"[W]hat if a graduate student's financial aid package includes loans, scholarships, a paid graduate assistantship, and a subsidy to help pay the student health insurance premiums? In this case, the student is both an employee (by virtue of the paid graduate assistantship) and a student. Can the university take the position that the health care subsidy is being provided to the student in his capacity as a student, and is therefore not prohibited by the IRS and DOL? We would welcome additional guidance from the IRS and DOL on this issue.... [A]n award of taxable, unrestricted cash is clearly permitted and a safe solution."  MORE >>