical expenses. This is done by funding the account with tax-deductible contributions.
To qualify for an HSA, you must meet certain requirements, including being covered under a high deductible health plan (HDHP) on the first day of the month, having no other health coverage unless otherwise permitted, and not being enrolled in Medicare.
The IRS allows approved HSA trustees, such as banks or insurance companies, to pay or reimburse individuals on a pretax basis for qualified medical expenses, including deductibles, coinsurance, copayments, and premiums for health insurance covering medical care.
The 2020 contribution limit for an individual is $3,550, and for a family, it's $7,100, with an additional $1,000 deductible over age 55. The 2021 contribution limit is $3,600 for an individual and $7,200 for a family, with the same additional deductible over age 55.
Here are the HSA contribution limits for 2020 and 2021:
It's worth noting that failure to remain compliant with HSA requirements will nullify the pretax advantages, resulting in the participant paying future premiums on an after-tax basis.
Benefits and Advantages
The Difference Card makes it easy to set up a MERP that can reduce healthcare costs and improve employee benefits.
Our dedicated account executives will assist with annual financial projections, so you can stay on top of your plan's finances.
By utilizing a self-insured medical reimbursement plan, employees receive additional benefits while taking home the same paycheck, and employers get a yearly payroll tax reduction per employee.
Customizing healthcare plans to meet specific needs is a compelling advantage of self-insured medical reimbursement, allowing employers to design benefit packages that align with their workforce's unique demographics and preferences.
Employees can contact our participant call center for a detailed, knowledgeable response to any questions they may have about their plan.
A self-insured medical reimbursement plan can provide a reduction in workers' compensation costs for California employers.
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How it Works
A self-insured medical reimbursement plan is essentially a company's own insurance plan that pays for employee medical expenses. This plan is often more cost-effective than traditional group health insurance.
The company sets aside a specific amount of money each year to fund the plan, which is usually based on the company's past medical expenses. This amount is then used to reimburse employees for their medical bills.
The plan's administrator, often the company's HR department, reviews and approves or denies medical claims. They also determine the reimbursement rate for different medical services.
Types of Self-Insured Medical Reimbursement Plans
Self-insured medical reimbursement plans can reimburse a wide range of qualified medical expenses. These expenses can include deductibles, coinsurance and co-pays, all on a tax-free basis.
Some common types of self-insured medical reimbursement plans include those that reimburse expenses related to doctor's office visits and emergency room or urgent care visits. These plans can also cover hospitalization and surgical procedures, as well as prescription drugs.
Here are some examples of typical expenses that may be reimbursed through a self-insured medical reimbursement plan:
- Doctor's office visits
- Emergency room or urgent care visits
- Hospitalization and surgical procedures
- Prescription drugs
- Glasses, contacts and other vision prescriptions
- Physical therapy and acupuncture
- Asthma inhalers and other prescription medications
- Over-the-counter medications, such as pain relievers, antibiotic ointments, eye drops, decongestants, cough syrup and antihistamines
- Women's menstrual care products, including pads, tampons, cups and liners
MERPs for Vision and Dentistry
MERPs for Vision and Dentistry can be established as dental and vision only, offering pricing advantages over insured group coverage plans.
Pricing advantages are even stronger with dental and vision benefits, making MERPs an attractive option for groups who want to save money.
Groups who may not have been able to afford coverage in the past can now consider MERPs as a viable alternative.
MERPs allow more of the benefit dollars to wind up in the hands of employees, which is a major perk for groups with favorable loss ratios.
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Defined Contribution
Defined Contribution is a movement that's been gaining momentum in the medical benefit offerings space. This shift is reminiscent of the 80s and 90s, when pensions gave way to 401k plans.
Employers are increasingly seeking ways to care for employees' physical well-being without exposing themselves to unlimited risk. Business needs are driving this desire.
Using a MERP (Medical Expense Reimbursement Plan) in conjunction with an insured medical plan allows employers to easily compose a fixed contribution strategy even over multiple years.
5. Partial Self-Insurance
Partial self-insurance is a common approach for groups looking to dip their toes into self-funding their medical benefits while limiting risk. This method can indeed reduce an employer's tax liability and lower the overall cost of offering healthcare benefits.
