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student loan match programs. Although educational assistance programs have been available for many years, the option to use them to pay for student loans has only been available for payments made after March 27, 2020. Under current law, this student loan provision is set to expire on Dec. 31, 2025. While a bipartisan bill has been introduced in Congress that would extend this benefit permanently, no action has been taken yet, and with a new composition of Congress in 2025, the status of the bill remains to be seen. An educational assistance program is a separate written plan that provides educational assistance to employees. Two key requirements are that these programs must be in writing and that they cannot discriminate in favor of highly compensated employees. Traditionally, educational assistance programs have been used to pay for employees’ books, equipment, supplies, fees, tuition and other education expenses. However, at least throughout 2025, they can also be used to pay principal and interest on an employee’s qualified education loans. Payments made directly to the lender, as well as those made to the employee, may qualify. In most cases, educational benefits are excluded from federal income tax withholding, Social Security tax, Medicare tax and federal employment (or FUTA) tax. By law, tax-free benefits under an educational assistance program are limited to $5,250 per employee per year, and assistance provided above this level is typically taxable as wages. On the other hand, qualified student loan match programs allow employers that sponsor 401(k) plans, 403(b) plans, governmental 457(b) plans or SIMPLE individual retirement account plans to provide matching contributions based on employees’ qualified student loan payments rather than only on elective contributions to the retirement plan. While the option to offer this program became available in 2024, various plan administration questions were left open for employers who wanted to offer it. In August 2024, the IRS released much-needed implementation guidance for employers seeking to offer a qualified student loan match program. The guidance addressed a variety of plan administration 19

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