ASA has issued several reports over the years warning of the legal pitfalls of health insurance plans promising outsized payroll and income tax savings. In 2023, the Internal Revenue Service issued guidance and proposed regulations confirming that the plans violate basic principles of tax law. It was thought this would have settled the matter, but the plans reportedly have resurfaced and are again being promoted to staffing firms. In this article, ASA lawyers review the background of these arrangements and conclude that the current plans present the same “double dipping” problem and legal risks as before.