If you have been sent documents about a Section 125 wellness plan, you have probably seen four or five acronyms used as though they were interchangeable. They are not, and some of them are no longer current.
Today the structure rests on two plan documents: a Section 125 Cafeteria Plan, and a Self-Insured Medical Expense Benefit Plan. That is the whole architecture. Everything else you may have read is either an older name for one of those two, or a component that is no longer named separately.
Here is each term, what it means, and whether it is current.
Quick reference
| Term you may have seen | What it refers to | Current? |
|---|---|---|
| Section 125 Cafeteria Plan | The plan document permitting pre-tax elections | Yes, one of the two required documents |
| Self-Insured Medical Expense Benefit Plan | The plan document governing reimbursement | Yes, one of the two required documents |
| SIMRP | Self-Insured Medical Reimbursement Plan, an older abbreviation for the document above | Superseded name, same document |
| SIMERP | A variant spelling with an extra E | Not used. See below |
| PCMP | Preventive Care Management Program | No longer named as a separate required document |
What is a SIMRP?
SIMRP stands for Self-Insured Medical Reimbursement Plan. It is the plan document that governs what medical care is covered and what gets reimbursed.
The underlying legal basis has not changed. It operates under Treasury Regulation Section 1.105-11, which sets out the rules for self-insured medical reimbursement plans, and it reimburses qualified medical care as defined at Internal Revenue Code Section 213(d).
What has changed is the label. Current documentation calls it the Self-Insured Medical Expense Benefit Plan. If you are reading an older document that says SIMRP and a newer one that says Self-Insured Medical Expense Benefit Plan, they are describing the same thing.
What about SIMERP, with an E?
Avoid it. It is not a term we use.
The variant spelling with an additional E has been associated with a company that administrators in this space describe as a bad actor. The acronym carries baggage it does not deserve, which is one of several good reasons to use the full plan name rather than any abbreviation.
What is a PCMP?
PCMP stands for Preventive Care Management Program. It described a component that sat inside older versions of this structure, documenting the delivery of preventive care.
It is no longer named as a separate required plan document. Current guidance is explicit that the Section 125 Cafeteria Plan and the Self-Insured Medical Expense Benefit Plan are the only two plan documents required going forward.
The substantive work the PCMP used to describe has not disappeared. The requirement that reimbursement follows documented Section 213(d) care, actually delivered and substantiated, remains central and is what makes the structure defensible. What changed is that it is no longer carved out as a third document with its own name.
If a vendor is still presenting the PCMP to you as a required third plan document, that is worth a question. It suggests their materials predate the current structure.
Why did the naming change?
Because the architecture was simplified, and because the older vocabulary was creating the wrong impression.
Three documents implied three separate things happening. Two documents describe what actually occurs: an election, and a reimbursement, governed separately. The simplification makes the structure easier to explain to a CFO and harder to mischaracterize as a single circular transaction, which is the misreading that causes most of the trouble in this category.
What does each document actually do?
The Section 125 Cafeteria Plan permits an employee to make a pre-tax election toward a qualified benefit. That is its entire function. It lowers taxable wages and, with them, payroll tax for the employee and the employer.
The Self-Insured Medical Expense Benefit Plan governs the benefit side. It defines what care is covered, requires that the care was actually delivered and substantiated, and caps the value it will reimburse at an amount written into the document.
Keeping these separate is not pedantry. The election and the reimbursement are distinct functions under distinct rules, and the arrangements the IRS has challenged are ones where nothing of substance sat between them. Our compliance page covers what those rulings said.
Which terms should we use internally?
Use the full names.
“Section 125 Cafeteria Plan” and “Self-Insured Medical Expense Benefit Plan” are unambiguous, current, and match what your counsel will see on the documents themselves. Acronyms in this space have drifted enough that they now generate more confusion than they save.
Frequently asked questions
What is a SIMRP?
A Self-Insured Medical Reimbursement Plan, the plan document governing what medical care is covered and reimbursed under Treasury Regulation Section 1.105-11. Current documentation refers to it as the Self-Insured Medical Expense Benefit Plan.
Is a SIMRP the same as a Self-Insured Medical Expense Benefit Plan?
Yes. Same document, updated name.
Is the PCMP still required?
No. The Section 125 Cafeteria Plan and the Self-Insured Medical Expense Benefit Plan are the only two required plan documents. The substantiation requirements the PCMP described remain part of how the plan operates, but it is not a separately named document.
How many plan documents are there?
Two.
What is Treasury Regulation 1.105-11?
The regulation governing self-insured medical reimbursement plans, including nondiscrimination requirements and the treatment of reimbursements. It is the legal basis for the benefit side of this structure.
What is Section 213(d)?
The section of the Internal Revenue Code defining qualified medical care. It sets the boundary for what a medical reimbursement plan can reimburse.
What to do next
If a vendor’s materials still name a PCMP as a required third document, ask why. It usually means the materials predate the current structure, and it is a reasonable question to put to anyone asking you to sign something.
Send your counsel the plan documents. Terminology matters far less than what the documents actually say. We provide both plan documents to your advisor on request, before any commitment. Ask for them.
If your counsel wants the compliance detail, our compliance page covers what the IRS has said and what a compliant plan has to demonstrate.
This page is educational and is not tax or legal advice. The plan structure and covered care behind the program are administered by Alively’s compliance partner; the Alively app is wellness software, not medical care. Employers should have the plan documents and supporting opinions reviewed by their own tax counsel before launch.