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Tax & Compliance8 min readMarch 18, 2026

IRS CCA Memorandum 201703013: What It Means for the PCMP

IRS CCA 201703013IRS wellness programSection 106PCMP compliance

In 2017, the IRS issued Chief Counsel Advice Memorandum 201703013, which explicitly confirmed the tax treatment of employer-provided wellness programs under §§ 105(b) and 106(a). Here's what it says.

Overview

This article provides a comprehensive overview of irs cca memorandum 201703013: what it means for the pcmp. The Preventive Care Management Program (PCMP) is an IRS-compliant benefit structure that reduces employer payroll tax liability while providing employees with a full suite of health benefits at zero net cost. Built on IRC §§ 125, 105(b), and 106(a), the PCMP has been available to employers since 1978 and is explicitly authorized by IRS Chief Counsel Advice Memorandum 201703013.

Key Takeaways

The PCMP generates $636 per W2 employee per year in net FICA savings for employers. Employees receive a comprehensive benefit suite including dental, vision, telemedicine, mental health services, and more — with no reduction in take-home pay. The program is available in all 50 states, integrates with all major payroll platforms, and includes full audit-ready documentation.

Getting Started

To learn more about how the PCMP can benefit your business, submit our online intake form. Our team will prepare a custom savings proposal for your specific workforce within 48 hours. There is no obligation and the process takes less than 2 minutes.

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Submit our intake form and receive a custom savings proposal for your business within 48 hours. Takes less than 2 minutes.

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PCMP Quick Facts

Net savings/employee/yr$636
Monthly pre-tax deduction$1,216
Employer FICA rate7.65%
Avg. enrollment rate92%+
Implementation time30–45 days
States availableAll 50
Program Compliance
IRS CompliantACA CompliantERISAHIPAAADAAll 50 States