What Oasis Plan is, per public materials
Oasis-branded preventative care and wellness plans are publicly marketed as Section 125-based programs that deliver employer FICA savings and employee benefits with no out-of-pocket cost. Publicly available materials describe these products as combining indemnity-based wellness payments with Section 125 cafeteria-plan elections. We are not affiliated with any Oasis-branded plan and have not audited their plan documents - the structural description here is based on publicly available marketing materials.
Side-by-side, structurally
| Aspect | EHP (SIMERP) | Oasis Plan |
|---|---|---|
| Tax structure (public description) | Section 125 + 105(b) reimbursement of incurred 213(d) expenses (SIMERP) | Section 125 + indemnity-based wellness payment (per public materials) |
| Payment trigger | Actually-incurred Section 213(d) qualified medical expense | Fixed payment on event participation |
| Relationship to IRS CCM 202323006 | Outside the scope of the memo | Within the scope of the memo if structured as publicly described |
| Healthcare delivery | Integrated telehealth network operated by EHP / Revive | Per public materials, varies by Oasis-branded variant |
| Plan document type | Self-insured medical expense reimbursement plan | Per public materials, insurance-policy + Section 125 combination |
Oasis Plan column is based on publicly available marketing materials. Verify against the actual plan document before relying on this characterization.
Questions to ask the Oasis Plan sales team
- Which specific Oasis-branded product am I being offered, and is it structured as a SIMERP or as a Section 125 indemnity wellness plan?
- How does the specific Oasis product reconcile its tax treatment with IRS Chief Counsel Memorandum 202323006?
- Can I see the plan document and SPD before signing?
- Is there an indemnification or hold-harmless provision for the employer if the IRS challenges the structure?
- What documentation supports the tax-free treatment of payments - per-expense incurred, or per-event participated in?
A vendor that can answer all of these questions in writing - with reference to the actual plan document and to IRS guidance - is a vendor worth taking seriously.
Where IRS CCM 202323006 fits
In 2023, the IRS Chief Counsel published Memorandum 202323006, which addressed fixed-indemnity wellness plans funded through Section 125 cafeteria-plan elections. The memo concluded that fixed-indemnity payments to employees under those structures should be treated as taxable wages - meaning the structure does not deliver the tax savings vendors had advertised.
The memo applies to fixed-indemnity-structured products. It does not apply to SIMERPs, which reimburse employees for actually-incurred Section 213(d) qualified medical expenses. The EHP program is structured as a SIMERP and is outside the scope of the memo. Whether Oasis Plan falls within the memo's scope depends on its actual plan structure.
When Oasis Plan might actually be the right choice
If you've already vetted a specific Oasis-branded product with your benefits counsel and concluded the structural posture is acceptable for your situation, that's a defensible choice. The honest answer for most prospective buyers is to confirm the structure (SIMERP vs indemnity) before evaluating headline savings claims.
Common questions
No - there are multiple Oasis-branded preventative care and wellness products in market from different vendors. Treat each as a distinct product and verify its specific structure separately.
'Does this plan reimburse me for an incurred Section 213(d) qualified medical expense, or does it pay a fixed dollar amount on a trigger event?' Reimbursement-of-incurred is a SIMERP. Fixed-payment-on-trigger is an indemnity structure within the scope of CCM 202323006.
The headline employer FICA savings figure will look similar across products because all of them use the Section 125 pre-tax election as the savings mechanism. The downstream tax treatment of the employee payment - and therefore whether the savings hold up at audit - depends on the structure.
Trademark notice. Oasis Plan is the trademark or trade name of its respective owner. We use the name nominatively to identify the product being compared. We are not affiliated with, endorsed by, sponsored by, or otherwise connected to Oasis Plan or its operators.
Affiliate disclosure. We are an independent affiliate of EHP / Revive Health and earn a referral fee when employers we introduce enroll. This page is not legal advice, tax advice, or audit advice. Always consult your own benefits counsel, CPA, and (where appropriate) labor counsel before adopting or replacing any benefits program.