2026 Employee Benefits Market Outlook 23 The second type of benefit offering allows employers to help employees pay down debt while simultaneously saving for retirement. As a result of legislation passed in late 2022, employers sponsoring 401(k) and similar retirement plans are now permitted to make matching contributions based on qualified student loan pay-ments (QSLPs) made by their participating employees. Employers seeking to offer a qualified student loan match program can rely on IRS implementation guid-ance from August 2024, which addresses a variety of plan administration issues, including: General eligibility rules, including dollar and timing limitations Employee certification requirements that student loan matching contribution requirements have been met Reasonable student loan matching contribution procedures that a plan may adopt Special nondiscrimination testing relief for 401(k) plans that include student loan matching contributions Plan sponsors may rely on this guidance for plan years beginning after Dec. 31, 2024, and should continue to monitor and prepare for proposed regulations from the Treasury Department and the IRS. These types of fringe benefits can significantly help employers attract and retain workers as more employees seek student loan support from their work-places. Given the high prevalence of education debt and the now- permanent status of the OBBBAs stu-dent loan provision, employers who do not currently offer these types of debt relief programs may want to consider establishing one. By proactively offering stu-dent loan support, employers can show employees they are valued and provide them with much-needed financial assistance and support, which may increase employee productivity, engagement and happiness. Implementation of these programs should always be done in consultation with benefits counsel to ensure compliance with documentation, nondiscrimination and other IRS requirements.
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