By adopting partial self-insurance, employers can enjoy a yearly payroll tax reduction per employee, which can add up quickly.
Compliance and Regulations
Businesses should stay informed about the regulatory landscape and ensure compliance with relevant laws to successfully implement a self-insured medical reimbursement program. This includes understanding the legal requirements to navigate potential pitfalls.
The IRS has specific guidelines for self-insured medical reimbursement plans, as stated in § 31.3401(a)(19)-1. Amounts reimbursed to employees under such a plan are not subject to withholding, even if they are includible in the employee's gross income.
Understanding the fundamental principles and benefits of self-insured medical reimbursement programs can help business owners make informed decisions. With the support of experienced partners, the journey towards self-insurance can be easier.
Compliance Requirements
Businesses must stay informed about the regulatory landscape to ensure compliance with relevant laws, particularly when implementing a self-insured medical reimbursement program.
Understanding the legal requirements will help business owners navigate potential pitfalls and ensure a seamless transition to self-insurance.
Legal considerations play a crucial role in the success of a self-insured medical reimbursement program.
By understanding the fundamental principles, benefits, and steps involved in setting up a self-insured medical reimbursement program, business owners can make informed decisions to revolutionize their healthcare coverage strategies.
Business owners should work with experienced partners like Western Republic Insurance to make the journey towards self-insurance easier.
Compliance with relevant laws is essential to avoid potential pitfalls and ensure a smooth transition to self-insurance.
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31.3401(a)(19)-1 Reimbursements Under

Compliance and regulations play a crucial role in implementing a self-insured medical reimbursement program. Businesses must stay informed about the regulatory landscape to ensure compliance with relevant laws.
Understanding the legal requirements is essential to avoid potential pitfalls and ensure a seamless transition to self-insurance. A self-insured medical reimbursement program represents a transformative approach to medical reimbursement, empowering business owners with greater control, customization options, and cost advantages.
The IRS has specific guidelines for reimbursements under a self-insured medical reimbursement plan. According to the IRS, amounts reimbursed to or on behalf of an employee after December 31, 1979, as a medical care reimbursement under a self-insured medical reimbursement plan do not constitute wages and hence are not subject to withholding.
This exemption applies even if the reimbursement is includible in the gross income of an employee. For rules with respect to self-insured medical reimbursement plans, see section 105(h) and § 1.105-11 of this Chapter (Income Tax Regulations).
To ensure compliance, business owners should be aware of the specific regulations and guidelines governing self-insured medical reimbursement plans. By understanding these requirements, employers can design benefit packages that align with their workforce's unique demographics and preferences.
Here are some examples of qualified medical expenses that can be reimbursed under a self-insured medical reimbursement plan:
- Doctor's office visits
- Emergency room or urgent care visits
- Hospitalization and surgical procedures
- Prescription drugs
- Glasses, contacts and other vision prescriptions
- Physical therapy and acupuncture
- Asthma inhalers and other prescription medications
- Over-the-counter medications, such as pain relievers, antibiotic ointments, eye drops, decongestants, cough syrup and antihistamines
- Women's menstrual care products, including pads, tampons, cups and liners
Implementation and Administration
Implementing a self-insured medical reimbursement plan requires careful consideration of the plan's design and administration.
The plan's funding mechanism, such as a trust or a dedicated bank account, must be established to hold and manage the plan's assets.
Self-insured plans typically have a higher administrative burden compared to fully insured plans, but they offer more flexibility and control over costs.
To minimize administrative costs, the plan's administrator should be selected carefully, considering factors such as experience and cost.
The plan's administrator is responsible for managing the plan's day-to-day operations, including claims processing and communication with plan participants.
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Employer Sets Allowance Limits

The employer sets the allowance amounts for reimbursement, which can be a flat dollar maximum or a more complicated structure allocating specific amounts to procedures or categories.
A simple reimbursement plan allocates a flat dollar maximum amount to be spent by the employee and eligible dependents on eligible items within a calendar year.
This monthly allowance reflects the total amount an employer can reimburse the employee for health expenses.
The Difference Card can help employers set up a Medical Expense Reimbursement Plan (MERP) with prepackaged suggestions based on effective plans across their book of business.
