Randolph Health Services
The staff of a dental practice standing together in their treatment room.

For legal / counsel

The Design Basis, on the Table.

You will ask whether this is another wellness-indemnity scheme dressed up in plan language. Fair question. Here is the structure in full, the IRS memo that killed the imitators, and the documentation for your review before anyone enrolls.

Book a 15-Minute CallGet the Employer Deck

Stated plainly

What Vital 110 Is.

1A supplemental plan. Runs alongside existing major medical — it does not replace it.
2ACA MEC positioning. Positioned by Health Compass Inc. as Minimum Essential Coverage satisfying Employer Mandate Penalty A.
3Section 125 pre-tax structure. Premiums run through the employer’s cafeteria plan under the ERISA/DOL framework.
4Self-insured, TPA-adjudicated. Payments are adjudicated as claims via assignment-of-benefit, documented on an EOB.

The memo

IRS CCA 202323006 (2023).

The IRS concluded that cash paid to an employee with no unreimbursed medical expense is taxable wages under §105(b) — the ruling that made the WIMPER / fixed-indemnity category radioactive. Vital 110 is designed to fall outside it: payments run as TPA-adjudicated claims on an EOB rather than flat wellness cash. We volunteer this citation rather than hope you miss it.

Hold us to these

The Diligence Framework We Invite You to Apply.

Five questions any plan promising payroll-tax savings should pass.

  1. Is there a real plan underneath?
    An ACA-qualifying MEC health plan — or just a wellness program?
  2. Are payments adjudicated as claims?
    Documented on an EOB — or flat cash per activity?
  3. Is every payment tied to actual care?
    A covered medical encounter under §105(b) — or paid regardless?
  4. Is participation monitored?
    A plan requirement someone checks — or an honor-system checkbox?
  5. Will they put it in writing before you enroll?
    And welcome your CPA and counsel reviewing it first?

Our answer to all five is on the record, and the plan documentation is available for your review.

The boundary

What RHS Does and Does Not Represent.

Randolph Health Services is an insurance agency and independent marketing organization. It does not underwrite, insure or administer the plan, and nothing on this page is tax or legal advice. Health Compass’s AOB/EOB framing is a design basis the IRS has not blessed, and no tax outcome is guaranteed. We ask that your counsel and tax advisors review the plan documents on the front end — that is the posture of a plan with nothing to hide.

Your compliance materials

Two Documents, and a Conversation.

Compliance BriefThe structural difference versus WIMPER/SIMRP, the CCA analysis and the diligence framework.
Download the brief →
WIMPER / SIMRP White PaperThe complete cited record for your CPA and counsel — authority by authority.
Download the white paper →

Read both before you speak to us — then bring your counsel to the call. Every Vital 110 engagement starts with a conversation between you, Randolph Health Services and Health Compass, and the plan documents are walked through there rather than mailed out cold.

The Compliance Brief states Health Compass’s design basis and is not a legal or tax opinion. RHS makes no assertion regarding the structure’s tax treatment; rely on your own counsel and tax advisors.

Next step

Bring Your Counsel to the Call.

Fifteen minutes with us and Health Compass, with your advisors in the room — before anyone enrolls, not after.

Book a 15-Minute CallGet the Employer Deck