Coronavirus Stimulus Deal’s Impact on Employee Benefit Plans


On March 27th, Congress passed a stimulus package in response to the Coronavirus/COVID-19 pandemic.  The package, which is entitled the Coronavirus Aid, Relief, and Economic Security Act (the “CARES Act” or the “Act”), contains several provisions that affect employee benefits.

Retirement Plans

Health Plans

Student Loans

The Act allows employers to reimburse or pay up to $5,250 of an employee’s student loan payments through a Code Section 127 education assistance plan.  This expansion applies only for loan payments (whether to the employee or directly to the lender) made by the employer after enactment and before January 1, 2021. The $5,250 limit is an aggregate limit for other permitted educational assistance and loan repayments combined.  Section 127 arrangements are subject to certain technical requirements, including nondiscrimination and a plan document.  For employers that already have Section 127 plans, this change can be implemented by an amendment to the definition of qualifying expenses.  The Act also prohibits “double-dipping” by employees: employees may not deduct amounts that are reimbursed or paid by the employer.


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National Law Review, Volume X, Number 87