Employers work with a dedicated account executive to develop a communication plan and benefit materials, and employees can contact a participant call center for questions.
Data Abundance
Having access to detailed utilization data is a significant advantage of a MERP, as KBI Benefits calls it an “employee healthcare usage gage” on their company blog.
This data can be particularly valuable for groups that are currently unable to view their claims experience due to their size or pooling arrangement.
For example, with copays being run through the MERP administrator and the insurer, employers can suddenly have full access to detailed utilization data specific to their employee population.
Explaining a MERP Program to Employees
Explaining a MERP Program to Employees is crucial for a successful rollout. Communication is key to employee understanding and acceptance of the new program.
Employees need a concise explanation of which benefits will be funded by the MERP and which will continue to be paid by the insurer. This explanation should also cover when to contact the plan administrator for service.
A debit card will be provided to employees, and they should understand how to receive reimbursements from the MERP if not.
Typically, employees will need to access full instructions, particularly during future enrollment periods while making their plan selections.
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Cost Savings and Efficiency
A self-insured medical reimbursement plan can be a cost-effective option for businesses, allowing them to save up to 10-15% on medical expenses by reducing administrative costs and negotiating lower rates with providers.
With a self-insured plan, employers can also take advantage of tax benefits, such as deducting medical expenses on their tax returns.
By controlling their own medical expenses, businesses can allocate resources more efficiently and make strategic decisions about their healthcare budget.
Tax and Cost Savings

A WIMPER program can save employees money by allowing them to purchase additional benefits at a lower cost, without affecting their net pay.
By contributing a portion of their salary to pay for qualified benefits, employees can reduce their compensation and lower their FICA tax liability.
A fixed indemnity insurance plan can be used separately as a reimbursement if the value of the wellness plan that provides medical care is excluded from gross income.
This can result in significant tax savings for employees, as they can save income taxes on the pretax contributions made to an IRC section 125 cafeteria plan.
A WIMPER program can also save employers money by reducing FICA taxes paid, as the amount elected by the employee to be contributed to the plan is not considered to be wages and therefore not taxable for Social Security purposes.
Partial self-insurance can also reduce an employer’s tax liability and lower the overall cost of offering healthcare benefits.
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By allowing employees to choose their own benefits and providing tax-free reimbursements, a WIMPER program can lead to lower Federal Insurance Contributions Act (FICA) taxes for both the employer and employee.
This can result in significant cost savings for businesses, making a WIMPER program an attractive option for companies looking to reduce their healthcare costs.
Control of Funds
Control of Funds is a significant advantage of Medical expense reimbursement programs. Unspent funds at year-end stay with the employer and are available for next year's benefits programs.
This means employers can provide benefits that are fairly accessed only by those who need them, unlike traditional insurance plans where the insurance carrier retains premium dollars. This approach can lead to more targeted and efficient use of funds.
The Medical expense reimbursement program allocates funds spent toward eligible expenses only if they are incurred, rather than representing an obligation to pay. This helps employers save money by avoiding unnecessary costs.
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What Is Merp?
A MERP, or Medical Expense Reimbursement Plan, is a type of self-insured medical reimbursement plan that can help individuals and families save money on medical expenses.
It's a relatively straightforward concept, and it's actually based on the basic mechanics of a MERP program, which typically follows a set of steps outlined in a MERP program guide.
Frequently Asked Questions
What are the disadvantages of merp?
MERP can be challenging for employers and employees due to its instability and administrative burdens, impacting work productivity and overhead costs
Sources
- https://www.taxnotes.com/research/federal/irs-guidance/revenue-rulings/irs-rules-on-amounts-reimbursed-under-a-self-insured-medical-expense/dkxd
- https://www.cpajournal.com/2021/01/27/20-questions-about-the-establishing-a-health-wellness-program-in-the-workplace/
- https://www.differencecard.com/blog/why-the-difference-card-uses-a-merp-to-build-custom-plan-designs/
- https://wrinsurance.com/2023/12/26/inside-simerp-how-self-insurance-redefines-medical-reimbursement/
- https://www.ecfr.gov/current/title-26/chapter-I/subchapter-C/part-31/subpart-E/section-31.3401(a)(19)-1
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