8890.02 / What is a qualified student loan payment for purposes of the post-SECURE Act employer retirement matching option?

Only payments that are classified as qualified student loan payments (QSLPs) can be considered in the employer’s matching program. A qualified student loan payment is one that is made on a loan taken for the sole purpose of paying qualified education expenses for the individual, a spouse or someone who was the individual’s dependent at the time the debt was incurred. The loan must be for education provided during an academic period for an eligible student and the expense must be paid or incurred within a reasonable period of time before or after the debt was incurred.¹

Qualified education expenses include tuition, fees, books, and other similar required expenses incurred by an eligible student. An eligible student, in turn, is someone who is enrolled at least half-time (with at least six credit hours) in some type of program of study that is designed to lead to a degree, certificate or other type of recognized education credential at an eligible education institution.

Expenses incurred for games, sports, hobbies, or non-credit activities do not qualify.

The law does not specify whether the student must have graduated from or completed the program in order for the related student loan debt to qualify. Because the student loan matching program is entirely optional, it seems possible that the employer may be entitled to decide whether graduation is a requirement for receiving the benefit.