Institutional Governance: Our Commitment to Compliance

  Most benefit programs in this space have faced legitimate IRS scrutiny. The reason is straightforward: they were structured around passive wellness participation — activities that required no actual medical care. The IRS correctly challenged those payments as taxable wages.

iM4 Health is built on a fundamentally different legal foundation. Here is exactly how.

Every claim payment in the iM4 Health program is triggered exclusively by an IRC Section 213(d) medical care event — a consultation, health assessment, or screening performed by a licensed medical professional.

· What 213(d) means: Section 213(d) defines legitimate medical care under the Internal Revenue Code — the same standard used to determine medical expense deductibility. It has been permanent law since 1954.

· Why it matters: The IRS Chief Counsel Memoranda (including CCA-202323006) specifically challenged programs where payments were tied to wellness participation with no qualifying medical care. iM4 Health payments require a documented 213(d) medical event. That is the legal and structural line between a compliant program and a liability.

· No passive participation: We strictly prohibit payments for wellness activities that do not meet the IRC Section 213(d) definition of medical care.

The iM4 Health program is engineered within the established provisions of the Internal Revenue Code:

· Section 213(d) Medical Care Foundation:Every claim payment is tied to a qualifying medical care event performed by a licensed professional — not passive wellness participation.

· Section 125 Cafeteria Plan: The delivery mechanism through which employee pre-tax elections are processed, generating FICA tax savings for both employer and employee.

· Section 105(b) Exclusions: All reimbursements for qualifying medical care are excluded from the employee's gross income, maintaining the take-home pay increase without increasing tax liability.

· ACA & HIPAA Compliance: iM4 Health is a compliant enhancement that works alongside — never in conflict with — Affordable Care Act requirements.

· Greenberg Traurig LLP: Legal counsel provided by Fred E. Karlinsky — Chair, Global Insurance Regulatory and Transactions Practice Group — one of the largest and highest-ranked law firms in the United States with 3,100+ attorneys and the most Tier 1 national rankings of any firm in America.

· A+ Rated Carrier: Underwritten by United States Fire Insurance Company (Crum & Forster group) — A (Excellent) AM Best rating — in continuous operation since 1822.

· State Department of Insurance Approvals:The iM4 Health structure has been reviewed and approved by multiple state Departments of Insurance across the country.

· Audit-Ready Documentation:Every transaction — from payroll deduction to claim reimbursement — is fully documented and reportable, providing the audit trail required by Fortune 500 compliance teams.

· Zero Compliance Issues Since 2020:Five years of continuous operation with no IRS enforcement actions or regulatory findings. 

iM4 Health and its affiliates do not provide legal or tax advice. We recommend that all clients consult with their own legal counsel and tax professionals to ensure that the implementation of this program aligns with their specific corporate structure and regional regulations.